FAA Organizational Evolution
New Structures are Needed for the FAA to Proactively Regulate Aviation Safety
Professor Larry E. Greiner, who researches management and organization at the University of Southern California’s Marshall School of Business, published a landmark study entitled “Evolution and revolution as organizations grow.” Harvard Business Review, p37-46 (1972). His analyses of businesses and how they evolve over time. Although the trends which he identified were derived from the private sector, these specific periods of organizational development appear to be useful in examining the changes in federal agencies:
Phase 1: creative expansion → leadership crisis
Phase 2: directional expansion → autonomy crisis
Phase 3: expansion through delegation → control crisis
Expansion through delegation (evolutionary phase) leads to a crisis of control (revolutionary phase). As the organization expands from delegating more responsibilities to lower level managers, top tier directors start to lessen their involvement in the routine operations, reducing the communication between both levels. This eventually leads to a crisis of control, as lower level managers become accustomed to working without the intrusion of top-level directors. This leads to a conflict of interest with the directors, who feel that they are losing control of the expanded organization.
Phase 4: expansion through coordination → red tape crisis
Expansion through coordination (evolutionary phase) leads to a crisis of red tape (revolutionary phase). As an organization expands from improving its coordination, such as through product group formation and authorized planning systems, a bureaucratic system develops. This eventually leads to a crisis of red tape, where many administrative obstacles reduce efficiency and innovation.
Phase 5: expansion through collaboration
At this stage, the organization seeks to overcome the barrier of red tape through adopting a more flexible and versatile matrix structure (matrix management). Educational courses are arranged for managers, to equip them with the skills of solving team disputes and to foster greater teamwork. Complex and formal systems are also made simpler, and there is an increased emphasis on the communication between managers, to solve crucial problems. Although Greiner identified expansion through collaboration as the evolutionary phase, he did not specifically identify the succeeding crisis (revolutionary phase), as there was little evidence due to most of the organizations still being in the collaboration phase. However, Greiner predicted that the crisis might involve the exhaustion of members in an organization, due to a strong requirement for innovation and teamwork.
Dr. Greiner’s thesis seems to be affirmed by recent FAA announcements of changes in the AVS (Aviation Safety) and its two major components (AFS—Flight Standards and AIR—Aircraft certification). About 30 years ago, the Administrator delegated much of the Headquarters policy power and certification authority to the region and field. The rationale was by locating decision making closest to where the actual work was being performed, the quality of the actions would be enhanced by the proximity to the facts. That would qualify as Dr. Greiner’s Phase 3 and he noted that the distance between the field and the headquarters executives creates a sense that the leaders are losing control.
Without any explicit statement of a new approach, the FAA actions showed that there was greater coordination.
Another set of policy changes, like SMS, the new Part 23 and a new compliance policy, have stressed the relationships among HDQ, the regions and the local field offices. These initiatives have demanded different communication skill sets (collaboration v. confrontation), require greater quantitative analytical abilities and demand more of a macro vision than the micro scrutiny of the old inspections.
At a recent industry meeting, the following changes were described:
- “Whereas we were previously geographically divided by regions and by district boundaries, we understand that might not be the most effective way to manage,” James Viola, manager of the FAA’s General Aviation and Commercial Division, told an audience at Heli-Expo in Dallas, in detailing changes ahead for AFS.
- “We constantly want to improve quality of the work with industry,” he said. Rather than managing by geographical location, AFS will be managed by functional areas, “so we have experts from bottom to top…and work closely with industry, which is the ultimate expert,” Viola added.
- The organization will be streamlined with a small group of leaders managing AFS, but each leader will have a sharper focus on function. Standards will be aligned under the functions with the aim of reducing duplication or overlap.
- General aviation and Part 135 will filter up to “one person” who has the expertise to make that decision, he said.
- Viola said. It is a cultural change. The reorganization will entail an interdependency within the agency and a change to emphasize “How do we get to yes?” Viola said.
- He cited as an example an application for Part 141 flight school recognition that is submitted to a Flight Standards District Office that might not have the personnel to handle the certification process. The reorganization is designed to facilitate such a situation, by enabling the FAA to assemble a team from across the agency to take a more standardized approach to that certification. Under this approach, he said, “We can be world leaders on standardized safety training and we can really make an impact on general aviation safety.”
“AIR Transformation” [previously noted]
- Lance Gant, manager of the FAA’s Rotorcraft Directorate, provided details on some of the AIR changes it builds upon the “pretty explicit direction” from Congress to improve its processes. The change is a necessary one, he said. “A lot of things have changed for us…We recognize there are a lot of new entrants into the National Airspace System. We have global manufacturing.”
- AIR has already taken a number of steps to improve the process, he said, citing a move to a risk-based approach and development of a “scorecard” for the use of organization designation authorization. “The thing we are working on now is realignment of the certification service,” he added. Under the reorganization, the traditional directorate structure “goes away” and will be replaced with functional divisions. The three primary divisions involving industry interface are policy and innovation; compliance and airworthiness; and system oversight. Two other divisions, organizational performance and enterprise operations, are designed for monitoring the organization and providing the necessary resources.
- The FAA wants to prepare for certification projects, rather than react to them, Gant said. “In the past we’ve always told applicants when you are ready to certify something that’s when you can come to us. Now we are encouraging applicants to come in early before they are ready for certification…so we can start developing policy or methods of compliance around the technology.”
- New technologies, especially those that weren’t already anticipated under existing standards, would slow down certification processes. The FAA wants to change that. “The FAA and industry have a common goal. The FAA values compliance but we also understand industry needs to get product to market efficiently and quickly because it’s competitive out there,” Gant said.
- “It’s not just for the FAA to make change. We need industry to make a commitment to operate differently,” he said. “The critical path is not people. It is processes with the FAA. The critical path is shared by the FAA and industry.”
These changes are not just whimsical revisions by senior leadership. They reflect 30 years of Congressional trend to reduce staffs. The past practice of deep review of documents cannot be supported by the level of inspectors required by this work. Looking at past records was one of the reasons why the FAA was assigned the Tombstone Agency appellation. Another factor supporting this change is that technology is innovating at an accelerated rate; the resident FAA experts may not be relevant to the new aircraft certification applications. In order to move from a reactive to a proactive perspective, these organizational evolutions are absolutely required.
These new structures are necessary to allow the FAA to really regulate aviation safety.