Alternative Methods of Compliance (AMOC)

U.S. DEPARTMENT OF TRANSPORTATION ORDER FEDERAL AVIATION ADMINISTRATION 8110.103C National Policy Effective date: 05/11/2026 SUBJ: Alternative Methods of Compliance (AMOC) This order provides guidance to Federal Aviation Administration (FAA) personnel and FAA designees who handle alternative methods of compliance (AMOC) proposals to airworthiness directives. This order explains how to determine if an AMOC is needed, the process to follow, and other AMOC considerations pursuant to Title 14 of the Code of Federal Regulations (14 CFR) Part 39.

Digitally signed by

DANIEL

DANIEL J. ELGAS Date: 2026.05.11

J. ELGAS

13:03:01 -04'00' Daniel J. Elgas Director, Policy and Standards Division Aircraft Certification Service Distribution: Electronic Initiated By: AIR-600 8110.103C Table of Contents Paragraph Page Chapter 1. General Information ................................................................................................... 1-1 1. Purpose of This Order. ................................................................................................ 1-1 2. Audience...................................................................................................................... 1-1 3. Where to Find This Order. .......................................................................................... 1-1 4. What This Order Cancels. ........................................................................................... 1-1 5. Explanation of Policy Changes. .................................................................................. 1-1 6. Effective Date.............................................................................................................. 1-2 Chapter 2. What is an AMOC? .................................................................................................... 2-1 1. Defining an AMOC. .................................................................................................... 2-1 2. When and Why an AMOC Is Necessary or Desirable. ............................................... 2-1 3. Who Approves an AMOC? ......................................................................................... 2-2 Chapter 3. The AMOC Process ................................................................................................... 3-1 1. AMOC Process Flowchart........................................................................................... 3-1 2. The AMOC Proposal................................................................................................... 3-1 3. Delegated AMOCs. ..................................................................................................... 3-1 4. Assigning Evaluator and Checking FAA Authority.................................................... 3-4 5. Level of Safety Determination. ................................................................................... 3-4 6. Is AED Coordination Required? ................................................................................. 3-4 7. Coordination with PI/FSDO/CHDO/IFO.................................................................... 3-5 8. Coordination with Legal Counsel................................................................................ 3-5 9. Proper Methods of Responding to AMOC Proposals. ................................................ 3-5 10. How to Approve an AMOC. ....................................................................................... 3-6 11. Denying an AMOC Proposal. ..................................................................................... 3-8 12. How to Route the Response. ....................................................................................... 3-9 13. Compile Records and Storing in Office Files. .......................................................... 3-10 14. Distribution of Responses. ........................................................................................ 3-11 Chapter 4. Additional AMOC Considerations ............................................................................. 4-1 1. Amending an AMOC Response. ................................................................................. 4-1 2. Revoking an AMOC.................................................................................................... 4-1 3. Global AMOCs (AMOCs of General Applicability). ................................................. 4-2 ii 8110.103C Table of Contents Paragraph Page 4. AMOC Proposals from Foreign Entities. .................................................................... 4-3 5. AMOC Proposals for Foreign-Registered Aircraft. .................................................... 4-3 6. Military Commercial Derivative Aircraft (MCDA).................................................... 4-4 7. Sharing AMOCs with DAHs....................................................................................... 4-4 8. Appliance AMOCs, Including Technical Standard Order (TSO)-Approved Articles.4-4 9. AMOCs Involving Certification Projects.................................................................... 4-5 10. Public Requests for Copies of AMOCs....................................................................... 4-6 Chapter 5. Administrative Information........................................................................................ 5-1 1. Distribution.................................................................................................................. 5-1 2. Authority to Change This Order.................................................................................. 5-1 3. Related Material. ......................................................................................................... 5-1 4. List of Acronyms......................................................................................................... 5-1 5. Suggestion for Improvements. .................................................................................... 5-1 6. Records Management. ................................................................................................. 5-1 Appendix A. Criteria for Coordinating AMOC Proposals with AED ........................................ A-1 Appendix B. Guidance on Writing an AMOC Approval Statement ...........................................B-1 Appendix C. Examples of How NOT to Write AMOC Statements ............................................C-1 Appendix D. AMOC Approval Response Checklist .................................................................. D-1 Appendix E. 24/7 FS AMOC Urgent Request Support ...............................................................E-1 Appendix F. AMOC Response Template .................................................................................... F-1 Appendix G. Related Material .................................................................................................... G-1 Appendix H. List of Acronyms................................................................................................... H-1 Appendix I. Directive Feedback Information ...............................................................................I-1 iii 8110.103C List of Figures Figure Page Figure 3-1. AMOC Process Flowchart ........................................................................................ 3-2 Figure B-1. Example of an AMOC Approval Requirements Chain ........................................... B-1 Figure E-1. 24/7 AMOC Procedures ...........................................................................................E-2 List of Tables Table Page Table 3-1. AMOC Response Distribution for FAA ADs .......................................................... 3-11 Table A-1. AED Coordination Criteria....................................................................................... A-1 iv 8110.103C Chapter 1. General Information 1. Purpose of This Order. This order provides information to FAA staff and designees on how to handle alternative methods of compliance (AMOC) proposals to airworthiness directives (AD). This order shows how to— a. Identify who can approve or deny an AMOC proposal; b. Handle urgent requests for AMOC support; c. Differentiate between a transferable and a non-transferable AMOC; d. Properly coordinate an AMOC approval or denial; e. Handle global AMOC proposals (also known as an AMOC of general applicability); and f. Handle AMOC proposals from other civil aviation authorities (CAAs) and foreign owners/operators.

2. Audience. All FAA Aircraft Certification Service (AIR) personnel responsible for AMOCs.

It is also written for Flight Standards Service (FS) inspectors, Aircraft Evaluation Division (AED) personnel, and certain designated engineering representatives (DERs), as well as type certification organization designation authorization (ODA) holders.

3. Where to Find This Order. You can find this order and other FAA documents referenced in this order on the FAA employee website, on the FAA public website, and in the FAA Dynamic Regulatory System (DRS).

4. What This Order Cancels. This order cancels FAA Order 8110.103B, Alternative Methods of Compliance (AMOC), dated September 14, 2016.

5. Explanation of Policy Changes. This order incorporates the following changes: a. Updates organizational references to reflect the current AIR organizational structure.

b. Updates organizational references to reflect the current FS organizational structure.

c. Replaces the CAA contact information in table 3-1 with the newly created global AMOC email address.

d. Clarifies certain procedures for delegated AMOCs.

e. Incorporates deviations and clarifications issued against the previous revision of this order.

f. Adds chapter 5, Administrative Information, and appendices G and H.

1-1 8110.103C 6. Effective Date. This order becomes effective on .

1-2 8110.103C Chapter 2. What is an AMOC?

1. Defining an AMOC.

a. Section 39.11 states: “Airworthiness directives specify inspections you must carry out, conditions and limitations you must comply with, and any actions you must take to resolve an unsafe condition.” An AMOC provides an acceptable level of safety for a different way, other than the one specified in the AD, to address the unsafe condition.

b. This order uses the general term “AMOC” to define an FAA-approved alternative method of compliance to the specific requirements of an AD or a change in the required time to accomplish the AD. The term “product” refers to an aircraft, aircraft engine, propeller, or appliance pursuant to § 39.3.

c. In August 2002, the FAA amended Part 39 (Amendment 39-9474). The amendment incorporated several provisions previously included in individual ADs. One such provision specified that the AD apply to the product even if it had been modified, altered, or repaired in the area addressed by the AD. Another such provision identified procedures for asking the FAA to approve AMOCs to the AD.

2. When and Why an AMOC Is Necessary or Desirable.

a. An AMOC is required if an owner/operator cannot comply with or finds a different way to comply with the actions specified in an AD.

b. The reasons an AMOC may be necessary or desirable include, but are not limited to, the following— (1) To accomplish AD actions in a way that better suits an owner/operator’s individual processes; (2) Because an owner/operator devises a different or better way of addressing the unsafe condition; (3) Because an owner/operator wishes to adjust the compliance time stated in an AD; (4) Because existing modifications, alterations, or repairs to a product make compliance with AD actions difficult or impossible; (5) To use later revisions of service documents specified in an AD; (6) Because a superseding AD invalidates AMOCs issued against the previous AD; (7) To address errors in the service document; or (8) To address errors in the AD.

2-1 8110.103C Note: For an error in an AD, an AMOC can be an expeditious way to alert affected owners/operators of the error and the correction. However, if the error affects the substance of the AD or expands its scope, the AD must be superseded to eliminate the error and ensure the broadest availability of the correction.

3. Who Approves an AMOC?

a. Each AD identifies the office responsible for approving AMOCs to the AD, referred to hereafter as the responsible office.

(1) For products where the United States is the State of Design (SoD), the responsible office will be the appropriate AIR-500 or AIR-700 branch (a Certification Branch, Continued Operational Safety Branch, or Operational Safety Branch).

