Printed headline: Keep Focus
FAA Flight Standards has doubled down on a new approach to regulatory oversight, addressing matters by subject area instead of geography (i.e., through a local office). While the concept isn’t new, recent publication of a dedicated page in the Flight Standards Information Management System identifying established focus teams suggests that the agency is running with the concept.
Industry and government have long grappled with ways to increase consistency and standardization in FAA oversight. The Consistency and Standardization Initiative, which created a mechanism for industry to question actions by agency officials at every level of the “management chain,” has been met with confusion and resistance from the regulated and regulators. While the initiative is laudable and can produce welcome policy changes and clarifications when followed all the way through, the process is cumbersome, quick resolutions are unlikely, and the routing process is widely misunderstood and/or unclear.
The focus team concept will hopefully have more success. Over the past few years, several teams were established to oversee specific areas including ADS-B equipage, the “new compliance philosophy,” helicopter air ambulance operations, unmanned aircraft systems, air cargo operations and airman certification standards (ACS). Team members are selected based on expertise in a specific area or project, without regard to geographic location or position in the agency.
FAA Flight Standards Director John Duncan addressed the concept in a recent safety briefing, stating: “[t]o align our structure with our evolving culture, we have just started to make a shift from today’s geography-based model to a function-based structure that will help us increase our agility, efficiency and consistency.” The shift would temper expectations that all enforcement personnel have expertise in all areas of the regulation, increase reliance on focus teams for regulatory interpretation and hopefully create more standardized enforcement in those areas.
The FAA UAS Oversight and Compliance focus team processes illustrate the manner in which feedback is utilized and disseminated. Credit: FAA
As an example, the ACS focus team—created to implement and oversee the new testing standards for pilot certificates and ratings—is made up of FAA staff from various agency divisions to ensure a broad cross-section of expertise. (The ACS team has the added advantage of an active industry advisory group that provides regular recommendations.) Instead of reaching out to their local office, stakeholders are asked to contact the focus team with questions and requests for clarification. Team members are identified on the FAA website and issues and resolutions are coordinated with the appropriate regional branch and policy division. Every inquiry is answered, and feedback is used to make system improvements.
Similarly, the UAS Oversight and Compliance Focus Team was created in March 2016 to help usher in the new Part 107. The team acts as a single point of contact for field personnel with UAS oversight and helps ensure consistent and standard application of the regulation. An email address is made available to the public, as it is the team’s responsibility to address questions and resolve conflicts. Thus, if implemented correctly, the focus team concept creates consistent leadership and a “closed-loop” system, by which feedback received is used to improve policy and training.
Agency officials have stated that any organizational changes required to create a function-based structure would be implemented with “minimal disruption” to certificate holders. While stakeholders would argue that internal agency change always has a trickle-down effect (e.g., safety assurance systems), the airworthiness community would likely welcome any alteration that created a direct line of communication to regulators with the authority to make policy improvements.