9/18/20

 

8900.1 CHG 722

VOLUME 10  SAFETY ASSURANCE SYSTEM POLICY AND PROCEDURES

CHAPTER 12  CERTIFICATION SERVICES OVERSIGHT PROCESS

Section 1  Safety Assurance System: Certification Services Oversight Process

Source Basis:

    Section 91.1014, Issuing or Denying Management Specifications.

    Section 119.35, Certificate Application Requirements for All Operators (applicable to parts 121 and 135 operators).

    Section 125.21, Application for Operating Certificate.

    Section 133.15, Application for Certificate Issuance or Renewal.

    Section 137.15, Application for Certificate.

    Section 141.13, Application for Issuance, Amendment, or Renewal.

    Section 142.11, Application for Issuance or Amendment.

    Section 145.51, Application for Certificate.

    Section 147.5, Application and Issue.

10-12-1-1    GENERAL. This chapter explains the policy, concepts, principles, roles, responsibilities, and expectations for managers responsible for the Certification Services Oversight Process (CSOP).

A.    Purpose. CSOP is designed to assist the Flight Standards Service (FS) in the management of certification applications. CSOP provides guidance to FS offices in accepting, sequencing, tracking, and reporting new certification applicant status. CSOP tracks initial certification projects associated with Title 14 of the Code of Federal Regulations (14 CFR) parts 91 subpart K (part 91K), 121, 125, 133, 135, 137, 141, 142, 145 (including satellites), and 147. CSOP begins upon receipt of the certification application and continues until the project is completed or terminated.

B.    Scope. This section applies to FS managers and provides an overview of the following CSOP functions:

    Receipt of an initial certification request;

    Acceptance of the preapplication information;

    Resource analysis;

    Waitlist;

    Transfers;

    Waitlist advancement;

    Reports; and

    Notifications.

10-12-1-3    RESERVED.

10-12-1-5    BACKGROUND.

A.    Certification Process. FS uses the certification process to determine if an applicant is qualified to hold a certificate and possesses the ability to operate in a safe manner. Before CSOP can begin, the applicant must conduct an initial inquiry with the Federal Aviation Administration (FAA). The applicant is also expected to read and understand the certification process requirements for the certificate being sought. The initial inquiry activity is informational only and does not initiate CSOP or the certification process.

NOTE:  CSOP and certification are two distinct and very different processes. See Volume 2 for the applicable certification process guidance.

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B.    Overview. CSOP provides a standard process for communication and coordination. It allows management to share information for analysis and sequencing of initial certification projects. CSOP guidelines and automation tools are necessary in the decision-making process, but it is important to recognize they are only support tools. It is essential for all involved to apply critical thinking, interdependence, and sound judgment while working through the process. Many factors affect the path of a certification project. CSOP policy and guidance is designed to provide the best possible outcome for each set of circumstances.

C.    Flight Standards Responsibility. From the start of the application phase through Continued Operational Safety (COS) oversight, FS is responsible for the certification process. While the FS office is the focal point for all phases of the certification process, the success and effectiveness of this critical function requires active engagement, timely communication, and collaboration of management at all levels in support of the flying public.

D.    Accuracy. The FS office must ensure an accurate portrayal of the certification projects in CSOP by placing and maintaining the applicant’s status. For 14 CFR parts currently managed using the Safety Assurance System (SAS) automation, the certification data will be populated automatically in CSOP. Title 14 CFR parts not managed using SAS automation will require manual entry of certification data into CSOP. The entry and verification of CSOP information is required at all levels within FS.

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E.    Use of Resources. A “first-in, first-out” approach to the sequencing of certification projects is preferred; however, managers may prioritize projects based on the availability of specific resources. Justification to modify the certification sequence may include an assessment of available resources based on 14 CFR part and those needed for COS. The justification must include an assessment of resources from within and outside the FS office.

F.    Communication. Consistent communication and a commitment to collaboration are necessary and expected. If aviation safety inspector (ASI) resources are not available for certification or COS at the FS office level, the office must provide documentation and notify the CSOP coordinator. Regular communication between the FS office and the applicant regarding the status of a certification project is a requirement of CSOP. The office will notify an applicant regarding the status of their application via telephone, letter, email, or the use of messaging functionality in the automation. If a notification is made by telephone, the office should follow up with a letter.

