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FAA is Updating Alternative Methods of Compliance (AMOC) Guidance

The FAA has released for comment Draft Order 8110.103C. This is an update to the Alternative Methods of Compliance (“AMOC”) guidance.

AMOC are typically used when an airworthiness directive (“AD”) provides one resolution to a safety problem, but the AMOC applicant has another approach that achieves the same level of safety. One example would be where a modification PMA is developed to solve the AD problem, but is not identified as a solution in the AD. The PMA holder might apply for an AMOC to identify the PMA part as a solution alternative solution to the safety issue identified in the AD.

This update provides an opportunity to clarify the AMOC process to make it smoother and to clarify and improve the safety analysis that is performed.

MARPA members with comments should share those comments with MARPA so we can incorporate your concerns in industry comments from the Association (please share them by June 30, 2025).

Comments on this update are dues by July 7, 2025.

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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