Printed headline: ‘The Administrator Shall . . .’
Enacting a new six-year FAA bill in late 2018 was a major achievement, both for Congress and the many industry organizations that helped shape the legislation. ARSA is particularly proud of its leadership role in creating a new federal grant program to recruit and train maintenance technicians.
With the FAA bill complete, the aviation policy focus is shifting from Capitol Hill back to the executive branch, which must implement the new law. Officials at the FAA as well as in the Transportation and Homeland Security departments, the Transportation Security Administration, Government Accountability Office (GAO) and other agencies have their work cut out for them. The 462-page bill (which reauthorized not only the FAA but also the TSA and which affects other agencies) is full of congressional directives to enact new regulations, set up new advisory bodies, undertake studies, complete reports and establish new programs.
Congress mandates government action by directing the administrator or secretary of the relevant agency or department using the phrase “the administrator [or secretary] shall.” If you search the phrase “administrator shall” in the FAA bill, you’ll find that it appears 478 times; “secretary shall” appears 126 times.
Those numbers should be a wake-up call about the massive impact that executive branch policymakers will have on the aviation industry in the years ahead. In response, businesses and their association representatives must step up engagement, not just to prevent bad things (e.g., poorly thought-out regulations) but also to improve the way the government works.
ARSA has carefully reviewed the bill and compiled a matrix of more than 40 provisions that may potentially impact the maintenance industry. The association will petition to join stakeholder bodies, contribute suggestions about ways to improve FAA operations and training programs, provide information to support various GAO studies, work to ensure that the technician-training grant program is a top priority and coordinate with our members and industry allies to ensure our efforts are aligned.
The work of passing the FAA bill is complete, but the challenge of implementing it in a way that best serves the needs of the aviation community while upholding safety has just begun. Here’s how you can get involved:
(1) Review the ARSA matrix (visit arsa.org/faa-reauthorization-2018) and (if you have time), the bill itself.
(2) Consider the association’s priority levels for each initiative and compare them to what you believe are the most pressing areas of need for your business.
(3) If you work with trade association or corporate government affairs offices, contact them regarding your priorities and help find ways to shape the work of the FAA and other agencies (individually and through industry groups).
(4) Find opportunities in 2019—the sooner the better—to come to Washington and engage both on and off the Hill. (ARSA’s annual conference in March, which has days of both executive branch and legislative engagement, is a good example.)
Now is the time to understand what is in the new law and how your company will be affected. More important, this is your chance to become active at every point where “the administrator shall” do something that affects your work.
Christian A. Klein is the managing member of Obadal, Filler, MacLeod & Klein, plc, overseeing the firm’s policy advocacy practice. He represents trade associations as a registered federal lobbyist and provides strategic communications and legal counsel services to clients. He is executive vice president of the Aeronautical Repair Station Association. The views expressed are not necessarily shared by Aviation Week.