RAWLINSON, Circuit Judge:

Appellant-Defendant Airbus Helicopters, Inc. (AHI) appeals the district court’s order granting motions to remand to state court. AHI contended that it properly removed this case to federal district court pursuant to 28 U.S.C. § 1442(a)(1) (§ 1442(a)(1)). According to AHI, the district court erroneously determined that AHI did not satisfy the “acting under” requirement of § 1442(a)(1). Reviewing de novo, we affirm the judgment of the district court.

I. BACKGROUND

In February, 2018, John Udall, a resident of the United Kingdom, was killed in a helicopter crash while touring the Grand Canyon. The helicopter (Crashed Helicopter) was owned and operated by several of the Hecker Defendants1 and manufactured by AHI.

Plaintiff-Appellee Mary Riggs (Riggs) filed this action in Nevada state court against AHI and the Hecker Defendants, alleging that the Crashed Helicopter was defectively designed because the fuel tank was not crash-resistant, and could not withstand an impact of a minimal or moderate nature without bursting into flames and engulfing the passenger compartment.2

AHI removed the case to federal district court, asserting § 1442(a)(1) as the basis for removal. That provision permits removal to federal court of an action against “any officer (or any person acting under that officer) of the United States or of any agency thereof, in an official or individual capacity, for or relating to any act under color of such office.” 28 U.S.C. § 1442(a)(1). Riggs and the Hecker Defendants separately moved to remand the case to Nevada state court, on the basis that AHI did not meet the requirements of § 1442(a)(1).

In the Federal Aviation Act, Congress charged the FAA with the duty to establish “minimum standards required in the interest of safety” for the “design, material, construction, quality of work, and performance of aircraft, aircraft engines, and propellers.” 49 U.S.C. § 44701(a)(1). The FAA promulgated (and regularly revises) the Federal Aviation Regulations, which delineate such standards. See 14 C.F.R. § 1.1 et seq. Given the technological complexity of modern aircraft, these safety standards dictate an aircraft’s design from its critical components to its smallest detail. For instance, a helicopter—or, in the FAA’s parlance, a “rotorcraft”—must satisfy regulations covering everything from its “landing gear” to the “number of self-contained, removable ashtrays.” Id. §§ 27.729, 27.853(c)(1).

Besides imposing substantive safety standards, the Act also creates a “multistep certification process to monitor the aviation industry’s compliance.” United States v. S.A. Empresa de Viacao Aerea Rio Grandense (Varig Airlines), 467 U.S. 797, 804 (1984). Before an aircraft can lawfully take flight, the FAA must issue a series of “certifications” or “certificates”—terms that the Act uses interchangeably. The first of these is called a “type certificate,” which the FAA “shall issue” if it finds the aircraft “is properly designed and manufactured, performs properly, and meets the regulations and minimum standards prescribed [by the FAA].” 49 U.S.C. § 44704(a)(1). Then, before the manufacturer can mass produce an approved design, it must obtain a “production certificate.” Id. § 44704(c). To do so, the manufacturer must show that duplicates of the design will, among other things, “conform to the [type] certificate.” Id. Finally, the owner of each aircraft must obtain an “airworthiness certificate” by showing that the aircraft “conforms to its type certificate and, after inspection, is in condition for safe operation.” Id. § 44704(d)(1). It is illegal to operate an aircraft without an airworthiness certificate. See id. § 44711(a)(1).

Together, these certification requirements prohibit a manufacturer (or the aircraft’s eventual owner) from altering an aircraft’s design without the FAA’s approval. Instead, if a manufacturer wishes to make changes, it must seek one of two possible certificates. If a “proposed change . . . is so extensive that a substantially complete investigation of compliance . . . is required,” then the manufacturer must seek a new type certificate from the FAA. 14 C.F.R. § 21.19. For less significant changes, the holder of a type certificate may seek a “supplemental type certificate.” 49 U.S.C. § 44704(b)(1) (emphasis added); see also 14 C.F.R. § 21.113. Like an ordinary type certificate, a supplemental certificate authorizes the holder then to seek production and airworthiness certificates for the modified design. See id. § 21.119.

