The New Part 23 may lead to a new AIR organization: why & what?

Aircraft Certification Service Transformation
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Aircraft Certification Service Transformation

Why and what may this new approach look like?

Aircraft Certification Service TransformationDorenda Baker, Director of the Aircraft Certification Office, has initiated an Aircraft Certification Service Transformation. It will realign her team of more than 1,300 engineers, scientists, inspectors, test pilots and other experts responsible for the design and production approval, airworthiness certification, and continued airworthiness programs of all U.S. civil aviation products. The new paradigm will be a functionally-aligned organizational structure (PDF) to execute the certification strategy.”

Why and what may this new personnel approach look like?

The WHY?

Change is hard and within the context of governmental organizations, the “plaque” which lines the arteries of regulatory processes is real. Individuals achieve promotions based on their mastery of the existing policies, procedures and standards. Any change to that existing system is disruptive to that accreted flow and tends to create resistance.

After a delay, which seemingly consumed a decade, the FAA has instituted a major revision to how its certificates aircraft. The new Part 23 transforms the traditional airworthiness determination from a specific checklist process (that is a set of prescriptive, detailed requirements found in the FARs) to performance-based airworthiness. That alteration of how airplanes are permitted to be manufactured and subsequently sold will have an impact on the cadre of FAA AIR (the 3-letter designation for those in this geographically dispersed office) employees. The skills upon which they have relied in the past are subject to refinement, alteration and addition.

Aircraft Certification Service Transformation

Those engineers and other staff persons have worked in four regional offices (ANE, ASO, ACE and ANM) plus a large number of Aircraft Certification and Manufacturing Inspection District Offices. Through the proposed realignment of functions will lead to the better attainment of following policy goals:

  • Consistency and Standardization — Improves consistency and standardization by establishing single functional lines for certification, standards, and system oversight.
  • Innovation — Fosters innovation by engaging applicants and industry early to understand new concepts and ensure a viable path to compliance.
  • System Oversight  Shifts focus from transactional compliance activities to system oversight and early involvement in standards development.
  • Streamlined Certification — Facilitates early industry engagement and risk-based monitoring to eliminate unnecessary FAA involvement in the “critical path” during certification.
  • Metrics-Based Analysis  Establishes business practices for utilizing metrics to determine efficacy of Industry/FAA associated with compliance and time to market.
  • Agility and Adaptability  provides agility and adaptability to meet the challenges of the dynamic global aviation industry.

In more functional terms, the plan is explained as follows:

“To respond to these challenges, the FAA needs a structure that better aligns personnel and executive leadership with the work performed. It will incrementally shift the focus of resources to enable early engagement with industry and promote more consistent oversight of the aviation system. The agency expects an effective realignment to produce an incremental reduction in involvement during the certification program. In turn, freed resources will be refocused on areas of high safety impact and areas that the Service does not currently have the capacity to support, such as fleet safety activities, new technology, or working with emerging foreign airworthiness authorities.”

That’s high level organizational design speak for the new job functions, the shift from prescriptive to performance based, no longer supports the allocation of human resources at many locations around the nation.

One further of pealing back the jargon and perhaps revealing the real rational is that the new Part 23 may result in the functional obsolescence of many of the old certification staff. By reorganizing the distribution of job requirements and locations, those who may feel challenged by this philosophical transformation can exercise their career employee rights and might chose to retire rather than move or compete for the new positions. Many of the individuals subject to this reorganization are represented by NATCA and the union may be able to negotiate a good package. [NOTE: NATCA helped create a process which may protect its AIR members from this change.]

Aircraft Certification Service Transformation

Over its history the FAA has experienced a number of reorganizations. The movement of personnel to regional and field offices has been justified by the need to have the regulators closer to the regulated. Consolidations have been made on several occasions based on the values of the leveraging administrative/support  services and economy of scale of larger teams. This transformation may find value of filtering/realigning talent for AIR’s new challenges.

That’s the WHY and here is the LOOK LIKE?

So at the end of the transition, AIR will look like this:

Aircraft Certification Service Transformation


That’s not a set of boxes easily set in a large number of locations. The ultimate AIR mail address list will likely be a lot shorter.


Aircraft Certification Service Realignment
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