(2) For products where the United States is not the SoD, the responsible office will be the appropriate certificate managing office in either AIR-500 or AIR-700.

(3) Sometimes the responsibility for design approval is transferred from one office to another office, such as when a type certificate is transferred. When this happens, the responsibility for approving AMOCs for that product also transfers with the design approval.

(4) When the office identified in the AD receives an AMOC proposal for a product that has transferred, that office is responsible for forwarding the AMOC proposal to the office currently responsible for approving or denying the AMOC.

(5) In cases involving a large fleet of products, or when a high volume of AMOCs may be likely, the FAA may choose to send a letter to industry organizations notifying them of the transfer. This notification helps direct AMOC proposals directly to the responsible office, thereby eliminating delays resulting from one office having to transfer proposals to the correct office.

b. The FAA has authorized certain company DERs and ODA holders to review and approve AMOC proposals. Refer to chapter 3, paragraph 3 of this order for more details.

c. Principal inspectors (PI) may not approve an AMOC proposal, but they may comment on AMOC proposals they receive (such as pointing out the unique characteristics of the requester’s fleet and operation, or indicating whether the operator can reliably accomplish the requirements of the AMOC proposal) before forwarding it to the manager of the FAA office identified in the AD.

Note: For the purposes of this order, a PI can be a principal maintenance inspector, principal avionics inspector, or principal operations inspector.

2-2 8110.103C Chapter 3. The AMOC Process 1. AMOC Process Flowchart. Figure 3-1 of this order depicts the AMOC process in a high- level flowchart. The following paragraphs explain the steps.

Figure 3-1. AMOC Process Flowchart 3-2.

AMOC START Proposal 3-3.

3-3 DER/ODA Holder Is AMOC Follow AMOC process in FAA Yes delegated to DER/ orders 8110.37 & 8100.15, as ODA holder?

applicable & para 3-3. of this order No 3-2.b.

Legend 3-7.d.

Was AMOC AED – Aircraft Evaluation Division Evaluator received through PI/ No AMOC – Alternative Method of Compliance Notify PI/FSDO/CHDO/IFO FSDO/ CHDO – Certificate Holding District Office for opportunity to comment DER – Designated Engineering Representative CHDO/IFO?

FSDO – Flight Standards District Office IFO – International Field Office Yes ODA – Organization Designation Authorization PI – Principal Inspector 3-2.c.

Proceed to Did PI/FSDO/CHDO/ 24/7 IFO request urgent Yes procedures “after hours” (Appendix E) support?

Use criteria in Appendix A No 3-7.

3-5. 3-4. If 24/7 Evaluator 3-6.

Procedures Evaluator Evaluator PI/FSDO/ Evaluator don’t apply Does it provide an Does FAA have Yes No Yes CHDO/IFO Is AED coordination acceptable level authority to issue is the point of required?

of safety? AMOC?

contact Yes No New Information 3-6.b.

3-11.

Evaluator Evaluator Add AED to Notify requester coordination grid to resolve deficiencies No Cannot Resolve 3-10.a.

3-11.

Evaluator Evaluator No Recommend Draft denial AMOC response approval?

Refer to Yes Appendices B & C, and F 3-10.d.

3-9. & 3-10.c. 3-12.

(if applicable) Evaluator 3-12.b.

Evaluator Evaluator Review draft response Manager* Draft AMOC approval Route draft against checklist (optional) Authorize Response response response (Appendix D) 3-14.

3-13.

Responsible Office Evaluator Records Distribute AMOC END *or person delegated Compile & store response to appropriate AMOC approval/ records organizations.

denial authority 3-1 8110.103C 2. The AMOC Proposal. Section 39.19 states in part that “anyone may propose to FAA an alternative method of compliance or a change in the compliance time, if the proposal provides an acceptable level of safety.” a. Although a letter is preferred, AMOC proposals may be submitted by other means, such as email, fax, or telephone. AMOC proposals received by telephone must be documented.

b. AMOC proposals should be sent to the responsible office through the PI, unless the requester does not have a PI, as in the case of a design approval holder (DAH). When the requester does not have a PI, the AMOC proposal is sent directly to the manager of the FAA office identified in the AD.

c. If a PI, Flight Standards District Office (FSDO), Certificate Holding District Office (CHDO), or International Field Office (IFO) identifies an urgent need for AMOC support outside of normal business hours, follow the process outlined in appendix E of this order.

Note: A CHDO is the FSDO responsible for administering the certificate and is charged with the overall inspection of the certificate holder’s operations.

d. Refer to Advisory Circular (AC) 39-10, Alternative Methods of Compliance, for the requester’s responsibilities regarding AMOC proposals.

3. Delegated AMOCs.

a. The FAA authorizes certain company DERs or type certificate ODA holders to review and approve AMOC proposals. For information on what the ODA holder and DER can do within this delegated authority, refer to FAA Order 8100.15, Organization Designation Authorization Procedures, and FAA Order 8110.37, Designated Engineering Representative (DER) Handbook.

(1) The AD will identify if the AMOC approval authority is delegated. For ADs that do not include an AMOC delegation section, AMOC approval authority may be delegated— following the guidance in FAA Orders 8100.15, Organization Designation Authorization Procedures, and 8110.37, Designated Engineering Representative (DER) Handbook , as appropriate—through a process established between the responsible office and the DAH. AMOC approval authority that has been delegated by the FAA and approved by the designee requires no further FAA approval. The responsible office can delegate AMOC approval authority only for ADs where the requester intends to restore a product to its type certification basis or other known, defined, and published standards. This includes the following: (a) Certain AD-mandated structural modifications, alterations, or repairs, including those where no previous FAA-approved action exists.

(b) Fully substantiated temporary structural repairs if the standards required by the AD are well defined.

(c) The approval of an alternative inspection method, threshold, or interval where a repair or modification results in the inability to accomplish the existing AD-mandated inspection or necessitates a change in the existing AD inspection threshold. The standard for 3-2 8110.103C these approvals is the appropriate damage tolerance regulation (for example, 14 CFR 25.571, Amendment 25-45 or later).

(d) Non-structural minor deviations not associated with correcting the unsafe condition as documented and agreed to between the FAA and designee. The deviation must not have an adverse impact on the prescribed corrective action intended to address the identified unsafe condition. For example, if the location of a bracket is a part of, or the cause of, the unsafe condition described in the AD, it is not appropriate for an AMOC to allow a deviation from the bracket relocation requirement specified in the AD.

(e) In coordination with the responsible office, when the designee has documented a pattern of identical approvals and it has been demonstrated that the AMOC is applicable to a defined set of products, the designee may be authorized to approve either a global AMOC or an individual AMOC applicable to multiple products (such as in the case of rotable or un-serialized parts), on a case-by-case basis, for any of the conditions identified in chapter 3, paragraphs 3a(1)(a) through 3a(1)(d) of this order.

(2) When reviewing an AMOC proposal, the designee is not required to coordinate with the AED/PI/FSDO/CHDO/IFO. However, the designee must consider whether the AMOC proposal is transferable and include a statement to that effect on their approval (refer to chapter 3, paragraph 10b of this order).

(3) The responsible office must ensure that the DERs and ODA holders follow restrictions applicable to foreign-registered aircraft (refer to chapter 4, paragraph 5 of this order).

(4) For an AMOC intended solely for a foreign-registered aircraft or for a global AMOC that could apply to foreign-registered aircraft, include the following statement on the approval: “This AMOC only applies to the FAA AD listed above. The FAA does not have the authority to approve this as an AMOC to any AD issued by another civil aviation authority (CAA). Approval of an AMOC to another CAA’s AD must come from that CAA.” (5) The responsible office can remove authority for approving AMOCs at any time and for any reason it deems appropriate. Refer to FAA Order 8000.95, Designee Management Policy, for more information on removing a DER’s authority. Refer to FAA Order 8100.15, Organization Designation Authorization Procedures, for more information on removing an ODA holder’s authority.

b. The FAA may authorize an ODA holder the authority to approve global AMOCs for administrative (non-technical) corrections to a service bulletin referenced in an AD, provided a procedure is in place for such approvals. Refer to FAA Order 8100.15, Organization Designation Authorization Procedures, for the specifics regarding this procedure.

c. Distribute delegated AMOCs in accordance with chapter 3, paragraph 14 of this order.

3-3 8110.103C 4. Assigning Evaluator and Checking FAA Authority.

a. The responsible office assigns an evaluator to the AMOC proposal if the office has not delegated AMOC approval authority pursuant to chapter 3, paragraph 3 of this order. The evaluator can be an aviation safety engineer, flight test engineer, or pilot, as appropriate.

b. If the AMOC proposal is for an AD issued by another CAA, the FAA does not approve the proposal because approval is the responsibility of the CAA that issued the AD. The evaluator drafts a denial response pursuant to chapter 3, paragraph 11 of this order.

c. If an AMOC proposal is for an FAA AD for a foreign-registered aircraft, the FAA can approve the proposal, but the CAA of the State of Registry (SoR) is responsible for authorizing the use of the AMOC. Refer to chapter 4, paragraph 5 of this order for more information on AMOC proposals for foreign-registered aircraft.

