The regulatory process currently is primarily one way. The FAA visits certificate holders to surveil and inspect their compliance. The FSDOs, ACOs, MIDOs, FSDOs, ADOs and the like receive reports about their operations, personnel changes, errors, manual amendments, new equipment, etc. The regulators know a great deal about the regulated.
Do you know what ASO-200, ANM-200, the Chicago ACO, the BOS-AEG or the litany of acronyms means? What is the relationship between your local ACO and ANE certification organization? What responsibility or authority does each hold? What can they demand from you? How does Sequestration impact your POI/PMI/PAI? Who is the head of the Flight Standards organization, to whom does she report and what power does she have to compel the field to follow national policy (on paper or in reality)?
Ignorance about the answers to these questions may contribute to your organization’s poor relations with the FAA. Tom Hoffman in the above lined article paints a picture of the Air Transportation Division, AFS-200, its people, its mission and its internal processes. If you work for an air carrier, read Tom’s exposition carefully. Understanding how that body of dedicated public servants responds to their assignments provides invaluable insight into how the rules and policies which impact your airline are established.
More importantly, it creates a road map of where you can go to consult the person who drafted the regulation for which you are now crafting a company manual which tries to comply with those sometimes ambiguous words. Calling him or her will not only help clarify the rule’s intent, but also establish a relationship with a key player who may call you the next time she or her is trying to establish new guidelines.
For airports, aircraft certification, repair stations and other certificate holders, FAA.gov holds vast amounts of information about the regulators, who they are, where they work, what their contact information is, etc. The same website can also take you, with perseverance, to the original NPRMs and predecessors which control your work. The rabbit trail to this information is not intuitive, but there are experts who have figured out the maze and can come share their knowledge with your organization or profession .
In addition to these resources, you can be aware of the general state of affairs of federal employees—what Congress is doing with their salary levels, whether the FAA operational budgets have been further reduced for FY 2014 (which, by the way, is almost at the end of the 1st Quarter), who the current and next Administrators/ Deputy Administrators are/will be, etc. Your company probably has a Washington Office; ask them to share their insights into the FAA’s political and career employees. (They may ask why someone in the Ops or Certification or other line office is interested; share with them this post.) Take all of those bits of information and use that data set to relate to your regulator. Beginning your next visit to the local FAA office with a comment indicating your understanding of Sequestration’s impact is a very positive way to begin a conversation which is otherwise likely to be tense.
These are but a few examples of how the regulated can build a constructive, even proactive relationship with your regulators. It is a simple awareness adjustment—recognize how important the FAA is to you, try to understand their institutional imperatives (like there are sound reasons why the investigators tend to focus on records and once you comprehend that, your company’s attention to paper will become easier) and relate to their valid agenda. If they recognize that outreach, the dialogue may not be as contentious.
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