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Aircraft Parts, aviation, FAA, FAA Design Approval, Manufacturing, PMA, Policy

FAA Sequencing Decision is Coming – File Your Comments Now

Is it possible that YOUR company could get shut out of the race for FAA resources? Could a government policy put you at the back of the line for getting your PMA approved?

Time is rapidly running out on your opportunity to file comments on the government policy that will allocate FAA certification and approval resources that are critical for approving PMA projects.

The FAA does not have enough resources to simultaneously work on every single PMA, STC, and other certification or approval project that comes along.  The FAA Aircraft Certification Offices (ACOs) need to find fair ways to allocate their resources and prioritize projects.  The process for allocating ACO resources is known as “Sequencing.”

This FAA Sequencing Procedure is very important to companies that work with the FAA.  It provides guidance about how to make sequencing decisions – these are the internal FAA decisions about which projects will get FAA resources and which ones will be delayed.  This has a tremendous impact on business and profitability, because the FAA approval process is often a bottleneck on innovation. A safety improvement project that is delayed for weeks or months could inhibit safety not only because of the delay, but also because for many companies – particularly smaller ones – delay can mean the difference between whether the company is successful or whether the company may run out of financing before it can bring its safety improvement to the marketplace.

In its original form, the sequencing guidance gave a tremendous advantage to large type certificate holders, especially when compared to PMA applicants.  But this advantage cut across all projects, so a large type certificate holder that was developing the same STC project as a small independent develop would get FAA resources faster under the proposed sequencing procedures.

Last year, after MARPA filed its comments on the FAA’s proposed Sequencing Procedure, the FAA extended the comment period to an entire year.  That comment period now ends October 31, 2012 (after being opened in 2011).

MARPA’s comments focused on making sure that smaller companies, including PMA companies, would receive fair access to government resources when they work on their certification and approval projects with the FAA.

MARPA’s comments on the sequencing proposal are available on the MARPA website.

How do you comment? You can email comments to: renton.bean@faa.gov .  You can also mail comments to:

Renton Bean
AIR-100
FAA National Headquarters
950 L’Enfant Plaza North, S.W.
5th Floor
Washington, DC 20024

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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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