Perhaps because of this elaborate certification process, Congress offered the FAA an unusual tool to ease its regulatory burden: the authority to delegate its duties to the private sector. Specifically, the Act states:

(d) DELEGATION.—(1) Subject to regulations, supervision, and review the Administrator may prescribe, the Administrator may delegate to a qualified private person . . . a matter related to (A) the examination, testing, and inspection necessary to issue a certificate under this chapter; and (B) issuing the certificate.”

49 U.S.C. § 44702(d)(1) (emphasis added); see also Varig Airlines, 467 U.S. at 807 (“[T]he FAA obviously cannot complete this elaborate compliance review process alone. Accordingly, [the Act] authorizes the Secretary to delegate certain inspection and certification responsibilities to properly qualified private persons.”).

Since 1927, the FAA and its predecessor agency have established programs delegating its certification authority to the private sector—either to individual engineers or to organizations. Establishment of Organization Designation Authorization Program, 70 Fed. Reg. 59,932, 59,932 (Oct. 13, 2005) (codified at 14 C.F.R. pts. 21, 121, 135, 145, 183) [hereinafter ODA Rule]. In 2005, the FAA exercised its authority under § 44702(d) to institute the Organization Designation Authorization (“ODA”) Program, which “consolidat[es] and improve[s]” the “piecemeal organizational delegations” previously developed. Id. at 59,933.

Under such program, the FAA authorizes “ODA Holders” to “perform specified functions on behalf of the Administrator.” 14 C.F.R. § 183.41. ODA Holders act as “representatives of the Administrator,” and when “performing a delegated function, [they] are legally distinct from and act independent of the organizations that employ them.” ODA Rule, 70 Fed. Reg. at 59,933. Further, to become an ODA Holder, an organization must sign a memorandum of understanding promising to “comply with the same standards, procedures, and interpretations applicable to FAA employees accomplishing similar tasks.” Federal Aviation Administration, Organization Designation Authorization Procedures, Order 8100.15, at A1-17 (2006) [hereinafter ODA Order].1

Since 2009, Airbus has been a “Supplemental Type Certification ODA.” Id. ¶ 2–6, at 5. In this capacity, Airbus has the authority to “develop and issue supplemental type certificates . . . and related airworthiness certificates.” Id. Airbus may issue such certificates both for its own aircraft or for those of other applicants. See id. ¶ 11–7, at 88. Although the FAA may revoke Airbus’s ODA status or reconsider its issuance of a specific certificate, see 49 U.S.C. § 44702(d)(2)–(3), a certificate issued by Airbus carries the same legal consequence as one issued by the FAA: it gives the FAA’s formal approval to the aircraft’s design (in the case Beginning with the text, the Federal Aviation Act compels the conclusion that the FAA delegates formal legal authority to ODA Holders. By its own terms, 49 U.S.C. § 44702(d)(1) authorizes the FAA to “delegate” a “matter related to” the “examination, testing, and inspection necessary to issue a certificate” and “issuing the certificate.” To “delegate” means to “give part of one’s power or work to someone in a lower position within one’s organization.” Delegate, Black’s Law Dictionary (9th ed. 2009); see also Delegate, Webster’s Third New International Dictionary (unabr. ed. 1986) (“[T]o entrust to another: transfer, assign, commit <power delegated by the people to the legislature> <one may [delegate] one’s authority to a competent assistant>”). Congress’s use of “delegate” thus suggests that the FAA may transfer its own formal legal powers to private persons, and the rest of the statute accords with such interpretation. In 49 U.S.C. § 44702(a), for instance, Congress established that the “Administrator of the [FAA] may issue” the long list of certificates mandated by the Act. See also 49 U.S.C. § 44704 (same). Accordingly, the responsibility to issue certificates falls in the first instance to the FAA, and it is this authority that § 44702(d)(1) allows the agency to “delegate.”

