Printed headline: Dear Mr. Administrator
ARSA welcomes every new appointee to the FAA. With an introductory letter and briefing followed by routine updates, visits and collaboration, the association provides a personal connection for agency leaders to understand issues important to the industry. More important, the association works to ensure mutual goals are achievable and met.
On July 24, Stephen Dickson was confirmed as administrator of the FAA. ARSA’s “open letter” to him begins its engagement with the new administrator and underscores the key areas in which the government and industry must progress for the sake of the global aviation safety system:
Dear Mr. Administrator,
Welcome and congratulations. You’ve joined a list of illustrious and memorable leaders atop one of the world’s foremost aviation safety regulators. As you settle in and coordinate with outgoing Acting Administrator Dan Elwell, ARSA urges you to focus attention in the following areas:
(1) Workforce development. Since you are a pilot, we know you understand the needs of operations. However, the challenge of finding and retaining skilled technical talent is a crisis of equal proportions. Aviation maintenance employers compete against every other hands-on industry in the world for skilled workers and in many ways are playing from behind. It’s time to taxi into position for a successful takeoff and everlasting flight. The industry has paved some of the surface, so, please:
· Stand up the workforce grant program established through the 2018 FAA reauthorization law.
· Support industry efforts to reconsider every “pathway” through which maintenance professionals progress, from entry-level technician to specialist to repairman to mechanic to supervisor to executive.
· Modernize the standards by which the agency oversees maintenance training and measures competency.
(2) Open doors. The hard work of aviation safety only becomes more difficult when the agency doesn’t engage with the industry it oversees. While there are uninformed opinions about the dangers of “coziness” between a regulatory agency and its regulated entities, the safety of today’s aviation system is the result of close, careful and lawful collaboration among and between certificate and approval applicants and holders and dedicated individuals in government and the private sector that has and will continue to identify, assess and mitigate risk. Don’t lose faith in that engagement. Some of the ways the agency can ensure its regulations and expectations are understood, implemented and followed are:
· Make FAA training resources available to industry participants at physical locations as well as online.
· Support the integrity of stakeholder bodies like rulemaking and advisory committees that seek public insight.
· Maintain and enhance the system of delegations to allow the FAA to leverage industry expertise.
(3) Recommit to regulatory consistency. Compliance begins and ends with the plain language of the rules. For the FAA to truly achieve the “just culture” promised by its compliance program, it must rely on the basic standards set by Title 14 of the Code of Federal Regulations. Some small steps that will help achieve a mutual change in cultures may be:
· Sensibly enforce the rules related to availability and possession of maintenance data.
· Reinforce the efforts of the Aviation Rulemaking Advisory Committee’s Part 145 Working Group.
· Utilize the Regulatory Consistency Communications Board and consistency and standardization initiatives as methods to resolve local disagreement or confusion over regulatory requirements.
(4) Withstand political and media pressure. One of ARSA’s chief legislative priorities every year is to minimize congressional micromanagement by limiting regulatory mandates. Despite that effort, lawmakers give your agency an awful lot to do. As you well know, the phrase “the administrator shall” appeared nearly 500 times in last year’s law reauthorizing the agency. There are plenty who will call for action on every front and show impatience for anything else; against this pressure you must implement congressional directives in a manner that achieves the highest possible level of safety, based on risk, while minimizing additional burdens on industry.
(5) Lead globally. Build on progress that’s been made toward efficient collaboration with other international civil aviation authorities, in the design, production and maintenance arenas. Build on the small successes of the “quadrilateral” group—the FAA, European Aviation Safety Agency, Transport Canada and ANAC Brazil—to streamline oversight and reduce regulatory complexities. Ensure that properly coordinated technical and maintenance implementation procedures accompany every bilateral aviation safety agreement pursued and managed by the U.S.
While there is much to do, there are plenty of people, resources and groups ready to help. Count ARSA among them.
The Aeronautical Repair Station Association
Brett Levanto is vice president of operations of Obadal, Filler, MacLeod & Klein. He provides strategic and logistical support for the Aeronautical Repair Station Association.