Notice2025-20520
Notice of Availability of Revision C to FAA Order 8100.15 Regarding Organization Designation Authorization (ODA) Procedures
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Published
November 21, 2025
Issuing agencies
Transportation DepartmentFederal Aviation Administration
Abstract
Revision C to FAA Order 8100.15 incorporates new FAA policy to address certain provisions of the Aircraft Certification, Safety, and Accountability Act of 2020 (the Act). This Order also introduces the Airmen Certification (AC) ODA type, reorganizes the existing content, and applies a systems-based approach to oversight, among other changes.
Full Text
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<title>Federal Register, Volume 90 Issue 223 (Friday, November 21, 2025)</title>
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[Federal Register Volume 90, Number 223 (Friday, November 21, 2025)]
[Notices]
[Pages 52787-52788]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-20520]
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
[Docket No. FAA-2024-0491]
Notice of Availability of Revision C to FAA Order 8100.15
Regarding Organization Designation Authorization (ODA) Procedures
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Notice of availability.
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SUMMARY: Revision C to FAA Order 8100.15 incorporates new FAA policy to
address certain provisions of the Aircraft Certification, Safety, and
Accountability Act of 2020 (the Act). This Order also introduces the
Airmen Certification (AC) ODA type, reorganizes the existing content,
and applies a systems-based approach to oversight, among other changes.
FOR FURTHER INFORMATION CONTACT: Mr. Scott Geddie, Policy and Oversight
Integration Section, AVS-64, AVS ODA Office, Federal Aviation
Administration, by telephone at 405-954-6897 or by email at
<a href="/cdn-cgi/l/email-protection#d281b1bda6a6fc95b7b6b6bbb792b4b3b3fcb5bda4"><span class="__cf_email__" data-cfemail="89daeae6fdfda7ceecedede0ecc9efe8e8a7eee6ff">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Background
FAA Order 8100.15, Revision C, Organization Designation
Authorization Procedures, provides updated policy associated with the
requirements set forth in Title 14 Code of Federal Regulations (14 CFR)
Part 183, Subpart D.
The changes in Revision C of FAA Order 8100.15 include the
introduction of the AC ODA type, reorganization of content, and the
introduction of a systems-based approach to oversight. This revision
also addresses certain provisions of the Act including the prevention
of interference with ODA unit members (UM) at companies that hold ODA,
allowing communication between UMs and the FAA, FAA approval of UM
selections made by Type Certificate (TC) ODA holders, and assignment of
FAA advisors to UMs at TC ODA holders.
A proposed version of Revision C to the Order published in the
Federal Register and was available for public comment from July 22,
2024 through October 21, 2024 (89 FR 59012, July 22, 2024). The FAA
received 114 public comments. The comments were from various
stakeholders, including educational institutions, industry
associations, air carriers and commercial operators, individuals, and
18 of the 75 current ODA holders. Organizations submitting comments
included Aerospace Industries Association, Aviation Technician
Education Council, the Air Line Pilots Association International,
Airlines for America, American Airlines, Bell Textron Inc., The Boeing
Company, Cirrus Design Corporation, Delta Air Lines, Embry-Riddle
Aeronautical University, the Foundation for Aviation Safety, Garmin
International, General Aviation Manufacturers Association, Gulfstream
Aerospace Corporation, Honeywell International, Lycoming Engines, the
National Air Transportation Association, the National Association of
Flight Instructors, Pratt & Whitney, Rolls-Royce Corporation, Textron
Aviation, United Airlines, and Williams International.
Supportive comments: Overall, commenters supported the proposals in
the draft Order. Some commenters noted the collaborative engagement
between the FAA and stakeholders in ensuring the proposed policy
achieves its intended benefits for the aviation community.
Comments in support of AC ODA: Most commenters, particularly
educational institutions and industry bodies, were supportive of the
introduction of the AC ODA type and its implications for the aviation
industry. Commenters highlighted the potential for AC ODA holders to
alleviate bottlenecks in the certification process, which are currently
exacerbated by a shortage of Designated Mechanic Examiners (DME).
Commenters viewed the ability for Part 147 schools to conduct
certification exams in-house as an important step toward streamlining
the certification process, reducing costs, and enabling a more
efficient transition of aviation maintenance technician graduates into
the workforce. Commenters from educational institutions noted the
positive impact the proposed policy revisions would
[[Page 52788]]
have on student success, retention, and timely graduation rates.
As a result of public comments, the FAA made several changes to the
AC ODA content to clarify the information related to off-site
facilities as well as for international activity where an ODA holder
may be involved, to correct typos and regulatory references, and to
define terminology such as operational approvals.
Comments opposing AC ODA: Some commenters objected to the
introduction of the new AC ODA type, stating it will reduce safety.
However, these commenters did not provide sufficient data to support
their comments. The FAA assessed the expansion of the ODA program to
include specific regulatory parts for airmen certification and
determined it will not introduce additional risk to the safety of the
National Airspace System.
Multiple authorizations: Based on a public comment associated with
the use of multiple procedures manuals, the FAA incorporated the
ability for an organization to hold more than one authorization when
doing so will facilitate efficiency in the oversight of the type(s)
associated with the authorization.
Clarifications and consistency: Many comments addressed the
procedures governing ODA. Commenters recommended changes to enhance
clarity and improve consistency. In response, the FAA modified language
in several locations for consistency, such as replacing the word
``survey'' with ``solicitation'' for alignment with language used in
FAA Notice 8100.19, Updated Policy on Organization Designation
Authorization (ODA) Holder Interference with ODA Unit Members (UM) and
Communication between UMs and the FAA. The FAA also updated the
information on the use of FAA forms to align with deviation memorandum
AIR-100-17-160-DM09, which allows organization management teams (OMT)
to accept certain customized foms for documentation of ODA
certification activities. The FAA updated the draft Order to provide
additional clarity on when forms may be replicated or modified. Another
example of a change made by the FAA due to public comment is the
refinement of ODA holder training requirements; the FAA clarified the
training requirements to focus on how to deliver the training content
rather than specifying who should present the training content.This
clarification establishes quality standards for delivering training and
allows for more flexibility in assigning trainers.
Editorial changes: The FAA evaluated and incorporated multiple
suggestions where commenters requested editorial changes and
corrections, such as typographical errors and inaccurate references to
other paragraphs, regulations, and other FAA policy.
This Order is available to the public at <a href="http://www.faa.gov/regulations_policies/orders_notices">http://www.faa.gov/regulations_policies/orders_notices</a>, on the Dynamic Regulatory System
website at <a href="https://drs.faa.gov">https://drs.faa.gov</a>, and in the docket.
Authority: 49 U.S.C. 44702 and 44736.
Scott A. Geddie,
Manager, AVS-64, Policy and Oversight Integration Section, AVS ODA
Office.
[FR Doc. 2025-20520 Filed 11-20-25; 8:45 am]
BILLING CODE 4910-13-P
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