Confirming Congress’s mandate, the FAA itself describes the ODA Program as a delegation of legal authority. Under the program, ODA Holders like Airbus function as “representatives of the Administrator” and “perform[] a delegated function.” ODA Rule, 70 Fed. Reg. at 59,933; see also 14 C.F.R. § 183.41 (similar). The ODA Order states that the program “delegate[s] certain types of authority to organizations,” and that such designees “act on the FAA’s behalf.” ODA Order, ¶ 1–1, at 1. Further, these delegees “assist” the agency and “help carry out” its manifold “duties [and] tasks,” Watson, 551 U.S. at 152 (emphasis removed), because the “[d]elegation of tasks to these organizations [allows] the FAA to focus [its] limited resources on more critical areas,” ODA Rule, 70 Fed. Reg. at 59,933.

Altogether, Congress and the FAA expressly said—time and again—that the agency indeed “delegate[s]” to private persons (like Airbus) the authority to issue certificates, and Watson counsels that a “delegation of legal authority” satisfies § 1442(a)(1)’s “acting under” requirement. 551 U.S. at 154–57. It follows that Airbus “act[s] under” the FAA.

I am not alone in this view. The Eleventh Circuit came to the same conclusion in Magnin v. Teledyne Cont’l Motors, 91 F.3d 1424 (11th Cir. 1996), and the Solicitor General has endorsed that court’s holding. In its briefing for Watson, the Solicitor General argued that the defendant could not seek removal under the federal officer removal statute (as the Supreme Court later held), but it cited Magnin to support the argument that “a private citizen delegated authority to inspect aircraft by the [FAA] acts under a federal officer in conducting such an inspection and issuing a certificate of airworthiness.” Brief for the U.S. as Amicus Curiae Supporting Petitioners at 26, Watson, 551 U.S. 142 (No. 05- 1284). “The critical point,” the Solicitor General continued, “is that the individual acts on behalf of the FAA Administrator in conducting the inspection.” Id.

B

Despite the clear evidence of delegation, the majority concludes that Airbus’s actions as an ODA Holder constitute mere “compliance” with FAA regulations. See Maj. Op. at 16–18. With respect, I believe the majority is wrong.

The majority’s critical error is that it conflates Airbus’s two distinct roles as a manufacturer and as an FAA delegee. Specifically, an ODA Holder acts as either the regulated party or the regulator—depending on the specific function performed. It is true, of course, that all manufacturers—in their capacity as manufacturers—must comply with the FAA’s numerous safety standards whenever they design or build an aircraft. But as an ODA Holder, the organization also acts as a “representative[] of the Administrator.” ODA Rule, 70 Fed. Reg. at 59,933. In this capacity, the manufacturer is “legally distinct from” the organization, and its “authority . . . to act comes from an FAA delegation.” Id. Put differently, the manufacturer doffs its “aviation industry hat” and dons its “FAA hat,” and so clad, the ODA Holder exercises the agency’s statutory authority to issue certificates.

Perhaps because the issuance of certificates so obviously constitutes an exercise of the FAA’s governmental power, the majority seeks to recast the ODA Program as a “self-certification” regime. See Maj. Op. at 16–18 (emphasis added). The majority borrows such reasoning from Lu Junhong v. Boeing Co., where the Seventh Circuit compared a manufacturer’s authority to issue certificates to “a person filing a tax return” compelled to certify that he reported his income “honestly.” 792 F.3d 805, 809 (7th Cir. 2015). Such “certified compliance,” the court reasoned, was indistinguishable from other forms of “ordinary compliance” deemed insufficient to satisfy § 1442(a)(1). Id. at 810.

