Purpose

The purpose of this document is to assist you in understanding, implementing, and gaining FAA Approval for the MyFBO.com Advanced Curriculum Feature (ACF) as an Electronic Recordkeeping System for your School.

FAA Approval of MYFBO.com

The FAA accepts and can approve electronic recordkeeping in place of paper records. Unfortunately, there is not a standard or national FAA Approval for Software and Recordkeeping Systems. FAA Approval is accomplished flight school by flight school and FSDO by FSDO. In other words, it all depends upon you, your FSDO and your POI. MyFBO.com has had flight schools sail through the process and other's that have received a less than warm response from their FSDO or POI.

Before you begin there are a few key points or tips to remember:

• Educate Yourself. A lack of knowledge of the approval process, FARs, and applicable ACs may lead to failure. Your FSDO or POI will look to you to describe the system and process to them.
• Sell It. The FAA read-only access capability of MyFBO.com is a key selling point for the FAA. The feature allows your POI/PMI to log in and have read only access to the training or maintenance records.
• Don't Assume. Although there are FSDOs and POIs familiar with MyFBO.com, many are not. You will find many POI's that can barely turn on a computer, let alone audit a complex software system. MyFBO.com does offer free training for your Inspector. Training can be done via webinar or at our offices. There is a free invitation letter from MyFBO.com to the FAA below. Please feel free to print and give to your POI.  
• The FAA is busy. Your FAA Inspector will not want to do any extra work; they are busy. Putting their rubber stamp on a Jepessen Quad-Fold is a lot easier than reading. This is one of the most important points. One of the keys of any approval process is to make the process as easy on the FAA as possible. In simple terms, try to give them something to rubber stamp.  
• Be prepared. Have your syllabi set up in the system. When they ask to see it, have something to show them.
  
• Understand the Limitations. An understanding of what the MyFBO.com ACT can and can't do is critical. 141 recordkeeping is multifaceted and MyFBO.com handles some of the recordkeeping. In other words, understand were MyFBO.com will fit in and be used and where it will not.
• It is Yours. Although MyFBO.com will assist in any way possible, remember that you are seeking approval for your recordkeeping system, not ours.
 

Related FAA Documents you will Need

• AC 120-78 - Guidance is set forth in this AC for digital signatures and electronic recordkeeping. It does apply to “Persons performing airmen certification under 14 CFR parts 61, 63, 65, 141, and 142”.
• AC 141-1A - Certification of Pilot Schools
• FAR Part 141.93, 141.95, and specifically 141.101.

The Approval Process

According to AC 120-78, FAA Approval of Electronic Recordkeeping Systems is a 3 step process:

1. Announcing Intent to Use Electronic Recordkeeping. Certificate holders and operators intending to use electronic recordkeeping should consult with their local FSDO before implementing an electronic system. To obtain FAA approval, the certificate holder or operator must submit a letter to the appropriate FSDO describing the proposed system and include the proposed section or revision to the operator’s manual. It is assumed new applicants may include this information during the application process.
   
   Supporting Documentation:
   • Sample Letter of Intent for Electronic Recordkeeping (MS Word)
   • Optional - Letter from MyFBO.com (Invites POI for free training)
2. Description of Electronic System and Proposed Manual Changes. The electronic system description should explain how the electronic recordkeeping will be used in your maintenance and operational activities. The proposed manual section or revision should clearly state who in the organization has authority and the overall responsibility for implementing, modifying, revising, and monitoring the electronic recordkeeping computer software.
   
   In other words you are going to have to write a few paragraphs describing:
• How the system works.
• How it will be used at your school.
• Standard operating procedures.
• Who can use it and how they will be trained.
• Backup procedures.

Supporting Documentation:

• Sample MyFBO.com TCO Supplement (MS Word - Zipped) 

Don't have a TCO? Many commercial syllabi producers provide help in creating TCOs. For example, see http://www.gleim.com/aviation/tcotool/. 

3. FAA Approval Process. The appropriate FAA Principal Inspector will review the electronic recordkeeping proposal. If the proposed electronic hardware and computer software system meets the elements of AC 120-78, the inspector will make the appropriate entry on the operator’s operation specifications.
   
   Supporting Documentation:

• MyFBO.com and AC 120-78 / 141.101 - Document addresses issues in AC 120-78 point by point. Print and give to your POI along with AC if you think it will help.

09/01/09 cli