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Aircraft Parts, FAA, Policy, Regulatory, Repair Stations

AMOC Guidance – Revision Available for Review and Comment

The FAA has published a draft document for public comment, entitled “Draft Order 8110.103A, Alternative Methods of Compliance.”  I know that this is a very important issue for many of us in the PMA community, so the revisions should bear careful scrutiny.

The FAA has summarized the revisions to the Order as follows:

Summary: This order revision incorporates a clarification and deviations issued since the initial publishing of the order. These include:

  • clarification of who can be granted delegated signature authority for AMOC approval /denial letters
  • approval of AMOCs for foreign-registered aircraft
  • coordination of AMOCs with flight standards personnel, using AEG coordination criteria
  • procedures for handling urgent “after hours” (24/7) AMOC requests
  • approval of AMOCs by means other than a letter (i.e. email or FAX)
  • a new boiler plate statement in AMOC approval letters that requires operators notify their PI/FSDO/CHDO before using
  • removal of the requirement for the AMOC revocation statement in global AMOC approval letters

It also incorporates additional guidance for writing AMOC approval statements, feedback, and other improvements.

The draft is available online at  Please look at it and provide MARPA with your comments by July 22, 2010, so we can incorporate them into the Association’s comments.

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.


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