5. Level of Safety Determination.

a. Evaluate the data submitted along with the information (such as risk analysis) used to support the decision to issue an AD and, using best engineering judgment, determine if the AMOC proposal provides an acceptable level of safety. If necessary, consider reaching out to subject matter experts if there are specialized aspects involved (safety critical information (reference 49 USC 44704(e)), human factors, systems safety analysis, etc.). Contact the requester to obtain missing or additional information. For imported products, the evaluator may consult with the CAA of the SoD for information to assist in making the safety determination.

b. If the AMOC proposal provides an acceptable level of safety, continue with the AMOC process outlined in chapter 3, paragraph 6 of this order.

c. If the AMOC proposal does not provide an acceptable level of safety, consider giving the requester an opportunity to address any deficiencies. If any deficiency still exists after providing the requester the opportunity to respond, deny the proposal pursuant to chapter 3, paragraph 11 of this order.

6. Is AED Coordination Required?

a. AED provides technical knowledge for the operator’s maintenance and operational program, as well as insight into fleet issues. As the evaluator, determine if AED coordination is required by using the AED coordination criteria in appendix A of this order for both individual and global AMOCs.

b. If the AED coordination criteria in appendix A of this order are met, the AED is the primary FS point of contact for the AMOC proposal. Discuss the AMOC proposal with the AED and continue the process, starting with chapter 3, paragraph 8 of this order. Include AED on the AMOC response coordination grid when routing the response for coordination pursuant to chapter 3, paragraph 12 of this order.

3-4 8110.103C 7. Coordination with PI/FSDO/CHDO/IFO.

a. If the AED is not the primary FS point of contact pursuant to chapter 3, paragraph 6 of this order, either the PI/FSDO/CHDO or the IFO is the primary FS point of contact. However, prior FS coordination is not required for a global AMOC proposal from a DAH.

b. If the AMOC proposal is for a U.S.-registered aircraft, the PI/FSDO/CHDO is the primary FS point of contact for the AMOC proposal, unless it is operated by a foreign operator (refer to 14 CFR Part 129).

c. If the AMOC proposal is for a foreign-registered aircraft, or if the aircraft is U.S.-registered but operated by a foreign operator, the IFO is the primary FS point of contact; however, coordination with the IFO is not required.

d. If the AMOC proposal came directly to the responsible office with no PI/FSDO/CHDO comments, notify the appropriate PI/FSDO/CHDO to provide an opportunity to comment on the proposal. PI/FSDO/CHDO insight is especially important for proposals for changes in AD compliance times. Contact the manager of the appropriate office for assistance in obtaining a response from the PI/FSDO/CHDO or resolving issues.

e. The evaluator must save any comments provided with the AMOC proposal, or a record of the request for PI/FSDO/CHDO comments and the resulting comments (including “no comment” if applicable). These records can be in various formats, such as a memorandum, printed email, or teleconference record.

8. Coordination with Legal Counsel. Legal review of an AMOC is not required. However, the evaluator can choose to request coordination from legal counsel if desired. When doing so, include legal counsel on the approval letter grid.

9. Proper Methods of Responding to AMOC Proposals.

a. The responsible office manager, or person delegated AMOC approval/denial authority, approves, or denies all AMOC proposals via— (1) An email response, or (2) A letter response.

b. An email response must be transmitted from and contain the name and title of the official approving or denying the AMOC (refer to chapter 3, paragraphs 10e and 11b of this order). The email must contain the minimum requirements of this order for an AMOC approval response (refer to chapter 3, paragraph 10c of this order) or denial response (refer to chapter 3, paragraph 11 of this order). The AMOC approval email response must contain one of the following statements, as appropriate: (1) For ADs where specific reference is made to an AMOC letter, use: “This email is issued pursuant to the authority of the Manager of the [insert approving office] and is the AMOC approval letter referenced in paragraph (*) of AD [****-**-**].” 3-5 8110.103C (2) For all other ADs, use: “This email is issued pursuant to the authority of the Manager of the [insert approving office] as referenced in paragraph (*) of AD [****-**-**].” c. Do not respond to AMOC proposals verbally. This applies even if a response will be provided. The evaluator may informally state that an AMOC proposal response is in progress, but must clarify that the proposal is not approved or denied until the requester receives the authorized written or electronic response. Refrain from making a commitment for approval or denial of the proposal because circumstances may change or delay that determination.

10. How to Approve an AMOC. If the FAA has delegated AMOC approval authority to a DER or ODA holder, follow the AMOC process as shown in FAA Order 8100.15, Organization Designation Authorization Procedures , or FAA Order 8110.37, Designated Engineering Representative (DER) Handbook , as applicable (refer to chapter 3, paragraph 3 of this order).

a. Review of Comments. When reviewing an AMOC proposal, review the comments, if any, received from the PI/FSDO/CHDO/IFO or AED and recommend whether to approve or deny the AMOC.

b. Transferability Determination. If the evaluator is considering recommending approval of the AMOC proposal, determine if the AMOC should be transferable. A transferable AMOC is an AMOC that will continue to apply to a product after it has been transferred to a new owner/operator. The holder of a transferable AMOC can make the AMOC approval document available to someone else who receives a product covered by that document. Changes of compliance time are typically not transferable. The evaluator must be careful when determining transferability, and not make an AMOC transferable if it depends on— (1) A particular maintenance program schedule, which may not transfer with the product; (2) Procedures, facilities, or processes unique to the requester; (3) Operational procedures, limitations, or training unique to the requester; (4) Recurring inspections or other maintenance actions unique to a requester’s maintenance program; or (5) Any other factors unique to the requester.

c. AMOC Approval Response. If the evaluator recommends approval of the AMOC proposal, they must draft an AMOC approval response. Appendix B of this order provides guidance on how to write a specific and effective approval statement within the response and includes examples of problematic statements. The approval response must, at a minimum, meet the following requirements: (1) Clearly state the AD number and specific AD paragraph(s) to which the AMOC applies.

3-6 8110.103C (2) Specify the make and model designations or other limiting factors (such as serial numbers or part numbers) to which the AMOC applies.

(3) Reference the data used to establish the acceptable level of safety that served as the basis for approving the AMOC.

(4) Identify any restrictions on the AMOC, such as applicability, special procedures, facilities, processes, or time limitations (or specify that there are no restrictions, if applicable).

(5) If applicable, refer to the appropriate service documents by number, revision level, and date of revision, if available. It is acceptable to use: “or later [FAA] approved revision” if the AMOC requester has a procedure in place with the responsible office to ensure future revisions of the document will not change the specifics that led to the determination of an acceptable level of safety.

Note: If some of the required information in chapter 3, paragraphs 10c(1) through paragraph 10c(5) of this order is contained in the AMOC proposal, reference the information in the proposal and attach it to the AMOC response.

(6) State whether the AMOC is transferable. For an AMOC intended solely for a foreign-registered aircraft, use one of the following as applicable: This FAA AMOC is transferable with the aircraft to an operator that operates the aircraft under U.S. registry.

This AMOC is not transferable with the aircraft to another owner/operator.

(7) Include the following statements: Before using this AMOC, notify your appropriate principal inspector, or lacking a principal inspector, the manager of the local Flight Standards District Office/Certificate Holding District Office.

The preceding paragraph also applies to any applicable foreign- registered aircraft upon transfer of the aircraft to the U.S. registry, if compliance with the AMOC has not been accomplished.

(8) Include the following statement: All provisions of AD [****-**-**] that are not specifically referenced above remain fully applicable and must be complied with accordingly.

(9) Include the following statement (this statement is not required for global AMOC approvals because it may not be possible to determine who has received or is using a global AMOC): 3-7 8110.103C The [insert approving office] will revoke this AMOC if the [insert approving office] later determines that this AMOC does not provide an acceptable level of safety.

(10) Include the following statement for an AMOC intended solely for a foreign- registered aircraft or for a global AMOC that could apply to foreign-registered aircraft: This AMOC only applies to the FAA AD listed above. The FAA does not have the authority to approve this as an AMOC to any AD issued by another CAA. Approval of an AMOC to another CAA’s AD must come from that CAA. A copy of this response will be forwarded to the CAA, where [this/these] aircraft [is/are] registered for their consideration. [A copy of the response only needs to be sent to the CAA of the requester, in accordance with table 3-1.]

