Delegation Models — DER/ODA, DOA/POA, DAO/PAO
Section 13: Jurisdiction Mapping Sets
Definition
The mechanisms by which certification authorities delegate specific approval privileges to qualified individuals or organizations, enabling them to perform certain certification activities on behalf of the authority. Delegation reduces the authority's direct workload while maintaining safety oversight. Each jurisdiction has evolved different delegation structures reflecting its regulatory philosophy.
Where This Shows Up
Delegation is essential to the functioning of the aviation certification system because the volume of certification activity far exceeds the capacity of government engineers alone. The scope of delegated authority varies: some delegates can only make findings of compliance, while others can approve data and issue approvals directly. All delegation systems include surveillance mechanisms (audits, spot checks, document reviews) by which the authority monitors the quality of delegated actions. The trend across jurisdictions is toward organizational delegation (ODA, DOA, DAO) rather than individual delegation (DER), providing more scalable and systematic oversight.
Primary Sources
Representatives of the Administrator — FAA regulation governing the appointment of DERs and authorization of ODAs.
Design Organisation Approval — EASA framework for approving design organisations with defined privileges.
TCCA framework for Delegated Approved Organizations (DAOs) and individual delegates.
Across Jurisdictions
14 CFR Part 183
DERs are individuals appointed under 14 CFR 183 with authority to make findings of compliance and approve data in their area of expertise (structures, systems, flight test, etc.). ODAs are organizations authorized under 14 CFR 183 Subpart D to perform functions on behalf of the FAA through ODA Unit Members, providing a more comprehensive delegation. The ODA manages its unit members under FAA oversight via a procedures manual approved by the FAA.
FAA individual delegation (DER) predates organizational delegation (ODA). ODAs have broader scope but require more organizational infrastructure. DERs remain widely used, especially by smaller applicants.
Part 21 Subparts J (DOA) and G (POA)
The DOA (Part 21 Subpart J) authorizes an organization to approve minor changes, minor repairs, and certain design activities under defined privileges without individual EASA approval for each action. The scope of privileges is defined in the DOA approval terms. The POA (Part 21 Subpart G) authorizes production organizations to issue authorized release certificates (EASA Form 1) for parts and appliances. EASA does not have an individual delegate system equivalent to the FAA DER.
EASA relies on organizational approval rather than individual delegation. The DOA has defined privileges that allow it to approve certain data without submitting to EASA for each approval. This is fundamentally different from the DER concept.
TCCA Delegation of Authority Framework, AWM Chapter 505
DAOs are organizations approved by TCCA with delegated authority to make findings of compliance and approve design data within their scope. PAOs hold production approval with authority to issue release documents. TCCA also maintains a system of individual delegates (Design Approval Delegates) for specific engineering functions.
TCCA's delegation system draws elements from both FAA (individual delegates) and EASA (organizational approvals), reflecting Canada's position between the two regulatory philosophies.
Related Terms
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