G.    Expectations. To ensure standardization and consistency, the Executive Director, Flight Standards Service expects every employee at every level to embrace this philosophy, support the program, and adhere to this national policy. The use of separate local procedures is not authorized.

H.    Documents. CSOP is not an official file for certification. Only preapplication documents, Letters of Intent (LOI), or documents necessary for resource analysis should be considered for uploading to the automation in CSOP. CSOP coordinators and Office Managers (OM) should work together to determine what information is necessary in order to perform an effective resource analysis of the certification project.

I.    CSOP Participants and Responsibilities.

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1)    Executive Director, Flight Standards Service. The Executive Director, a Deputy Executive Director, or any individual acting for the Executive Director may approve all policy and guidance changes to CSOP. The Executive Director’s responsibilities include:
a)    Assuring aviation safety and enabling aviation commerce and service, which includes the certification activities covered by CSOP;
b)    Responsibility for the policy and guidance that enables the development, coordination, and execution of CSOP;
c)    Fostering a culture within FS that supports these objectives; and
d)    Reviewing the CSOP program as necessary to ensure that it is functioning correctly, and reviewing specific certification projects identified by division managers.
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2)    Office of Safety Standards, Safety Analysis and Promotion Division. The Continual Improvement Program Office (CIPO) is responsible for the program management of CSOP. Responsibilities of the CIPO manager include, but are not limited to:
a)    Establishing CSOP policy and the automation to support the certification process;
b)    Serving as an information resource for all FS managers;
c)    Reporting automation changes and enhancements to all FS managers;
d)    Assigning a program manager to oversee CSOP;
e)    Assigning CSOP coordinator functions in SAS automation; and
f)    Providing Operations Research Analyst (ORA) support as needed.
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3)    Safety Assurance Division Managers and Safety Standards International Program Division Manager. Responsibilities include:
a)    Designating member(s) of management as CSOP coordinator(s); and
b)    Providing CSOP support to FS offices.
4)    Flight Standards OMs. Responsibilities include:
a)    Assuring adherence to established CSOP procedures;
b)    Assessing and justifying personnel required for each certification project;
c)    Assuring accuracy of certification project management information; and
d)    Assuring timely completion of the CSOP preapplication information.
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1.    The External Portal may be used to submit preapplication information for applicable 14 CFR parts. The FS office will enter the applicant’s preapplication information upon receipt and prior to the acceptance decision, into the automation for 14 CFR parts 91K, 125, 133, and 137, and any other applicant who chooses to not use the External Portal.

2.    The FS OM may assign an aviation safety assistant (ASA), aviation safety technician (AST), ASI, or Frontline Manager (FLM) as the office CSOP point of contact (POC) to perform CSOP functions, such as entering and maintaining records and preparing letters. The OM is responsible for CSOP and the accuracy of the associated documentation and may not delegate those responsibilities. The OM retains responsibility for beginning, waitlisting, or terminating certification projects.

5)    CSOP Coordinator. Responsibilities include:
a)    Providing CSOP support to FS offices; and
b)    Adherence to established CSOP procedures.

10-12-1-7    THE CERTIFICATION SERVICES OVERSIGHT PROCESS.

Figure 10-12-1A.  Certification Services Oversight Process Flowchart

Figure 10-12-1A. Certification Services Oversight Process Flowchart

10-12-1-9    PROCEDURES.

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A.    Submit Preapplication Information (see flowchart process step 10-12-1-9A). The applicant submits the associated form to the FAA for the related 14 CFR type (e.g., FAA Form 8400-6, Preapplication Statement of Intent; FAA Form 8420-8, Application for Pilot School Certification; LOI; or statement of intent (SOI)). The certification project begins in CSOP upon receipt of the certification application, prior to acceptance of the application document and preapplication information. The External Portal may be used to submit preapplication information for all applicable 14 CFR parts. The FS OM or POC will enter the applicant’s preapplication information, upon receipt and prior to the acceptance decision, into the automation for parts 91K, 125, 133, and 137, and any other applicant who chooses to not use the External Portal. The FS office must make the preapplication information acceptance decision within 30 calendar-days of receipt of a certification application (see Step 10-12-1-9B, Receive and Review Preapplication Information).