Once again, the majority—as Lu Junhong before it—evinces its misunderstanding of the regulatory regime. Although an ODA Holder issuing a certificate must ensure that the aircraft complies with the FAA’s safety standards, the organization’s issuance of the certificate does more; it stamps the FAA’s imprimatur on the aircraft. In so doing, the ODA Holder exercises a power derived from the agency and independent from its responsibilities as a manufacturer. Indeed, the FAA authorizes ODA Holders like Airbus to issue certificates “to an applicant other than the ODA Holder”—thus confirming that such power cannot be reduced to self-certification. ODA Order, ¶ 11–6, at 88 (emphasis added). And because the nature of the certification authority should not fluctuate depending on who is granted the certificate, the mere fact that Airbus certifies its own aircraft has no bearing on whether it “act[s] under” the FAA.

In short, a true self-certification regime (as with the taxpayer attesting to his income) involves an affirmation that the regulated party completed his duty; an ODA Holder’s “certification” conveys the agency’s formal approval to the aircraft.

The majority’s flawed understanding of the ODA Program blinds it to the differences between this case and Watson. There, the defendant—Philip Morris—argued that the FTC had “delegated authority” to test cigarettes for tar and nicotine, and that it “‘act[ed] under’ officers of the FTC” when it conducted such testing. Watson, 551 U.S. at 154 (emphasis removed). But the Supreme Court “found no evidence of any delegation of legal authority from the FTC to the industry association”—the “fatal flaw” in Philip Morris’s argument. Id. at 156 (emphasis added). Accordingly, the Court found no reason to treat “the FTC/Philip Morris relationship as distinct from the usual regulator/regulated relationship.” Id. at 157.

Eager to fit this case into Watson’s mold, the majority casts Airbus as a regulated party complying (or self-certifying compliance) with FAA rules and regulations. See Maj. Op. at 16–18. But as shown, Congress and the FAA said that the FAA delegates “legal authority” to act “on the Government agency’s behalf.” Watson, 551 U.S. at 156. That delegation goes well beyond the “usual regulator/regulated relationship,” id. at 157, and as a delegee Airbus “assist[s]” and “help[s] carry out” the duties and tasks of the FAA, id. at 152 (emphasis removed). Under the correct reading of Watson, such a scheme satisfies § 1442(a)(1)’s “acting under” requirement. Id.3

III

The federal officer removal statute allows those who labor on the federal government’s behalf, and are therefore sued in state court, to have such case tried in a federal forum. In this case, the FAA authorized Airbus to issue certificates that the agency would otherwise issue on its own, and such delegation satisfies § 1442(a)(1)’s “acting under” requirement. Of course, it might seem strange that a manufacturer’s participation in this private-public partnership would permit it to avoid state court; § 1442’s core purpose, after all, is to give federal officials “a federal forum in which to assert federal immunity defenses.” Watson, 551 U.S. at 150 (emphasis added). But the statute’s text is broader still, and our court has discerned a “clear command from both Congress and the Supreme Court that when federal officers and their agents are seeking a federal forum, we are to interpret section 1442 broadly in favor of removal.” Durham v. Lockheed Martin Corp., 445 F.3d 1247, 1252 (9th Cir.

3 The Ninth Circuit cases that the majority cites do not support its conclusion. See Maj. Op. at 10–15 (citing Goncalves v. Rady Children’s Hosp. San Diego, 865 F.3d 1237 (9th Cir. 2017), and Fidelitad, Inc. v. Insitu, Inc., 904 F.3d 1095 (9th Cir. 2018)). Both cases apply Watson to statutory regimes quite different from the FAA’s, and each decision’s fact- intensive analysis defies extraction of a simple rule that resolves this case. The majority’s broad assertion that the court in Fidelitad was “confronted with the identical issue” that we confront here is simply wrong, Maj. Op. at 14; Fidelitad did not address a situation where an entity had formally and explicitly been delegated authority to issue certificates on behalf of a federal agency, let alone the specific delegation that Airbus acts under here.

2006) (emphasis added). The clear consequence of Congress’s handiwork is that FAA delegees perform the agency’s tasks. Because Airbus is such a delegee, § 1442(a)(1) entitles it to a federal forum.

I respectfully dissent.