Avionics News May 2018 - 35

also explained why this is not always a bad turn of
the use of ED DCTs. However, the Notice goes on
events for the certificate holder or applicant.
to say if an applicant chooses not to use the "selfEnter the Paperwork Reduction Act of 1995, which
audited" DCTs, then the inspector "will need to conduct
requires federal agencies to take responsibility and
their own evaluation of the applicant's programs and
accountability for reducing the burden of federal
complete the FAA DCTs."
paperwork on the public. The PRA is applicable to
The FAA has changed its policy about certain
collection of information that is mandatory, voluntary,
aspects of SAS implementation, especially for initial
or required to obtain or
applicants, but in practice,
retain a benefit. The Office
what will change for applicants
of Management and Budget
or certificate holders?
must approve collection of
Probably nothing. Inspectors
T
HE
FAA
HAS
CHANGED
information by any federal
who prefer using the portal will
IT S POLICY ABOUT
agency in accordance
likely encourage applicants and
CERTAIN ASPECTS OF
with the PRA, and the
certificate holders to continue
FAA has not yet obtained
using it as a more-efficient way
SAS IMPLEMENTATION,
such approval for the SAS
of communicating. Certainly,
ESPECIALLY FOR INITIAL
external portal.
when an applicant completes
APP L ICANTS, BUT
Until the FAA obtains
ED DCTs, the certification
IN PRACTICE,
OMB's approval, according
process is likely to move
to the Notice, the use of
faster, since the DCTs add
the portal to collect the
to the inspector's workload.
following information will
Inspectors who haven't
be voluntary:
bought into the portal yet will
* Configuration data.
appreciate the brief reprieve
* Preapplication
granted by this Notice but
statement of intent.
might still assign applicants
* FAA Form 8310-3,
certain DCTs - on paper - for
Application for Repair
completion in efforts to reduce
Station Certificate and/or Rating.
their workload and thereby speed up the applicant
* Scoped element design DCTs.
process.
* Changes to the scope of operations.
This policy change simply gives an applicant and, in
* Change requests to their certificate.
some cases, a certificate holder the opportunity to opt
* Submitted correspondence.
out of the SAS external portal - temporarily. In reality,
* Manuals.
there is little benefit to waiting until the portal receives
* Minimum equipment list revisions.
OMB approval and final implementation is rolled out.
Further, the Notice explicitly instructs inspectors
If used properly, the portal can be an efficient way of
not to give certificate holders system or subsystem
doing business with the FAA. Even the tedious task of
performance DCTs or element performance DCTs, as
completing ED DCTs can be a useful exercise for new
these are intended to be completed by the inspector as
certificate applicants.
part of the oversight and monitoring process.
In most cases, putting your head in the sand until
The Notice adds that element design DCTs -
the OMB approves of the portal is a counterproductive
typically used in the initial certification phase - may
strategy.
be considered "self-audited" DCTs, but until the FAA
Read the April 2018 edition of Avionics News for
receives OMB approval, the agency cannot mandate
more on SAS. q

WHAT WILL CHANGE
FOR APPLICANTS
OR CERTIFICATE
HOLDERS?

avionics news

may

2018

Table of Contents for the Digital Edition of Avionics News May 2018