(11) If the AD did not refer to critical task differentiation, or required for compliance (RC) notation, but the revision of service information in the AMOC includes this notation, include the following statement: The steps labeled as RC, including substeps under an RC step and any figures identified in an RC step, must be done to comply with the AMOC. A different AMOC is required for any deviations to RC steps, including substeps and identified figures. Steps not labeled as RC may be deviated from using accepted methods in accordance with the operator’s maintenance or inspection program without obtaining approval of a different AMOC, provided the RC steps, including substeps and identified figures, can still be done as specified, and the airplane can be put back in an airworthy condition.

d. AMOC Approval Response Checklist Review (Optional). Use the optional AMOC approval response checklist in appendix D of this order to help ensure compliance with this order. If the evaluator determines that the draft approval response does not comply with any requirement of this order, revise it to ensure compliance.

e. AMOC Approval Authority. The manager of the responsible office, or the person delegated AMOC approval authority, is the approval authority for the AMOC. The manager is authorized to delegate duties and responsibilities for AMOC approval using standard methods.

The manager defines any limitations associated with these delegations.

11. Denying an AMOC Proposal. If the evaluator is considering recommending denial of the AMOC proposal, notify the requester and the responsible PI/FSDO/CHDO/IFO or AED, as appropriate, and provide the requester an opportunity to address the deficiency. If the deficiency still exists after giving the requester sufficient time to respond, draft a denial response. The AMOC denial response must state the reasons the proposed AMOC is being denied (such as those listed in chapter 3, paragraphs 11a(1) through paragraph 11a(4) of this order).

3-8 8110.103C a. AMOC Denial Criteria. The responsible office must deny the AMOC proposal if the proposal: (1) Does not provide an acceptable level of safety.

(2) Does not meet the AMOC proposal requirements pursuant to chapter 3, paragraph 2d of this order.

(3) Is for an AD issued by another CAA pursuant to chapter 3, paragraph 4b of this order (the FAA refers the requester to the CAA of the country the aircraft is registered in).

(4) Is not appropriate as an AMOC (for example, an AMOC proposal solely to reduce the applicability section of an AD, or a proposal that is already permitted by the service information instructions required by the AD).

b. AMOC Denial Authority. The manager of the responsible office, or the person delegated AMOC denial authority, is the denial authority for the AMOC proposal. The manager is authorized to delegate duties and responsibilities for AMOC denial using standard methods.

The manager defines any limitations associated with these delegations.

12. How to Route the Response.

a. Response Package. Once the evaluator drafts the response using either an email or a letter, route it for coordination along with the following documentation: (1) The incoming AMOC proposal or documented telephone proposal (including the PI/FSDO/CHDO comments, if transmitted).

(2) A coordination grid which includes the signatures or initials of the following persons (scanned or faxed copies of coordination grids are acceptable). A copy of the coordination via email is an acceptable alternative.

(a) The evaluator; (b) AED (or “AED - not required,” as applicable); (c) Technical specialists at the evaluator’s discretion; and (d) The manager of the responsible office, or the person delegated AMOC approval/denial authority.

(3) The completed AMOC approval response checklist, if used.

(4) If recommending approval, any additional data used to establish the acceptable level of safety that was the basis for recommending approval of the AMOC (such as service information, emails, or calculations).

3-9 8110.103C b. Approval/Denial Authority Response. The manager of the responsible office, or the person delegated AMOC approval/denial authority, considers the following before authorizing the AMOC response and addresses any issues or concerns found: (1) Does the manager have the authority to approve or deny the proposal? (Refer to chapter 3, paragraphs 10e and 11b of this order for more information.)

(2) If approving the AMOC, does the proposal provide an acceptable level of safety?

(3) If approving the AMOC, does the AMOC response avoid problematic language? (Refer to appendix C of this order for examples.)

(4) If approving the AMOC, does the AMOC response approval statement include the correct AD paragraphs?

(5) If approving the AMOC, does the AMOC approval response follow a clearly delineated requirement chain? (Refer to appendix B of this order for an example.)

(6) Should AED have been included on the coordination grid?

(7) Was the PI/FSDO/CHDO coordinated with, when required by chapter 3, paragraphs 7b or 7c of this order?

(8) Should other technical personnel or organizations review the AMOC decision?

(9) If denying the AMOC, does the AMOC response clearly state the reasons for denial?

13. Compile Records and Storing in Office Files. The responsible office’s AMOC file consists of the following information (either in hard copy or electronic format). When filing AMOC information, use file code 8040.1. Refer to chapter 5, paragraph 6 of this order for more information on records management.

a. The AMOC proposal in whatever form it came (including the documented telephone proposal, if applicable).

b. Evidence of coordination with FS. This can include comments forwarded with the initial proposal, a request for comment, a record of no comment, and/or a record of AED contact when required by chapter 3, paragraph 6b of this order.

c. A copy of the AMOC response.

d. The coordination grid and any scanned or faxed copies of coordination grids, including email coordination (refer to chapter 3, paragraph 12a(2) of this order).

e. The completed AMOC approval response checklist, if used (refer to appendix D of this order).

3-10 8110.103C f. If the AMOC was approved, any additional data used to establish the acceptable level of safety that was the basis for approving the AMOC (such as service information, emails, calculations, or records of discussion with technical specialists).

14. Distribution of Responses. The responsible office sends copies of the AMOC response as summarized in table 3-1 of this order.

Table 3-1. AMOC Response Distribution for FAA ADs Individual AMOC Global AMOC Non-U.S.

U.S. Registered (U.S. or Non-U.S.

Registered Registered Product) Product Product AMOC Requester Response Response Response PI/FSDO/CHDO Copy N/A N/A Copy if on Copy if on Copy if on response coordination AED response response grid coordination grid coordination grid Copy SoR of requester, and CAA 9-AVS-Global- (for Non-U.S. N/A Copy to SoR Registered Products)* AMOC@faa.gov ** * When replying to direct AMOC proposals for non-U.S. registered products, always send a copy to the CAA overseeing the requester, and if different, the CAA of the SoR. Contact the FAA AIR International Office (AIR-40) for assistance if the appropriate CAA contact is unclear.

** In accordance with many of our bilateral agreements, the FAA is required to send copies of global AMOCs to certain CAAs. The FAA has created this email address so that offices only need to send a copy to this one address. AIR-630 will then forward it to the current list of applicable CAAs.

For any delegated AMOC, in addition to the distribution shown in table 3-1 of this order, a copy of the AMOC response should also be sent to the responsible office and managing office, if different.

3-11 8110.103C Chapter 4. Additional AMOC Considerations 1. Amending an AMOC Response. In some circumstances, the evaluator may need to amend an AMOC response (such as an omission, a typographical error, or submission of additional information that does not affect the acceptable level of safety). When amending an AMOC approval response, state the reasons it is being amended and that the original AMOC response is superseded. Ensure the amended AMOC approval response meets the criteria in chapter 3, paragraph 10c of this order. Only amend an AMOC response in cases where an acceptable level of safety still exists.

2. Revoking an AMOC. Although it should be rare, there may be times when a previously approved AMOC must be revoked because the AMOC does not provide an acceptable level of safety. A revocation letter will not be issued for global AMOCs because it may not be possible to determine who received or used the global AMOC. When a global AMOC does not provide an acceptable level of safety, it is necessary to supersede the AD to revoke the AMOC.

a. Because an unacceptable level of safety is contrary to the public interest and FAA requirements for airworthiness, the responsible office must revoke any previously approved AMOCs that no longer achieve an acceptable level of safety. To revoke such AMOC approvals, the responsible office must send a letter to the AMOC holder notifying them that the FAA proposes to revoke the AMOC and stating the reason for the proposed revocation. Any letters sent to the AMOC holder regarding revocation must be sent by certified mail (return receipt requested). For letters that must be sent internationally, as in the case of a foreign-registered aircraft, use a delivery service that provides guaranteed delivery confirmation. The office must send a copy of the (proposed) revocation letters to the AMOC holder’s PI (or, lacking a PI, the manager of the FSDO/CHDO/IFO).

(1) The proposed revocation letter must provide the AMOC holder with a minimum of seven business days to respond to the proposal.

(a) During this notice period, the responsible office should work with the AMOC holder to identify a means to provide an acceptable level of safety, which may result in the approval of a new AMOC.

(b) After the notice period, the responsible office decides whether a new AMOC is appropriate or whether the owner/operator must be required to comply with the AD as issued. The responsible office issues a letter revoking the AMOC and identifying the necessary actions for the owner/operator, such as complying with a different AMOC or complying with the AD as issued.

(2) If the AMOC is unsafe such that it creates an emergency situation, the FAA may forego or shorten the notice period, and the revocation may be made effective immediately or in fewer than seven days. An immediate revocation may effectively ground the affected aircraft. The reasons for the emergency action must be stated in the letter. The letter must include the following: 4-1 8110.103C This is to inform you of the FAA’s determination that the AMOC to AD [**** **-**], approved on [MM-DD-YYYY], does not provide an acceptable level of safety. This determination is based on [insert justification for the revocation and the immediate safety concern]. Therefore, the FAA is revoking the AMOC.

This revocation is effective upon receipt of this letter. You must comply with the AD as issued (refer to 14 CFR 39.9). You may propose another AMOC if necessary. Otherwise, continued operation of the affected aircraft would violate § 39.7.

