On July 2, MARPA filed comments with the FAA in response to the draft Standard Operating Procedure Aircraft Certification Service Project Prioritization and Resource Management. The SOP, commonly referred to as “sequencing,” is intended to assist the FAA in prioritizing certification projects submitted for FAA approval in order to get the most out of its limited resources. The goal of sequencing is to give priority to those projects that should have the most significant and immediate effect on safety.
Unfortunately, the policy as written misses out on clearly offering additional safety benefits, and disproportionately favors large businesses over small businesses, while offering no sound policy or safety rationale for this favoritism.
MARPA’s comments identified a number of problems with the policy. The factors and criteria established by the FAA and used to determine a ranking for the purposes of prioritization appear in many ways to be arbitrarily established, with no identified methodology or basis for the calculation of the assigned values. Additionally, the determination of the safety impact of a given project (a significant factor in calculating priority) appears to be left to the subjective evaluation of individual FAA offices or even individual employees. Such subjectivity creates the possibility that identical projects may be assigned a higher or lower priority based on the opinion of an individual employee.
Even when evenhandedly applied, the policy may negatively affect the ability of small businesses to compete with large companies and OEMs, based not upon the safety benefits of their projects, but almost entirely upon the resources available to the companies.
MARPA understands and appreciates the FAA’s efforts to optimize the use of their resources to provide the greatest possible safety benefit to the industry and the flying public. MARPA consistently works with the FAA to optimize its resources and enhance safety, through initiatives such as the Streamlined PMA Process, and participation on rulemaking committees. MARPA looks forward to continuing to work with the FAA to better improve aviation safety and resource commitment.