MARPA Comments on the FAA’s Sequencing SOP

MARPA has filed comments with the FAA on the DRAFT Sequencing Standard Operating Procedure (SOP) [“Aircraft Certification Service Sequencing Procedure”].

The SOP details the FAA’s mechanism for prioritizing certification, approval and validation projects.

This SOP would have a tremendous affect on the rights of private parties. The sequencing decisions about which projects will get FAA resources and which ones will be delayed, will have a tremendous impact on business and profitability, because the FAA approval process is often a bottleneck on innovation. A safety improvement project that is delayed for weeks or months could inhibit safety not only because of the delay, but also because for many companies – particularly smaller ones – delay can mean the difference between whether the company is successful or whether the company may run out of financing before it can bring its safety improvement to the marketplace.

MARPA’s comments address a variety of issues raised by the FAA’s draft in an effort to assist the FAA in improving the draft SOP. Many of MARPA’s comments center around the safety index values established in the SOP, which appear to provide an unfair advantage to companies meeting certain profiles.  In particular, it appears that small businesses could be placed at a competitive disadvantage by the draft SOP.