Regulatory and Certification Policy

Regulatory Brief

Airworthiness Concern Process

The issue:

The Airworthiness Concern Process (ACP, is a cooperative information sharing initiative between Industry and FAA intended to increase industry participation in the development of airworthiness issues before (or in lieu) of a proposed or final Airworthiness Directive (AD) for an aircraft. The ACP has been successfully employed for airframe related concerns for nearly 2 years. As a result of AOPA's efforts, the ACP was recently expanded to include engine and propeller related airworthiness issues. An important element of this official FAA process is AOPA Online, which serves as a "central hub" for distribution of airworthiness concern sheets to aircraft type-clubs, and submittal of type-club comments to the FAA.

The importance to our members:

The Airworthiness Concern Process is an official part of FAA policy that requires the FAA to solicit industry involvement in the development of airworthiness concerns before proposing or issuing an AD. This groundbreaking process affords aircraft owners and operators a valuable opportunity to provide the FAA input into what mitigating actions (if any) are necessary to remedy an airworthiness concern. Before ACP, FAA had no direct link to the real world operational and maintenance knowledge and expertise offered by aircraft type-clubs and their owner/operator members. ACP provides AOPA, aircraft type-clubs, and other organizations an opportunity to analyze potential concerns, verify whether or not they're actually occurring, and recommend the safest/most economically viable means of mitigation.

Significant provisions:

• Developed through a cooperative effort between, AOPA, aircraft type-clubs, FAA Small Airplane Directorate, FAA Chicago Aircraft Certification Office, and other aviation organizations
• Has been employed since July 2000 for airframe related airworthiness issues
• ACP is included as a supplement in FAA's Airworthiness Directive Manual (FAA-AIR-M-8040.1)
• Requires that FAA solicit industry input before proceeding with a proposed or final AD — except in emergency situations
• Upon identifying a concern, FAA must detail the concern on an airworthiness concern sheet and distribute it appropriate organizations and type-clubs for input
• AOPA Online serves as the "central hub" for distribution of airworthiness concern sheets to aircraft type-clubs, and submittal of type-club comments to the FAA
• Participating type-clubs have password protected access to the AOPA Online Airworthiness Concern web page - where they may download copies of Airworthiness Concern Sheets and supporting service information, view other organization's comments, and submit their association's comments directly to the FAA
• AOPA receives all Airworthiness Concern Sheets, posts them to the password protected type-club web page, and notifies appropriate type-clubs of any concerns applicable to their members' aircraft
• AOPA provides support, advice, and direction to type-clubs during all phases of the process, including research and development of comments
• AOPA draws upon the make/model specific operational and maintenance knowledge of participating type-clubs in the development of our comments, and often wholly supports the position of the type-club commenters
• Members unsure of their aircraft type-club's involvement in the ACP should contact their type-club officials directly for more information
• Aircraft type-clubs interested in participating in this process may contact the AOPA Airworthiness Concern Process team at AWC@aopa.org

AOPA position:

The Airworthiness Concern Process provides the GA community some much-needed access to FAA's continued airworthiness process. As the GA fleet continues to age and manufacturer support continues to dwindle, increased industry participation in the development of airworthiness actions is necessary to ensure the continued operational viability of the GA piston fleet. Increased industry participation through ACP has proven to decrease the cost and complexity of airframe related airworthiness concerns while maintaining an equivalent level of safety. AOPA is pleased that the FAA has agreed to expand ACP to include Engine and Propeller related concerns, and is confident that expansion of ACP into this new area will produce very favorable results.

Status:

• May 10, 2002, FAA Engine and Propeller Directorate officially agreed to full participation in the Airworthiness Concern Process
• July 21, 2000, ACP became an official part of FAA policy via the "Small Airplane Directorate Airworthiness Directives Manual Supplement (Airworthiness Concern Process Guide)"
• October 14, 1998, First airworthiness concern process developmental meeting between AOPA, FAA, aircraft type-clubs and other organizations