(3) If an acceptable level of safety can be ensured over the short term, the letter may delay the effectiveness of the revocation to avoid an unnecessary disruption of operations.

Once the revocation becomes effective, the owner/operator must be in compliance with either the AD as issued or a new AMOC. Otherwise, continued operation would be a violation of § 39.7.

b. The letter proposing to revoke an AMOC must include the following: This is to inform you of the FAA’s determination that the AMOC to AD [**** ** **], approved on [MM-DD-YYYY], does not provide an acceptable level of safety. This determination is based on [insert justification for the revocation]. Therefore, the FAA is proposing to revoke the AMOC. In deciding whether to revoke this AMOC, the FAA will consider any information you provide us within seven days of your receipt of this letter. This information may include data indicating that the FAA’s determination is erroneous or a request for a different AMOC. If the FAA decides to revoke this AMOC, you will be required to be in compliance with the AD unless the FAA approves a different AMOC.

Otherwise, continued operation of the affected aircraft would violate 14 CFR 39.7.

c. The responsible office must follow up with the final revocation letter, if appropriate, no later than five business days after the close of the notice period. The final revocation letter must address why any information submitted was inadequate.

3. Global AMOCs (AMOCs of General Applicability).

a. What is a global AMOC? As used in this order, a “global AMOC” is defined as an “AMOC of general applicability,” a term used in some bilateral agreements. A global AMOC applies to two or more operators; it can be used to obtain an AMOC for multiple serial numbers or makes and models specified in an AD. It can be a useful tool if the responsible office receives or expects to receive multiple requests for the same AMOC. A global AMOC applies to and is transferable with the product to other owners/operators. Anyone, including someone other than an owner/operator, may propose a global AMOC.

4-2 8110.103C b. Is an AMOC applicable to a fleet of aircraft the same as a global AMOC? An AMOC applicable to a fleet of aircraft is not a “global AMOC,” but rather an individual AMOC that applies to multiple aircraft operated by a single operator.

c. Global AMOC approval responses: (1) The minimum requirements for a global AMOC approval response are in chapter 3, paragraphs 10c(1) through 10c(8) of this order.

(2) Owners/operators using a global AMOC are still responsible for notifying their PI (or, lacking a PI, the manager of the FSDO/CHDO) before using it.

d. Converting to a Global AMOC. If converting an individual AMOC into a global AMOC, consider coordinating the global AMOC with the original requester’s PI/FSDO/CHDO/IFO pursuant to chapter 3, paragraph 7 of this order.

e. Proprietary Information in Global AMOCs. If converting an individual AMOC proposal into a global AMOC, be careful not to divulge proprietary information to unauthorized entities. When distributing a global AMOC approval response, use the distribution list in table 3-1 of this order. Following this list ensures proprietary information is only sent to authorized parties/individuals. Consult with legal counsel for any questions concerning proprietary information.

4. AMOC Proposals from Foreign Entities. The FAA may receive proposals from foreign entities to approve AMOC proposals related to FAA ADs for products not on the U.S. registry.

Such proposals may originate from a foreign owner/operator, a design or production approval holder, or another CAA representing a foreign owner/operator. The FAA responds to such proposals because it can minimize urgent proposals for AMOCs in the future. Some aircraft frequently change their registration, including during maintenance. A foreign-registered aircraft today could be U.S.-registered as soon as tomorrow. The importing owner/operator must demonstrate compliance with the FAA AD before the FAA may determine the aircraft to be airworthy. The FAA’s timely response to a foreign proposal for an AMOC, while the aircraft is on the foreign CAA’s registry, can speed up future determinations.

5. AMOC Proposals for Foreign-Registered Aircraft.

a. The FAA may approve or deny AMOC proposals (including global AMOCs) to FAA ADs for foreign-registered aircraft.

b. The FAA may not approve AMOC proposals to another CAA’s AD.

c. When responding to AMOC proposals for foreign-registered aircraft, use the criteria specified in chapter 3, paragraphs 10 or 11 of this order, as applicable.

(1) The FAA’s AMOC approval responses for FAA ADs for foreign-registered aircraft must clearly note that the FAA does not have the authority to approve AMOCs to any AD issued by another CAA.

4-3 8110.103C (2) If the response involves an AMOC to a “sensitive” AD (refer to FAA-IR-M 8040.1, Airworthiness Directives Manual, chapter 6, paragraph 6, for examples), coordinate with AIR-40.

6. Military Commercial Derivative Aircraft (MCDA). Because MCDA may be operated or maintained in a different environment than in the civil fleet, such as not being operated under U.S. civil registration, the military may want to meet the provisions of an AD differently than specified for the civil sector. The responsible military airworthiness authority may request an AMOC from the FAA for the AD. The FAA reviews and approves proposed AMOCs for MCDA for reasons similar to proposals from foreign entities.

a. AMOC proposals for MCDA are sent to the Military Certification Branch (MCB).

The MCB reviews the military request to determine if the FAA may evaluate it as an AMOC for the applicable AD. If the MCB determines the military request has merit, it will forward the request to the responsible office for technical evaluation and response.

b. The responsible office will evaluate the proposal and respond in accordance with chapter 3 of this order. The AMOC response will be directed to the requesting military authority with a copy to the MCB.

c. AMOC approval responses for FAA ADs for MCDA must clearly note that the FAA does not have the authority to approve AMOCs to any mandatory actions issued by the military.

Include the following statement: This AMOC only applies to the FAA AD listed above. The FAA does not have the authority to approve this as an AMOC to any mandatory action issued by the U.S. Armed Forces. Approval of alternatives to its mandatory corrective actions must come from the specific branch of service.

7. Sharing AMOCs with DAHs. Some DAHs keep and make available to their owners/operators a database of global AMOCs. The database allows owners/operators to search for previously approved global AMOCs that may apply to their aircraft. To assist DAHs in identifying AMOC proposals that might be candidates for a global AMOC, requesters may provide their consent in the AMOC proposal letter that permits the responsible office to share the AMOC approval response with the DAH. The responsible office will share with the DAH all AMOC approval responses for proposals that include such consent. The consent must include a statement such as the following, allowing the FAA to provide the AMOC approval response to the DAH for consideration for a global AMOC: Operator XYZ grants the FAA approving office permission to share the AMOC approval response with the design approval holder for its consideration in proposing a global AMOC.

8. Appliance AMOCs, Including Technical Standard Order (TSO)-Approved Articles.

Pursuant to § 39.3, the FAA has the authority to issue ADs that apply to appliances, including articles approved via technical standard order authorization (TSOA). As with any other AD, the 4-4 8110.103C responsible office has the authority to approve AMOCs for an appliance AD. However, certain considerations must be made for this type of AMOC.

a. Any person, including the TSOA holder, may propose, and the responsible office may approve, an AMOC for a design change to a TSO article. For more information regarding changes to TSOA articles, refer to FAA Order 8150.1, Technical Standard Order Program.

b. Because design changes to TSO articles do not include installation approval for those changes into a higher-level product, such as an aircraft or aircraft engine, the responsible office must include the following statement, when applicable, as a restriction in accordance with chapter 3, paragraph 10c(4) of this order: The conditions and tests required for TSO approval of this article and approval of this AMOC are minimum performance standards.

Those installing an article that uses this AMOC, either on or within a specific type or class of aircraft, must determine that the aircraft installation conditions are within the TSO standards, which include any accepted integrated non-TSO function performance specifications. TSO articles and any accepted integrated non-TSO functions must have separate approval for installation in an aircraft. The article may be installed only according to 14 CFR Part 43 or the applicable airworthiness requirements.

c. The installer of a TSO article modified with an approved AMOC does not require a separate AMOC for the installation of that article.

d. An AMOC issued against an appliance AD (one where the unsafe condition has been identified to be in the appliance) must address the unsafe condition in the appliance. An AMOC that does not address the unsafe condition in the appliance is not appropriate. For example, it would be inappropriate to approve an AMOC that allowed the installer to remove the appliance and replace it with a completely different appliance. In this case, the AMOC does not address the unsafe condition in the first appliance.

e. For an appliance AD, an AMOC should never be issued against the aircraft on which the unsafe appliance is installed; rather, the AMOC is written for the appliance itself.

9. AMOCs Involving Certification Projects.

a. Depending on the complexity of the AMOC proposal, a certification project such as a supplemental type certificate (STC) or parts manufacturer approval (PMA) may be required to show compliance to the applicable airworthiness regulations. In these cases, it is important for the certification project office and the office responsible for evaluating the AMOC to coordinate early and often throughout the project. It is inefficient for the certification project office to approve the design if the office responsible for the AMOC will not accept the design change or replacement part as an AMOC to the AD. Likewise, the responsible office cannot approve an AMOC until the design change or PMA is approved.