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NOTE:  If the applicant chooses to initiate their certification project using the External Portal, then the project must be completed using the External Portal. If not, the certification project must be completed outside of the External Portal.

B.    Receive and Review Preapplication Information (see flowchart process step 10-12-1-9B). If the preapplication information is acceptable, notify the applicant using the template letter in the automation and update the automation with the date the letter is sent (see Step 10-12-1-9D, Conduct Resource Analysis to Identify and Determine Resource Availability). If the preapplication information is not acceptable, notify the applicant using the template letter in the automation. The applicant may then choose to resubmit its application (see Step 10-12-1-9C, Applicant Resubmission).

C.    Applicant Resubmission (see flowchart process step 10-12-1-9C). If the applicant decides to resubmit the preapplication, then see Step 10-12-1-9A, Submit Preapplication Information.

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D.    Conduct Resource Analysis to Identify and Determine Resource Availability (see flowchart process step 10-12-1-9D). The FS office must conduct and document an effective and accurate analysis of both certification priorities and available resources for COS. The office must document the results of their resource analysis in the “Analysis Rationale” field of the automation. Some resource considerations are as follows:

1)    Part 121 principal inspectors (PI) must not be assigned to a new certification.
2)    Only part 121 trained and qualified ASIs will be assigned to part 121 certifications. ASIs may also be assigned as part of on-the-job training (OJT) while working with qualified ASI OJT trainers.
3)    Only General Aviation (GA) trained and qualified ASIs will be assigned to GA certifications. ASIs may also be assigned as part of OJT while working with qualified ASI OJT trainers.
4)    Consider what ASI specialties are required for the certification projects. If there is a specialty shortfall, then consider if that specialty is available from another office.
5)    Consider potential risk impact to office COS responsibilities. This includes communicating with ASIs being considered for the certification project to identify potential risk impact to their current COS workload. ASIs may not be assigned to a new certification if oversight of existing certificate holders will be compromised.
6)    Consider current office challenges (e.g., noncompliant certificate holders requiring additional resources for oversight and surveillance).
7)    Consider if office technical expertise meets the surveillance requirements for the proposed operation.
8)    Consider leaves of absence, training schedule, or personnel changes affecting the office.
9)    Consider national demands on the office.
10)    Consider the applicant’s geographic location relative to other certificate holders/agencies.
11)    Consider the applicant. For example, does the applicant have a compelling requirement apart from income to be in business immediately (e.g., an agricultural applicant has documentation demonstrating the need for its services to mitigate a pending agricultural emergency)?
12)    Consider if the office has the ability to certificate applicants requiring Safety Management Systems (SMS) as part of certification.
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E.    Are Resources Available? (see flowchart process step 10-12-1-9E). If the analysis reveals the FS office has the resources to support both the certification and COS after certification, then see Step 10-12-1-9J, ASIs Initiate Certification Project Using Volume 2. If the office does not have the resources, then the applicant is put on the waitlist (see Step 10-12-1-9F, Conduct Review and Reach Consensus With the Office). The OM must notify applicants of their initial status (e.g., “In-Progress” or “Waitlist”) by using the template letter in the automation within 30 calendar-days after accepting the preapplication information. The initial status notification may be included with the acceptance of preapplication information notification if the initial status is known at the time. Reasons to waitlist an applicant include:

1)    Insufficient Operations inspector resources to proceed with the certification;
2)    Insufficient Avionics inspector resources to proceed with the certification;
3)    Insufficient Maintenance inspector resources to proceed with the certification;
4)    The office does not currently have a sufficient number of ASIs;
5)    ASIs have not completed training;
6)    Multiple applicants are waitlisted ahead of this applicant;
7)    Other certifications are in progress;
8)    Resource availability is being determined above the FS office level;
9)    Lack of PIs for COS; or
10)    Other.
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F.    Conduct Review and Reach Consensus with the Office (see flowchart process step 10-12-1-9F). The CSOP coordinator will receive a notification when an office recommends waitlist status for an applicant. The CSOP coordinator will review the record associated with the notification to determine the best option for the project and, if necessary, should request additional information and documentation from the office. The request for additional information must be related to the certification project resource analysis only. Each certification project is unique. Some projects require very little information or interaction between the office and CSOP coordinator; some projects require additional information to communicate the resource needs. The CSOP coordinator and office will work together to resolve any disagreements regarding certification project resource analysis. The CSOP coordinator’s review includes the following actions:

    Reviewing the status of certification projects.

