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Industry Requests More Time to Comment on FAA Order 8130.21J

Update: On April 17, the FAA notified the industry signatories that it had extended the comment deadline to June 6, 2025.

On March 28, ARSA joined 11 ally trade associations in requesting the FAA provide more time to comment on Draft Order 8130.21J, “Completion of FAA Form 8130-3 under Part 21.” As announced by FAA Director of Aircraft Certification Caitlin Locke during ARSA’s Annual Conference, the draft was posted on March 19 with a 33 day comment period. The group requested an additional 60 days so it could coordinate analysis of the draft through June 23.

“Past experience with unintended consequences arising from 8130-3 guidance has shown that the industry can be dramatically affected (and consequently safety is affected) by choices in the related guidance,” the request said. “The entire industry wants to help the FAA avoid unintended consequences arising from 8130.21J.”

Locke highlighted the 18 page Draft Order during the Annual Conference as representing FAA effort to curtail expansive guidance documents: “[Order 8130.21] used to be…75 pages and now it’s 18. [The agency wants to highlight] examples of where we’re able to do that, where we’re able to meet the intent of what the guidance or the policy is for, to give the explanatory information that’s needed, but not add so much that then you need more guidance to interpret what you said because what you said before wasn’t clear, so you’re saying it again and now it’s not clear and you have six more forms and you don’t know why.”

In support of that effort and to reinforce the value of guidance as instructive but not regulatory, the aerospace community must ensure it’s provided time – as a partner to its regulator – to thoroughly review agency policy updates.

To read the Draft Order, click here.

To read the industry’s request for more time to comment, click here.

ARSA members should stay tuned from more updates (and clips) from the 2025 Annual Conference in the March edition of the hotline newsletter.

In addition to ARSA, the following trade associations supported the request:

Aircraft Owners & Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
Commemorative Air Force
Experimental Aircraft Association
International Air Transport Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association

Previous updates on recordkeeping guidance...




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