4-5 8110.103C b. It is inappropriate to only list on the supplemental type certificate that it is an approved AMOC. An AMOC response must meet the requirements of chapter 3, paragraph 10c of this order.

10. Public Requests for Copies of AMOCs. Pursuant to § 39.21, the office identified in the AD can provide information about alternatives it has already approved. Information that can be shared includes the name of the AMOC holder, the date the AMOC was approved, the applicable make and model, and the AD number and paragraphs to which the AMOC applies. Do not provide specifics on the technical nature of the AMOC, and do not provide a copy of the AMOC approval letter to anyone not listed in table 3-1 of this order.

4-6 8110.103C Chapter 5. Administrative Information 1. Distribution. Distribute this order electronically to all offices and divisions of the Aircraft Certification Service (to include all certification and certificate management branches), Flight Standards Service, and regional flight standards divisions; the Organization Designation Authorization Office (AVS-60), and to the FAA Academy Regulatory Support Division.

2. Authority to Change This Order. The AIR Policy and Standards Division (AIR-600) is responsible for issuing, revising, or canceling the material in this order.

3. Related Material. See appendix G of this order for related regulations and publications pertinent to this order.

4. List of Acronyms. See appendix H of this order for a list of all acronyms and their meanings as used in this order.

5. Suggestion for Improvements. Please forward all comments on deficiencies, clarifications, or improvements regarding the contents of this order to the AIR Directives Management Officer at 9-avs-air-directives-management-officer@faa.gov. Your suggestions are welcome. FAA Form 1320-19, Directive Feedback Information, is located in appendix I of this order for your convenience.

6. Records Management. Refer to FAA Order 0000.1, FAA Standard Subject Classification System; FAA Order 1350.14, Records Management; or your office Records Management Officer/Directives Management Officer for guidance regarding retention or disposition of records.

5-1 8110.103C Appendix A Appendix A. Criteria for Coordinating AMOC Proposals with AED 1. How to Use This Appendix. This appendix provides a decision tool to determine if the Aircraft Evaluation Division (AED) should be included on the coordination grid for the AMOC response. The grid copy of the AMOC response is the official record of AED coordination. The outcome of this decision tool is recorded by inclusion of AED on the grid or marking “AED - not required” on the grid. No other records of this decision are required. Notes regarding this decision may be included in the office files, but are optional.

2. Step 1: Review the Criteria in Table A-1 and Determine If Any Apply.

Table A-1. AED Coordination Criteria # AMOC-AED Coordination Criteria. Does the AMOC— Involve a change to the airplane flight manual (AFM), rotorcraft flight manual (RFM), or AFM/RFM 1 supplement, except in cases where the AFM/RFM change has been previously approved under existing certification/validation procedures?

2 Affect the master minimum equipment list (MMEL) dispatch?

3 Involve flight crew training as part of the AMOC proposal (typically includes a change to the AFM)?

4 Involve a change to what and how information is displayed to the flight crew?

5 Involve any placard installed that affects operational use?

6 Affect Extended Operations (ETOPS)/Configuration, Maintenance, and Procedures?

Involve any change to a mandated maintenance requirement (such as Special Federal Aviation Regulation (SFAR) 88 program changes or Corrosion Protection Control Programs), or changes to a manufacturer’s baseline maintenance/inspection requirements (typically found in the Maintenance Review Board Report or Electrical Wiring Interconnection System maintenance program)? This 7 includes AMOCs that involve changes to the maintenance requirements, for example, an AMOC that approves a revision to a Supplemental Structural Inspection Document (SSID) Significant Structural Item (SSI) or SSID SSI inspection program or inspection method. It does not include an AMOC that approves a repair on a PSE or an AMOC that approves an alternative inspection program on a PSE as the result of a repair on a single airplane or group of airplanes.

8 Introduce a new, novel, complex, or difficult inspection/maintenance procedure?

Involve a change to the Airworthiness Limitations Section (ALS) of the instructions for continued airworthiness (refer to 14 CFR 23.1529, 25.1529, 26.11, 27.1529, 29.1529, 31.82, 33.4, and 35.4), except in cases where the ALS change has been previously approved under existing 9 certification/validation procedures? This includes AMOCs that involve changes to the ALS. It does not include an AMOC to an AD-mandated ALS that approves a repair on a PSE or an AMOC that approves an alternative inspection program on a PSE as the result of a repair on a single airplane or group of airplanes.

A-1 8110.103C Appendix A 3. Step 2: Make a Decision (Select One).

a. If the evaluator is not sure about a criterion, either discuss it with AED or include AED on the grid.

1. One or more criteria are YES: AED on the grid is required.

2. All criteria are NO: AED on the grid is not required.

3. All criteria are NO, but the evaluator wants AED on the grid: AED on the grid is required.

b. If the AED coordination criteria are not met, consider contacting them as technical specialists. AED’s involvement may add value to the process and determination of AMOC acceptability.

A-2 8110.103C Appendix B Appendix B. Guidance on Writing an AMOC Approval Statement 1. AMOC Approval Requirements Chain. Refer to figure B-1 of this order for an example of an AMOC approval requirements chain.

Figure B-1. Example of an AMOC Approval Requirements Chain AD 2010-01-XX Chain of Requirements Requirement Service Step 9 – Service Bulletin X details: Within 3 Requirement Bulletin Y apply (includes step 7: Paragraph years, install Part (Includes step sealant “Install bracket per (g) per Service 9 – sealing) type A Service Bulletin Y) Bulletin X AMOC Request The AMOC approval statement must document the Apply continuous chain of requirements, starting with the sealant specific change, and then tracing back to the specific type B AD requirement (see example below) AMOC request to use sealant type B instead of type A 2. AMOC Approval Statement.

a. The evaluator should write the specific AMOC approval statement to capture this chain of requirements. The example shown in figure B-1 of this order is for an AMOC proposal from a domestic operator where Service Bulletins X and Y were incorporated by reference into the AD: The Federal Aviation Administration (FAA) received your proposal dated June 6, 2010, proposing an alternative method of compliance (AMOC) to paragraph (g) of Airworthiness Directive 2010-01-XX.

The West Certification Branch approves your AMOC proposal to paragraph (g) of AD 2010-01-XX to replace Sealant type A with Sealant type B as required by step 9 of Service Bulletin Y, dated April 5, 2009, which is required by Step 7 of Service Bulletin X, dated April 5, 2009.

All provisions of AD 2010-01-XX that are not specifically referenced above remain fully applicable and must be complied with accordingly.

B-1 8110.103C Appendix B b. If more than one AMOC is proposed, write an AMOC approval statement for each, or alternatively, write a separate AMOC response for each proposal.

B-2 8110.103C Appendix C Appendix C. Examples of How NOT to Write AMOC Statements 1. Examples of Problems. (This is what the FAA wants to avoid.)

2. Problematic Example 1.

Air ______ has proposed an extension of the repetitive inspection interval (Paragraph ‘D’) of the subject AD to 4,500 hours/18 months.

Due to Air ______’s past service experience, corrosion prevention program, and operating environment, the FAA finds this extension to be acceptable.

What’s wrong with Example 1?

• The specific AD is not defined in the approval response.

• The interval of 4,500 hours/18 months is not definitive. Is it which occurs first or later?

• There is no approval. It was “found” to be “acceptable.” 3. Problematic Example 2 (Global AMOC).

The subject service bulletin submitted with the reference letter has been reviewed in light of its relationship with Airworthiness Directive 85-13-01. The FAA concurs with the recommendation of DER _____ and considers the engineering aspects of the service bulletin to be approved.

What’s wrong with Example 2?

• The FAA only “considers” the engineering aspects of the service bulletin to be approved. The FAA never actually approved the AMOC.

• It is unknown what “reviewed in light of its relationship” actually means (for example, it is unknown if the service bulletin impacted the compliance times or any of the required AD actions).

• Avoid statements that approve the engineering aspects of the service bulletin, but do not approve the engineering aspects of the service bulletin as an AMOC. DERs cannot approve the engineering aspects of service bulletins that are the subject of an AD or global AMOC.

• It is unknown whether the service bulletin was the document that provided an acceptable level of safety to the AD. Typically, the FAA approves both a report substantiating the acceptable level of safety to the AD and the engineering aspects of the service bulletin, which identify how to accomplish the AMOC.

C-1 8110.103C Appendix C 4. Problematic Example 3.

The FAA has found the proposal acceptable based on the result of the fault tree analysis conducted by manufacturer X on the unit. Therefore, the FAA permits extending the time interval to 3,000 flight hours for the repetitive functional tests of the CDU cone break unit required by paragraph (a)(2) of AD 2003-YY-ZZ.

What’s wrong with Example 3?

Stating that the FAA permits something is not equivalent to approving it. This AMOC is not actually “approved” and thus has potential operational impact. Also, this “change in compliance time” should have stated that it was changing the repetitive test from X,XXX hours to 3,000 hours.