    Determining if the office will require additional assistance or resources to work certification projects submitted to their office.

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    Agreeing with the office’s decision to “Waitlist” a certification project (see Step 10-12-1-9G, Waitlist Applicant Until Resources Are Available and Notify Applicant).

    Possibly transferring the certification project to a different office (see Step 10-12-1-9I, Agree to Transfer?).

NOTE:  If the CSOP coordinator agrees with the office resource analysis, he or she will select “Yes” in the “Resource Analysis” tab. If the CSOP coordinator does not agree, he or she should contact the office and discuss the concerns to help reach an agreement.

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G.    Waitlist Applicant Until Resources Are Available and Notify Applicant (see flowchart process step 10-12-1-9G). The FS office will notify the applicant if the certification project is placed on the waitlist using the template letter in the automation. While the certification project is on the waitlist, the office must communicate the status to the applicant at least every 60 calendar-days using the template letter in the automation. Document the communication in the automation using the “Date Last Official Notification” on the Waitlist tab. The automation sets the date of reference for the 60 calendar-day time notification based on the date the applicant was last contacted.

NOTE:  The office must refrain from speculating as to when the certification project might begin.

1)    Adjusting Waitlist Order. With justification and approval from the CSOP coordinator and division manager, an applicant’s certification request can be moved ahead of other applicants. Managers have the authority to prioritize the waitlist to accommodate the 14 CFR type for which they have available resources to accomplish that type of certification project. Managers must conduct an effective and accurate analysis of available resources to produce the best results in determining prioritization of the CSOP workflow.
2)    Waitlist Advancement Tool. The Waitlist Advancement Tool must be completed and uploaded to the automation for any adjustments to waitlist order. The template Waitlist Advancement Tool is located in the automation.
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3)    Comments. If an applicant’s CSOP waitlist order is adjusted, the FS office must enter a justification in the SAS Waitlist Comments in the automation.

H.    Are Resources Available? (see flowchart process step 10-12-1-9H). FS OMs must review the CSOP waitlist weekly and any time circumstances change the office’s ability to perform certification projects.

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1)    CSOP Coordinator Review. CSOP coordinators must review the waitlist report monthly to determine the availability of resources to perform certification projects and brief division management on potential issues and program recommendations.
2)    Collaboration. The CSOP coordinator collaborates with the FS office to determine options for certification resources for waitlist applicants. If agreement is not possible, the division manager will make the final determination for the best option to accomplish the certification for waitlist applicants. Those options include:

    Remaining on the waitlist (see Step 10-12-1-9G, Waitlist Applicant Until Resources Are Available and Notify Applicant);

    Transferring the project to a different FS office; and

    Shifting resources to the initiating office in order for that office to conduct the certification (see Step 10-12-1-9J, ASIs Initiate Certification Project Using Volume 2).

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I.    Agree to Transfer? (see flowchart process step 10-12-1-9I). The focus of the Resource Analysis Process is to use all available resources to expedite the certification process for the applicant. The CSOP coordinator determines if the certification project can be assigned to another office at any location. The transferring office should make a reasonable effort to contact the applicant by phone or email to determine if they agree with the transfer of the certification project to another office. The CSOP coordinator transfers the certification project in the automation and the transferring office sends the transfer letter using the Transfer Letter template in the automation.

1)    When the CSOP coordinator transfers the certification project in the automation, the receiving FS office must contact the applicant within 10 calendar-days.
2)    The certification project must be in “Waitlist” status prior to transfer. The transferred project arrives in the receiving office in “Accept for Resource Analysis” status with comments history, but no “Resource Analysis” history. The receiving office will conduct resource analysis per flowchart process Step 10-12-1-9D, Conduct Resource Analysis to Identify and Determine Resource Availability.
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3)    If the applicant prefers to work with the office that initially accepted the preapplication information, this office will update the CSOP record and send a waitlist letter using the template letter in the automation, if appropriate (see Step 10-12-1-9G, Waitlist Applicant Until Resources Are Available and Notify Applicant).

