Deciphering How To Comply For AMOC For An AD

Guidelines for setting up an alternate means of compliance for an FAA airworthiness directive

The FAA and EASA each have very specific rules regarding applications for an airworthiness directive (AD) alternative method of compliance (AMOC). 

The FAA process begins with the applicant developing the AD AMOC proposal, which is submitted with an application to the FAA Aircraft Certification Office (ACO) identified in the AD. 

The requirements for the applicant are spelled out in 14 CFR Part 39, Section 39.19. The FAA staff responsible for AMOCs use Order 8110.103A (Change 1), which provides policy for working with AMOC applicants. The order describes the steps in handling, coordinating, approving and denying applications.

The ACO aviation safety engineer (ASE) reviews the submitted data, and determines if it is adequate. Additional information may be requested to determine whether the request meets an acceptable level of safety. The AMOC may be approved once the responsible ACO finds the application and data acceptable in complying with the AD.   

The documentation requirements vary from AD to AD, based on the applicant’s proposal. Testing may be mandated, although that is on a case-by-case basis. The FAA advises applicants to coordinate early with the ACO to avoid delays resulting from additional data or document requests.

For large, complex AMOCs, the FAA may require the applicant to do a “certification” project, and absolutely will require it if the applicant wants to offer the AMOC for sale.

The manager of the ACO that issued the AD has approval authority for the AMOC, including requests for different compliance times than those specified in the AD if the AD pertains to a product manufactured in the U.S. If the AD is focused on a component manufactured outside the U.S., AMOC approvals fall under the Standards Staff branch of one of the four FAA Aircraft Certification Directorates. 

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