ALPA puts it Legislative and regulatory goals on a chart
Recognizes need to follow up with FAA
Hill mandates should be prioritized among all legislative deadlines
By ALPA Staff
The passage of the FAA Reauthorization Act of 2018 (P.L. 115-254) was a significant achievement to move many of ALPA’s long-standing policy priorities. However, passing a law doesn’t mean that ALPA advocacy on those priorities stops. In the months since the legislation was enacted, ALPA has expended advocacy resources to ensure that the legislation is implemented by federal agencies as intended by Congress. ALPA will continue to work with Congress, as well as the agencies directly, to provide proper oversight to complete action as required by law.
Update on Secondary Flight Deck Barriers Mandatory installation of secondary flight deck barriers on all new passenger airliners was included in Section 336 of the FAA Reauthorization Act of 2018. After a variety of delays that included a government shutdown, the FAA opted to task the Aviation Rulemaking Advisory Committee (ARAC) with establishing a Flightdeck Secondary Barrier Working Group. This group was asked to develop a range of options to satisfy the requirements of Section 336. While ALPA was opposed to the working group in principle as Congress was clear in its intent to mandate the barriers, the Association participated in the process to influence the outcome. Capt. Wolfgang Koch (Delta), ALPA’s Aviation Security chair, was selected to cochair the working group. The ARAC released its report on February 27, which included recommendations essentially ignoring the work done by the RTCA in 2011. With ALPA input and direction, the final report was largely in line with the Association’s expectations, and ALPA supported the overall outcome. Since receiving the report, no other movement on this issue has occurred, nor has the FAA announced next steps.
Complete ALPA’s Call to Action on secondary barriers to insist that the FAA take immediate action to implement this important security feature.
This article was originally published in the June 2020 issue of Air Line Pilot.
ALPA’s mono-ocular view of Congressional priorities viewed through its primary points of advocacy is interesting and instructive. Its score of 6 implements and 2 pending places it high above the DC aviation organization standings (would most cockpit members find a .750 batting average as a good reason to pay their ALPA dues?)
The instruction is found in the accompanying text where the union notes “ALPA has expended advocacy resources to ensure that the legislation is implemented by federal agencies as intended by Congress.” That recognizes that enactment does not equal issuance of a final rule. What is implicit in the allocation of additional resources, i.e. administrative lobbying, are needed to follow a Mandate’s movement within the FAA and other executive agencies.
Equally absent from the ALPA article is that the FAA staff has a LONG list of Hill priorities. As each bill is signed by the President, the regulatory actions set by the statute is placed on top of a very high stack of other obligations. Setting a promulgation of 180 days does not mean that it will be issued within six months, primarily for 2 reasons:
- The FAA staffing does not expand in response to each such mandate, and
- The inboxes of the rulemaking staff are filled with other Congressional priorities.
⇒The sponsor of a new deadline should be required to examine the existing DOT rulemaking list and
declare where on that established precedence the new mandate should go.⇐
It would be interesting to listen to Senator A as she explains to Congressman B that his deadline has been trumped!!!
This is a recurrent theme and here are some previous insights on the question of Congressional priorities and mandate.
House Hearing On Slow FAA Implementation Shows Real Issue That Congress Set 400 Deadlined Mandates Without Any Priorities
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