J.    ASIs Initiate Certification Project Using Volume 2 (see flowchart process step 10-12-1-9J). CSOP is the management of certification projects. ASIs perform the certification process using Volume 2.

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K.    Monitor Certification Project Status in CSOP (see flowchart process step 10-12-1-9K). The FS OM will monitor the progress of the certification project.

L.    Terminations. Certification projects may be terminated in the automation at any stage of CSOP by the FS OM.

1)    For 14 CFR parts certificated outside of SAS, the FS OM will select the “Terminate Preapplication” button on the “Resource Analysis” tab. The “Terminate Preapplication” button is available until the project moves to “Active” status.
2)    Title 14 CFR parts certificated in SAS will have the “Terminate Preapplication” button available when the project is in “Accept for Resource Analysis” or “Waitlist.” Terminations after certifications have begun in SAS will have the “Termination” functionality in the “Certification Projects” portion of SAS.
3)    The FS OM must enter “Termination Justification” in the automation for any terminated certification project.
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4)    The office must send the applicant a termination letter using the template letter in the automation.

10-12-1-11    REPORTS.

Table 10-12-1A.  Certification Services Oversight Process Reports

Report Type

Properties

National Dashboard—The National Dashboard provides multiple system-level metrics at the national level that assess the overall health of the FS certification programs.

   Filters on office, status, 14 CFR part, proposed type of operations, and date range (initial date received).

   Shows data for the last 9 quarters.

   Provides a snapshot of data at time the report is run.

   Can be run in one of two views:

1)  Total number of applicants.

2)  Change in number of applicants from previous quarter.

Applicant

   Filters on status, office, 14 CFR part, company name, foreign, country, maintenance agreement, and date range.

   Provides a snapshot of applicants and a summary of dates for status changes.

Waitlist

   Filters on office, 14 CFR part, and company name.

   Shows all applicants currently in “Waitlist” status and includes waitlist tracking number, waitlist orders, and reason for waitlist.

Applicant Contact Overdue Status

   Filters on office and 14 CFR part.

   Can be run in one of three views:

1)  Initial status letter overdue.

2)  60 calendar-day waitlist letter overdue.

3)  Transfer letter overdue.

30 Calendar-Day – Initial Status Letter

Shows applicants who have not received an initial status letter within 30 calendar-days of moving to “Accept for Resource Analysis” status.

   If [current date – date of “Accept for Resource Analysis”] > 30 calendar-days, then display item as “Overdue.”

60 Calendar-Day – Waitlist Letter

Shows applicants on the waitlist who have not received their recurring 60 calendar-day waitlist letter.

   If [current date – date of “Last Official Notification”] > 60 calendar-days, then display item as “Overdue.”

10 Calendar-Day – Transfer Letter

   If [current date – date of “Last Official Notification”] > 10 calendar-days and applicant was transferred, then display item as “Overdue.”

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Table 10-12-1B.  Certification Services Oversight Process Report Parameters

Report Parameters

Description

Nonstandard

The Safety Analysis Program Office (SAPO) will generate all nonstandard information requests, such as Executive Director, Department of Transportation Office of the Inspector General (DOT OIG), Office of Management and Budget (OMB), and Freedom of Information Act (FOIA) requests.

Time to Complete Certification

For report purposes, time on the waitlist is not included. For example, “Accept for Resource Analysis” starts the certification project. The time stops (is not counted) if the project goes to the waitlist and restarts when the project comes off the waitlist.

Time on Waitlist

Begins when the FS office starts the project on the waitlist and ends when the project moves to any other status. Waitlist time should be cumulative. In other words, if a project is on “Waitlist,” goes to “In-Progress,” and then back to “Waitlist,” the total time on the waitlist should be added together.

Date Received

For Executive Director report purposes. The initial date an applicant submitted the preapplication information, regardless of any subsequent return for correction and resubmission to the FAA. “Date Submitted” is the date the application is submitted through the External Portal or the date the preapplication information is stamped in the office and later entered by the office into SAS.