5. Problematic Example 4.

The FAA has reviewed Service Bulletin 7X7-51-0018, Rev. 1 dated February 30, 2008, and approves it as an AMOC to AD 2009-23-51.

What’s wrong with Example 4?

This approval permits the service bulletin as an alternative to all actions required by the AD. It does not state specific paragraphs of the AD to which the AMOC applies or what aspects of the service bulletin are approved. If there were other requirements in the AD, the operator may use this statement to justify not doing them.

6. Problematic Example 5.

The FAA has reviewed your proposal and believes that this AMOC is equivalent to the intent of paragraph (a) of AD 2006-21-05 and can be considered terminating action for the subject AD for U.S.-registered airplanes.

What’s wrong with Example 5?

Stating that the FAA “believes” in an AMOC is not equivalent to approving it.

Furthermore, the FAA’s responsibility in approving an AMOC is to determine that the AMOC provides an acceptable level of safety, not “equivalent to the intent” of the AD.

C-2 8110.103C Appendix D Comments Added Instructions “Not Applicable” is not allowed. This is listed in the introduction/background section. It is also covered in the specific AMOC approval statement, as covered by the requirements below. “Not Applicable” is not allowed; the AMOC’s applicability must be clear and unambiguous. “Not Applicable” is not allowed; the basis for the FAA’s determination of an acceptable level of safety must be documented.

D-1 (YES/NO/ Response Requirement?

Complies With Not Applicable) Appendix D. AMOC Approval Response Checklist Details) Specific Order Requirement (Refer to FAA Order 8110.103C for The approval response must, at a minimum, meet the following requirements: Clearly state the AD number and specific AD paragraphs to which the AMOC applies. Specify the make and model designations or other limiting factors (such as serial numbers or part numbers) to which the AMOC applies. Reference the substantiating data used to establish the acceptable level of safety that was the basis for approving the AMOC.

Response Number: Evaluator: chap. 3, chap. 3, chap. 3, chap. 3, para. 10c Chapter 3 FAA Order 8110.103C para. 10c(1) para. 10c(2) para. 10c(3) Paragraph # 8110.103C Appendix D Comments Date Completed: Added Instructions If there are no restrictions, mark “Not Applicable.” Applies if the proposal response included service documents. “Not Applicable” is not allowed. “Not Applicable” is not allowed. The exact language in quotes from chapter 3, paragraphs 10c(7) through 10c(10) of this order must be used, as required. If not, mark “NO.” “Not Applicable” is not allowed. Verify that the person meets the requirements of the AMOC paragraph in the AD or meets the requirements of the office AMOC approval authority delegation memorandum. Was the applicable FS office given the opportunity to comment? A “Not Applicable” response may be appropriate.

D-2 (YES/NO/ Response Requirement?

Complies With Not Applicable) Details) Specific Order Requirement (Refer to FAA Order 8110.103C for Identify any restrictions on the AMOC, such as applicability, special procedures, facilities, processes, or time limitations (or specify that there are no restrictions, if applicable). If applicable, refer to the appropriate service documents by number, revision level, and date of revision (if available). State whether the AMOC is transferable. Include the statements in chapter 3, paragraphs 10c(7) through 10c(10) of this order as required. The manager of the responsible office (or person delegated AMOC approval authority) must authorize the approval response. FS coordination.

Initials of person completing checklist: app. A through 10c(10) chap. 3, chap. 3, chap. 3, chap. 3, chap. 3, chap. 3, para. 10e Chapter 3 FAA Order 8110.103C para. 6 & 7, para. 10c(4) para. 10c(5) para. 10c(6) para. 10c(7) Paragraph # 8110.103C Appendix E Appendix E. 24/7 FS AMOC Urgent Request Support 1. Overview. This appendix provides details on how AIR supports FS when there is an urgent need, after normal business hours, for an AMOC to an AD. FAA personnel should consistently advise operators that AMOC proposals are to be submitted pursuant to § 39.19.

Figure E-1 of this order provides a process flowchart. The steps in the flowchart are explained in the following paragraphs.

2. Is there a Need for Urgent Support? If the PI/FSDO/CHDO/IFO identifies the need for urgent AMOC support after normal business hours, they must notify AED. If AED agrees, it requests 24/7 AMOC support from the manager of the responsible office or the person delegated AMOC approval/denial authority.

3. Does the 24/7 Criteria Apply?

a. The responsible office manager or person delegated AMOC approval/denial authority determines if all of the following 24/7 conditions are met— (1) AMOC support is needed after normal business hours and to support proposals identified by PI/FSDO/CHDO/IFOs, and (2) AMOC support is needed to avoid significant air transportation disruptions or a substantial impact to an operator.

b. This process is intended to provide urgent support to PI/FSDO/CHDO/IFOs, and it is exercised at the discretion of the responsible office manager or the person delegated AMOC approval/denial authority. It is not intended to be used to accommodate operators who have failed to plan adequately for AD compliance.

c. If the 24/7 criteria do not apply, proceed to appendix E, paragraph 8 of this order.

d. If the 24/7 criteria apply, proceed to appendix E, paragraph 4 of this order.

4. Is Sufficient Technical Staff Available to Evaluate the AMOC?

a. The responsible office manager, or person delegated AMOC approval/denial authority, determines if sufficient technical staff are available to provide AMOC support.

b. If sufficient technical staff are available, proceed to appendix E, paragraph 5 of this order.

c. If sufficient technical staff is not available, the responsible office manager may assign themself as the evaluator and proceed to appendix E, paragraph 6 of this order. If technical staff is not available and the responsible office manager does not assign themself as the evaluator, inform all parties involved that the action would need to wait pursuant to appendix E, paragraph 8 of this order.

E-1 8110.103C Appendix E Figure E-1. 24/7 AMOC Procedures 3-2.c. From Figure 1, “Proceed to 24/7 procedures” E-2.

PI/FSDO/CHDO/IFO notifies appropriate * or person delegated AMOC AEG approval/denial authority E-2.

AEG Requests support 3-1. Go to normal procedures from the responsible office E-8.

E-3.

Evaluator or Responsible Office Responsible Office Manager* No Authority* Does 24/7 criteria Communicates reasons apply?

to all parties involved Yes No E-4. E-4.c.

Responsible Office Responsible Office Manager* Manager* No No Is sufficient tech staff Assigning self as available? evaluator?

Yes No Yes E-5.

E-6.

Responsible Office Evaluator Manager* Is AMOC Assign evaluator to needed?

AMOC Yes E-7. E-9.

Evaluator Evaluator Yes Proposal Draft AMOC adequate? response End Use criteria in Appendix A E-10. E-11. E-12. E-13.

Evaluator Evaluator Evaluator Evaluator Notify PI/FSDO/CHDO/IFO, Coordinate AMOC Route AMOC Communicate as required, & if available, of response with AEG, as response for response to all AMOC response required issuance parties involved E-2 8110.103C Appendix E 5. Assigning the AMOC. The responsible office manager, or person delegated AMOC approval/denial authority, assigns an evaluator to the AMOC proposal. The evaluator can be an aviation safety engineer, flight test engineer, flight test pilot, senior engineer, engineering manager, responsible office manager, or a person delegated AMOC approval/denial authority.

6. Is an AMOC Needed? The evaluator must determine if an AMOC is needed. If it is, proceed with the process. Refer to chapter 2, paragraph 2 of this order and AC 39-10 for guidance. If an AMOC is not needed, inform all parties involved pursuant to appendix E, paragraph 13 of this order.

7. Is the AMOC Proposal Adequate?

a. Use the AMOC proposal requirements in AC 39-10 as a guide to determine if the proposal is adequate to make an evaluation. Contact the requester, as necessary, to obtain missing information.

b. If there is enough information to determine that the AMOC does or does not provide an acceptable level of safety, draft an AMOC approval or denial pursuant to appendix E, paragraph 9. If the available data supports a limited period of operation, then to ensure an acceptable level of safety, consider making the AMOC time-limited (refer to chapter 3, paragraph 10c(4) of this order).

8. Communicate Reasons to All Parties Involved.

a. Send an email to all parties involved (including AED and the PI/FSDO/CHDO/IFO) notifying them of one of the following reasons that the action will need to wait— (1) The 24/7 criteria do not apply, or (2) The FAA cannot determine if the AMOC proposal does or does not provide an acceptable level of safety because of— (a) Inadequate data, or (b) Lack of available technical staff.

b. When sufficient data and/or technical staff are available, reconsider the AMOC proposal starting from the beginning of the AMOC process pursuant to chapter 3, paragraph 2 of this order.

9. Draft AMOC Approval or Denial Response. The responsible office manager or person delegated AMOC approval/denial authority approves or denies the AMOC proposal using the methods described in chapter 3, paragraphs 10c or 11 of this order, as appropriate.

E-3 8110.103C Appendix E 10. Notify PI/FSDO/CHDO/IFO of AMOC.

a. If the AMOC proposal is global and made by someone other than an owner/operator, there is no need to contact the PI/FSDO/CHDO/IFO.

b. For all other AMOC proposals, notify the appropriate PI/FSDO/CHDO/IFO of the AMOC response. If the PI/FSDO/CHDO/IFO is unavailable, proceed with issuing the AMOC response.

