Reducing Regulatory Burden

GAMA and AIA are conducting a survey of members to gather individual perspectives on recommendations and priorities to reduce regulatory burden and costs. This page provides further detail and background information on each of the proposed actions included in this survey. This list is divided into five categories aligned with the survey: design & production, maintenance, operations, noise & environment, and general.

Design & Production

1. Issue the NPRM for Transport Airplane and Propulsion Certification Streamlining (including business aircraft cabin interiors)

  • This rulemaking is necessary to streamline certification of transport category aviation products and modernize the regulations to better address new technologies proposed by applicants:
  • Adopts ARAC Regulatory Reform Recommendation to streamline business aircraft cabin interior certification to harmonize with EASA CS-25 Appendix S for Executive Interior and eliminate commonly used special conditions and exemptions

2. Remove redundant FAA conformity requirement for Part 21 certification

  • Currently, FAA Order 8110.4C establishes a requirement for redundant FAA conformity inspections for test articles and test setups for Type Certificate, Supplemental Type Certificate, and Parts Manufacturer Approval projects. This redundant FAA conformity serves as an oversight spot check of applicant/manufacturer requirements under 21.33 and 21.53 and is extremely administratively burdensome for both industry and FAA and requires FAA personnel or its specially authorized designees to travel all over the U.S. and the world to conduct redundant inspections.
  • Several ARCs have recommended that FAA update policy to provide for acceptance of applicant/manufacturer system for conformity and/or configuration management that satisfies 14 CFR 21.33 and 21.53 requirements in lieu of redundant FAA conformity checks.

3. Define and implement a future state for FAA aircraft certification to modernize and streamline the process.

  • Section 310 of the FAA Reauthorization Act of 2024 set in motion a review and study into a vision for a future state of type certification. This work is being conducted by MITRE, with industry engagement, and will focus on many key areas including an assessment of digital tools, the development of a risk-based model for type certification, how to implement corrective actions in a timely manner, how to implement efficiencies in the type certification process, and what can be learned from best practices and tools used by other certification authorities outside the FAA.
  • The MITRE report will serve as a starting point for the strategic development of the ‘future state’ of type certification, when published later in 2025.

4. Expand and enable ODA No-PNL so that the scope of availability and use covers a broader range of low-risk, repetitive, and/or well known types of projects.

  • The joint FAA/industry ODA Metric Continuous Improvement Team established a No-Project Notification Letter (no-PNL) action plan in 2015 to expand the number of ODAs with No-PNL authority recognizing the significant efficiency for both FAA and industry of increasing the number of projects managed by ODA and focusing limited FAA resources on system oversight.
  • This action would expand and enable a broader range of projects to be eligible for no-PNL by identifying  current low-risk, repetitive, and/or well known projects with PNL and addressing the reasons why these were not completed as no-PNL.

5. Streamline the Aircraft Certification issue paper process for consistency and predictability and reduce the number of issue papers necessary

6. Remove and/or update AC 27-1B Appendix B (Rotorcraft Instrument Flight) to align with regulatory requirements and guidance for instrument flight, consistent with safety continuum principles (similar to Part 23)

7. Revise Order 8110.49 Software Approval Guidelines to remove the mandate requiring only DO-178, and recognize that it is one means, but not the only, means of compliance.

  • FAA Order 8110.49A
  • Removes exclusive reliance on DO-178 and promotes flexibility in acceptable software compliance methods.

8. Publish the final rule for cybersecurity for transport category airplanes, eliminating regulatory burden of special conditions and redundant validation requirements.

9. Fully delegate Part 23 levels 1, 2 and Part 27 projects so that type certification procedures and level of FAA direct involvement and safety oversight are more consistent with the safety continuum approach for low-risk projects.

10. Facilitate the implementation of F37 standards for Part 22 Light Sport Aircraft

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11. Support the development of F44 standards for Part 23 aircraft

Maintenance

1. Issue final rule to revise maintenance rules for single engine turbine aircraft, to provide additional flexibility to include using a manufacturer’s maintenance program in leu of annual inspection

  • Issue this rule that will revise certain aircraft maintenance inspection rules for small, corporate-sized, and unmanned aircraft. The rule will include additional inspection program options for owners of single-engine turbine-powered airplanes and unmanned aircraft, relaxed mechanical reliability reporting requirements for certain aircraft, and several changes to clarify and simplify various maintenance-related regulations. The rule will relieve aircraft owners, operators, maintenance providers, and the FAA. The rule will provide greater flexibility for aircraft maintenance, standardized reporting requirements, and provide clarification of various maintenance-related regulations.
  • RIN on Inspection Programs for Single-Engine Turbine-Powered Airplanes and Unmanned Aircraft; Miscellaneous Maintenance-Related Updates

Operations

1. Remove the regulatory mandate on required oxygen use above FL250 in Part 135 operations from 135.89(b)(4), align with more flexible approach in 121.333(c)(3)

2. Promulgate DOT economic rules to allow for cost sharing for operation of a private aircraft

3. Remove the regulatory limitations on non-commercial use of airport facilities (through-the-fence issue)

Noise & Environment

1. Replace EPA/FAA Redundant and Conflicting Noise & Emissions Requirements with Applicant Declaration of Compliance with ICAO Standards

  • Despite the US participating in the development of noise standards at ICAO – through both the FAA and EPA – there are often conflicting noise and emissions requirements between the FAA and EPA.
  • To reduce the burden on industry, this change would allow noise certification to be delegated to applicants who would be able to make an Applicant Declaration of Compliance with Noise Standards, rather than placing significant burden on both industry and FAA in meeting the FAA’s requirements.

2. Eliminate the annual EPA reporting requirements under 40 CFR Part 87 for certificated pollutants (NOx, HC, CO, Smoke, CO2) and production quantities of Aircraft Engines

3. Remove the requirement for EPA/FAA involvement in making 21.93 No Acoustic Change determination

4. Revise FAA Part 34.11(a) venting requirements to harmonize with ICAO Annex 16 Volume 2 to streamline approval and global acceptance

General

1. Remove all outdated policy guidance or interpretation which require paper/legacy formats and clarify digital communications and submittals are acceptable

2. Streamline acceptance of Aircraft Certification and Flight Standards policy for the use of remote technology during inspection, test and witnessing

  • Revise policies which enable the use of remote technologies to streamline the process for obtaining FAA acceptance and promoting broader availability and use.

3. Facilitate the development and adoption of regulatory materials for the application of Artificial Intelligence and Machine Learning

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