Table 10-12-1C.  Status Definitions

Status

Definition

Accept for RA

Preapplication information received and accepted for FS office analysis of FAA resource availability for certification project.

Returned

Preapplication information was unacceptable; returned to applicant for correction(s).

Waitlist

Inability to begin certification due to lack of FAA resources (personnel COS and/or personnel certification). Based on FAA analysis only.

In-Progress

ASIs are performing certification per this order.

AA/MAG Certification

Specific to 14 CFR part 145 certifications conducted outside the United States under a maintenance agreement (MAG). Statuses not available when “AA/MAG Certification” is selected:
“In-Progress,” and “Waitlist.”

Terminated

Applicant certification is closed or cancelled. The applicant must reapply and the process starts from the beginning.

Active

Certification is completed; the applicant has received a certificate and operations specifications (OpSpecs).

10-12-1-13    NOTIFICATIONS. Notifications are alerts that are autogenerated by SAS and sent to users to inform them of workflow updates or data changes. The notifications used in CSOP are identified in Table 10‑12‑1D below.

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Table 10-12-1D.  Autogenerated Safety Assurance System Notifications

Process

Trigger

Notification

Recipient(s)

Preapplication accepted for resource analysis

Accept for Resource Analysis selected on Section 2 screen.

Preapplication information for applicant [XXX] has been accepted for resource analysis. Please send the Preapplication Information Acceptance letter to the applicant.

Office Manager (OM), office POC

Initial Status

20 calendar-days have passed since applicant was put in Accept for Resource Analysis status.

Initial status letter for applicant [XXX] is coming due in 10 calendar-days.

OM, office POC

Begin Certification

When OM or POC starts certification for applicant

Applicant [XXX]’s resource analysis has been completed with adequate resources to begin certification by [OM name] in [office].

CSOP coordinator

Waitlist

Waitlist button is selected on Resource Analysis – Office screen.

Applicant [XXX]’s resource analysis has been completed and is recommended for waitlist by [OM name] in [office] and is awaiting divisional agreement.

CSOP coordinators

Waitlist Advancement

Applicant is advanced on the waitlist

[OM name] in [office] has requested applicant [XXX] to be advanced on the waitlist and is awaiting CSOP coordinator and division manager approval.

CSOP coordinator

Waitlist Letter

50 calendar-days from date of last official notification (and in “Waitlist” status)

Waitlist letter for applicant [XXX] is coming due in 10 calendar-days. Waitlist tracking number for applicant is [XXX] and office waitlist order is [XXX].

OM, POC

10-12-1-15    CSOP PEER GROUPS. CSOP includes 14 CFR parts that are not incorporated into the entire SAS functionality. The additional peer groups are incorporated into the CSOP portion of SAS only. The complete CSOP peer groups list is shown in Table 10-12-1E below.

Table 10-12-1E.  Certification Services Oversight Process Peer Groups

CSOP Peer Groups

Peer Group Description

A

Part 121 Operators

B

Part 135 (10 or More Seats)

C

Part 135 (9 or Less Seats)

D

Part 135 (9 or Less Seats/Single Pilot)

E

Part 135 (HAA)

F

Part 145 Within U.S.

G

Part 145 Outside the U.S. Without Aviation Safety Agreement

H

Part 145 Outside the U.S. With Aviation Safety Agreement

I

Part 141 Pilot Schools

J

Part 142 Training Centers

K

Part 147 Aviation Maintenance Technician Schools

M

Part 91K Fractional Ownership

N

Part 125 Operators

O

Part 133 Rotorcraft External-Load Operations

P

Part 137 Agricultural Aircraft Operations

Figure 10-12-1B.  List of Templates

These templates are located in Preapplication Information/CSOP from the SAS Menu:

    Preapplication Information Accepted Letter.

    Preapplication Information Not Accepted Letter.

    Applicant Waitlist Letter.

    Applicant Waitlist Status Letter.

    In-Progress Letter.

    Termination Letter.

    Transfer Letter.

    Congressional Response Letter.

    Waitlist Advancement Tool.

10-12-1-17 through 10-12-1-29 RESERVED.