11. Coordinate AMOC Response with AED as Required. The evaluator must coordinate with AED, if needed. Use the criteria identified in appendix A of this order to determine if AED coordination is required.

12. Route AMOC Response.

a. Coordinate and route the AMOC response along with the incoming AMOC proposal, including the PI/FSDO/CHDO/IFO comments, if transmitted. File all correspondence and communication records in the responsible office’s file pursuant to chapter 3, paragraph 13 of this order.

b. Authority for the delegation of the approval or denial of the AMOC is in accordance with the relevant authority delegation memorandum (refer to chapter 3, paragraphs 10e and 11b of this order). Refer to appendix D of this order for an optional checklist to ensure compliance with this order for AMOC approval responses.

13. Communicate Response. Communicate the AMOC response to all parties involved, as appropriate. Distribute the AMOC response pursuant to chapter 3, paragraph 14 of this order.

E-4 8110.103C Appendix F Appendix F. AMOC Response Template Use the following template when responding to AMOC proposals. Fill in customized information in place of the italicized text or delete as appropriate. Follow the latest FAA branding and format guidance.

[ Date ] [ Name and address ] Reference: [ Insert letter number if applicable ] Subject: Alternative Method of Compliance (AMOC) to Airworthiness Directive (AD) [ Insert AD Number ] Dear [ Name ]: The Federal Aviation Administration (FAA) has received your proposal dated [ Month, Day, Year ] proposing an AMOC to paragraph(s) [ Insert specific paragraph number(s) of the AD ] of AD [ Insert AD number ].

[ For approval of the AMOC, include the following: ] The [ Insert approving office ] approves your AMOC proposal to paragraph(s) [ Insert specific paragraph number(s) ] of AD [ Insert AD number ] to [ Insert description of AMOC. Use appendix B to FAA Order 8110.103 as a guide. Include a reference to the substantiating data used to establish an acceptable level of safety. ] The following limitations apply to this AMOC: • [ Specify the make and model designation(s) or other limiting factors (like serial number(s) or part number(s)) to which the AMOC applies. ] • [ Insert any additional limitations that are necessary. ] • [ State whether the AMOC is transferable. For an AMOC intended solely for a foreign- registered aircraft, use one of the following as applicable: ] This FAA AMOC is transferable with the aircraft to an operator who operates the aircraft under the U.S.

registry.

(OR) • This AMOC is not transferable with the aircraft to another owner/operator.

F-1 8110.103C Appendix F • Before using this AMOC, notify your appropriate principal inspector, or, lacking a principal inspector, the manager of the local Flight Standards District Office/Certificate Holding District Office.

The preceding paragraph also applies to any applicable foreign-registered aircraft upon transfer of the aircraft to the U.S. registry if compliance with the AMOC has not been accomplished. [ Delete this paragraph for an AMOC that only applies to U.S.-registered aircraft. ] • All provisions of AD [ Insert AD number ] that are not specifically referenced above remain fully applicable and must be complied with accordingly.

• The [ Insert approving office ] will revoke this AMOC if the [ Insert approving office ] later determines that this AMOC does not provide an acceptable level of safety. [ Delete this paragraph for a global AMOC. ] • This AMOC only applies to the FAA AD listed above. The FAA does not have the authority to approve this as an AMOC to any AD issued by another civil aviation authority (CAA). Approval of an AMOC to another CAA’s AD must come from that CAA. A copy of this response will be forwarded to the CAA, where [ this/these ] aircraft [ is/are ] registered for their consideration. [ Include this statement for an AMOC intended solely for a foreign-registered aircraft or for a global AMOC that could apply to foreign- registered aircraft; otherwise, delete. A copy of the response is only sent to the CAA of the requester, in accordance with table 3-1 of FAA Order 8110.103. ] [ For denial of the AMOC, include the following: ] The FAA has reviewed your proposal and denies the proposal as an AMOC to FAA AD [ Insert AD number ] because [ State why the AMOC is being denied, refer to chapter 3, paragraph 11 of FAA Order 8110.103 ].

[ For all AMOCs ] If you have any questions or need additional information, please contact [ Insert name of AMOC evaluator ] at [ Insert telephone number ] or email [ Insert email address ].

Sincerely, [ Insert name of AMOC approval/denial authority ], [ Insert title of signer ] cc: [ Refer to table 3-1 of FAA Order 8110.103 for distribution. ] F-2 8110.103C Appendix G Appendix G. Related Material 1. Title 14, Code of Federal Regulations (14 CFR). The following regulations are related to this order. The full text of these regulations can be downloaded from the eCFR Code of Federal Regulations website. Paper copies can be ordered from the U.S. Government Bookstore website.

• Part 39 (amendment 39-9474), Airworthiness Directives.

• Section 39.3, Definition of Airworthiness Directives.

• Section 39.7, What is the Legal Effect of Failing to Comply With an Airworthiness Directive?

• Section 39.15, Does an Airworthiness Directive Apply if the Product has Been Changed?

• Section 39.19, May I Address the Unsafe Condition in a Way Other Than That Set Out in the Airworthiness Directive?

• Section 39.21, Where Can I Get Information About FAA-Approved Alternative Methods of Compliance?

2. FAA Advisory Circulars (ACs). The following ACs are related to the guidance in this order. Refer to the latest AC version for guidance, which is available on the Dynamic Regulatory System (DRS) website.

• AC 20-176, Service Bulletins Related to Airworthiness Directives and Indicating FAA Approval on Service Documents.

• AC 39-7, Airworthiness Directives.

• AC 39-10, Alternative Methods of Compliance.

• AC 43-9, Maintenance Records and FAA Form 8130-3 Return to Service.

• AC 120-16, Air Carrier Maintenance Programs.

• AC 120-77, Performance Rules: Provisions Contained in an Operator Manual Under § 43.13(c).

3. FAA Manual FAA-IR-M-8040.1, Airworthiness Directives Manual. The latest version of FAA-IR-M-8040.1 is available on the FAA Regulations/Policies/Handbooks/Manuals website.

4. FAA Orders. The following FAA orders are related to the guidance in this order. The latest version of each FAA order referenced in this document is available on the FAA Regulations/Policies/Order/Notices website.

• FAA Order 0000.1, FAA Standard Subject Classification System.

• FAA Order 1350.14, Records Management.

• FAA Order 8000.95, Designee Management Policy.

• FAA Order 8040.1, Airworthiness Directives.

• FAA Order 8100.15, Organization Designation Authorization Procedures.

• FAA Order 8110.37, Designated Engineering Representative (DER) Handbook.

• FAA Order 8110.101, Type Certification Procedures for Military Commercial Derivative Aircraft.

• FAA Order 8150.1, Technical Standard Order Program.

G-1 8110.103C Appendix H Appendix H. List of Acronyms Acronym Definition 14 CFR Title 14 of the Code of Federal Regulations AC Advisory Circular AD Airworthiness Directive AED Aircraft Evaluation Division AFM Airplane Flight Manual AIR Aircraft Certification Service ALS Airworthiness Limitations Section AMOC Alternative Method of Compliance CAA Civil Aviation Authority CDU Control Display Unit CHDO Certificate Holding District Office DAH Design Approval Holder DER Designated Engineering Representative DRS Dynamic Regulatory System FAA Federal Aviation Administration FS Flight Standards Service FSDO Flight Standards District Office FSIMS Flight Standards Information Management System IFO International Field Office MCB Military Certification Branch MCDA Military Commercial Derivative Aircraft MMEL Master Minimum Equipment List ODA Organization Designation Authorization PI Principal Inspector PMA Parts Manufacturer Approval PSE Principal Structural Element RC Required for Compliance RFM Rotorcraft Flight Manual SoD State of Design SoR State of Registry SSI Significant Structural Item SSID Supplemental Structural Inspection Document STC Supplemental Type Certificate TSO Technical Standard Order TSOA Technical Standard Order Authorization H-1 8110.103C Appendix I Appendix I. Directive Feedback Information Please submit any written comments or recommendations for improving this directive or suggest new items or subjects to be added to it. Also, if you find an error, please tell us about it.

Subject: Order 8110.103C, Alternate Methods of Compliance (AMOC) To: Directive Management Officer, 9-avs-air-directives-management-officer@faa.gov ( Please mark all appropriate line items) ☐ An error (procedural or typographical) has been noted in paragraph on page .

be changed as follows: ☐ Recommend paragraph on page (attached separate sheet if necessary) ☐ In a future change to this order, please include coverage on the following subject: (briefly describe what you want added): ☐ Other comments: ☐ I would like to discuss the above. Please contact me.

Submitted by: Date: Telephone Number: Routing Symbol: FAA Form 1320-19 (11/23) Supersedes Previous Edition I-1