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aviation, Continued Operational Safety, FAA, FAA Design Approval, Manufacturing, PMA, Policy, Regulatory, Safety Management Systems

What Does it Cost YOU to Meet FAA Requirements?

As many of you know, MARPA is working on the FAA’s Aviation Rulemaking Committee (ARC)  that is rewriting the manufacturing rules to address Safety Management and Design Organization elements.  One of the things that the FAA wants to track is the cost-benefit data, to ensure that the project will reflect a positive benefit for the industry (as well as for the FAA).

To this end, we are seeking data about what we should track to estimate costs.  We would appreciate answers to the following questions (note that we are seeking information about categories of costs, and not yet seeking numbers for costs):

  • What costs do you track internally that we could use as a baseline for certification or design costs?
  • What costs go into the certification/approval process?
  • What costs go into Continued Operational Safety?
  • Do you track how much it costs to bring a new article to market?
  • Do you track how much it costs to do the certification/approval piece of bringing a new article to market?
  • Could you estimate a cost per day associated with the certification/approval process (e.g. if we could speed up the process of getting a PMA, could we calculate a benefit based on the time that was saved)?

At this time, WE ARE NOT COLLECTING ANY NUMBERS!!  We are trying to identify what are the right questions to ask.  This information will be used to develop a certification cost survey for the membership, and THEN we will be in a position to ask for numbers.  When we ask for numbers, we will do it in such a way that individual company data will be protected.

[so you should be planning on eventually getting us hard numbers in these general areas]

Please get us your answers ASAP. We will plan on asking for this sort of data again in the August MARPA Supplement but it would be useful to get the initial data by the end of July.

The FAA has asked to use our Conference as an opportunity to collect industry data, so we will be developing data models during the summer in order to support those efforts.  We are hoping to develop metrics for measuring our industry’s costs between now and then, so that by the time of the MARPA Conference in October, we will have a robust model upon which to rely.


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 Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.



  1. Pingback: Help MARPA Understand Your Costs of Regulatory Compliance | MARPA - August 21, 2013

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