Regulatory Consistency Communications Board (RCCB)
Who can submit issues to the RCCB?
Internal and external stakeholders can submit issues to the RCCB.
What is the difference between an internal and external stakeholder?
An internal stakeholder is an employee or contractor of the FAA. An external stakeholder is a member of the aviation community and not employed by the FAA. For the purposes of the RCCB FAA designees are external stakeholders.
How does an external stakeholder submit an issue to the RCCB?
Initial submissions from external stakeholders must be made online. The online form is the only way external stakeholders may submit an issue to the RCCB.
How does an internal stakeholder submit an issue to the RCCB?
Internal stakeholders can submit issues to the RCCB via the online form or through an email to the RCCB email box at email@example.com. Email submissions to the RCCB must be sent from an faa.gov email address. If an internal stakeholder wants to submit an issue anonymously, they must use the online form.
Emails from an internal stakeholder must include the following information:
- Contact information: Submitter name, FAA email address, and FAA phone number.
- Details about the inconsistency, including:
- A clear statement or description of the inconsistency (including specific reference to any Code of Federal Regulations (CFR) or guidance documents involved);
- Background information on the issue to include the type of certificate holders involved (e.g., Title 14 CFR part 145 certificate holders), the Flight Standards District Office (FSDO), regional office, and policy offices involved to date (if any);
- A chronology of major events leading up to the RCCB submission including any action the FAA has already taken;
- How you became aware of the issue; and
- Current issues caused by the inconsistency.
Can I submit an issue anonymously?
Yes. Issues may be submitted anonymously. However, if no contact information is provided the RCCB will not be able to contact you to ask for more information, notify you whether the RCCB accepted the issue, or inform you of the status or resolution.
Can I attach documents to the online submission form?
No. The online form does not allow attachments for security reasons.
Will I receive a confirmation of submission?
Yes. All submitters will receive an email confirmation if they provide an email address.
What is the difference between the Consistency and Standardization Initiative (CSI) and the RCCB processes?
The CSI process is a way for external stakeholders to appeal or request reconsideration of a decision concerning the application of aviation safety regulations or policies by an AVS office. The process for appealing the decision starts at the lowest level possible and is elevated to progressively higher levels of management if not resolved. The CSI process gives both the stakeholder and the FAA an opportunity to present their side of the issue. The FAA provides a technical determination to the stakeholder within a certain number of days at each level of review to explain and validate the rationale behind the decision (or reverse the decision), after which the issue is either closed or elevated to the next level — up to the Associate Administrator for Aviation Safety. Stakeholders cannot submit a CSI anonymously, as they involve a specific situation between two parties. Information regarding CSI may be accessed at Consistency and Standardization Initiative.
The RCCB process is a way for internal or external stakeholder to request clarification and resolution on issues involving an inconsistency in how regulatory requirements are described or applied. The inconsistency may be between regulations and guidance documents or in the application of regulations or policies overseen by AFS or AIR. An issue submitted to the RCCB may require multiple policy and certification offices, as well as the Office of the Chief Counsel, to resolve. Stakeholders can submit issues to the RCCB anonymously.
Will the RCCB accept issues that meet the criteria for acceptance by the RCCB, but also involve a legal interpretation as part of the RCCB's resolution of the issue?
Yes. The resolution of an issue by the RCCB may very well include a legal interpretation, as one of several elements of the final action. However, submissions which are only a request for a legal interpretation will not be accepted by the RCCB.
How will I be informed of a completed action or resolution?
If you provided an email address, the FAA will email you a final resolution. Additionally, the RCCB will document actions taken in a memo posted on the Flight Standards Information Management System (FSIMS) for issues worked by the full RCCB. After going to FSIMS select "Publications", "Other Documents", and then "RCCB."
Do responses to RCCB issues constitute policy?
No. Responses serve as documentation of the actions taken to address the issues. RCCB memos or email responses are not policy documents. You must refer to current guidance for decision-making support.