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ARSA Presses for Rule-based Guidance

On Nov. 14, ARSA sent a letter to FAA Chief Counsel Arjun Garg expressing concern with the disconnect between agency guidance and the aviation safety rules.

The letter noted that compliance “begins and ends with the plain language of the rules,” quoting the association’s welcome message to Administrator Steve Dickson (read a public version via the August 2019 Aviation Week/MRO Network Editorial “Dear Mr. Administrator”). Recognizing this principle and citing President Trump’s Oct. 9 Executive Order “Promoting the Rule of Law Through Improved Agency Guidance Documents,” the message to Garg sought immediate attention for two FAA orders:

(1) FAA Order 8000.373A, “Federal Aviation Administration Compliance Program” (Oct. 31, 2018). The document purports to provide methods for the agency and the industry to work through compliance issues that do not pose a risk to the aviation safety system. As the language now stands, agency personnel can base, and are basing, decisions upon “guidance”, which unfortunately does not always comport with the rules.

(2) FAA Order 8900.1, Volume 1, Chapter 1, Section 1 (May 3, 2019). This document contains guidance to aviation safety inspectors (ASI) on certification and surveillance activities. It must be clear that regulations trump any guidance.

“ARSA urges the Chief Counsel’s Office to take immediate action to conform the above-referenced documents to basic principles of administrative law,” the letter to Garg said, providing specific recommendations for revising each order.

In addition to citing the October executive order, the letter referenced instructions from the Departments of Justice and Transportation as well as the Office of Management and Budget. To see ARSA’s analysis of these documents and their implications for aviation oversight, refer to the April 2018 and March 2019 editions of the hotline or “Are We There Yet?” in the June 2019 edition of DOM Magazine.

To read the complete letter, click here.

Previously from ARSA...

10/19/15 - ARSA, AIA, GAMA Support Development of AFS Guidance Methodology

October 19, 2015

On Oct. 9, ARSA joined the Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) on comments to the Flight Standards Service’s (AFS) Draft Order 8000.AFSGDD, “Flight Standards Service Guidance Document Development.”

The draft follows the recommendations of the Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC), on which all three associations participated. The comments applaud the FAA for working to broadly apply standardization principles already employed by the Aircraft Certification Service (AIR) in Order 8100.16.

“The proposed FAA Order 8000.AFSGDD represents an important step in promoting consistency of regulatory interpretations and application,” the comments state. “As stated in the CRI ARC, one of the root causes of inconsistency was inadequate and nonstandard regulatory application. The ARC highlighted that the absence of guidance development instructions for FAA personnel allowed for guidance to be published that was not based [on] or consistent with regulations which contribute to inconsistent application of the rule and confusion.”

To assist with the process, the associations provided suggested clarity in 8000.AFSGDD to ensure that rules and statutes take precedence over guidance material. With careful review for consistency, the final order will be an effective tool for regulators while shaping aviation safety and business practices.

FAA Follows CRI ARC Recommendation in Draft AFS Order

September 15, 2015

On Sept. 10, the FAA released draft Order FS 8000.AFSGDD, “Flight Standards Service Guidance Document Development,” for comment. The draft order supports the agency’s efforts to provide internally and externally consistent guidance by instructing Flight Standards Service (AFS) personnel.

The document follows the CRI-ARC’s recommendation for ensuring clear and consistent methods for creating and changing guidance and includes tips for agency writers as well as details on when, how and why it should be issued. The information is presented in a straightforward and concise manner and will help regulators while shaping aviation safety and business practices:

Order FS 8000.AFSGDD, Flight Standards Service Guidance Document Development: This order establishes the policy and guidelines for AFS personnel who develop, update, or change AFS directives and advisory circulars (AC). For more information and for instructions on how to comment, visit

The draft is open for 30 days, with comments due on Oct. 9.

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