The Federal Aviation Administration (FAA) performs a number of services that are tangential to its aviation safety mission. At the Mike Monroney Aeronautical Center in Oklahoma City, the agency operates a registry that serves as the place of recordation of aircraft and the aviation equivalent of the Department of Motor Vehicles driver records. Its physical presence there has spawned a cottage industry of lawyers and agents who facilitate the flings done at the FAA’s office.
The Office of Inspector General (OIG) has performed its normal exhaustive (21 page) review of this aircraft and airman registration function. The recommendations (p. 10-11) include eight actions and only one of them involves a policy issue (#2—“Issue policy or regulations that clarify informational requirements for registration of aircraft owned by trusts for non-citizens.”) The remaining seven urge the FAA to implement quality control and information technology (IT) security measures.
The criticisms can be interpreted as existing inefficient processing procedures and technology or the need for additional staffing and computer capacity/capability. Historically the OIG has been quick to call out the FAA for less than ideal human or technical performance. The absence of such an objection suggests that the Oklahoma City office is understaffed and/or deficient in its computer support.
The number of people and the sizing of the computer systems are functions of the Congressional budget. Reading between the OIG lines, it is reasonable to infer that the report’s real target is the underfunding of this function.
It is also reasonable to forecast the senators and representatives will not increase the dollars allotted for these functions.
Alternatives, which would provide real gains to the efficiency and accuracy of the registry, include:
- Raising the fees and/or
- Initiating an Office of Management and Budget (OMB) Circular A-75 process
According to the FAA’s website, the fee for registering an aircraft is $5. That appears to be absurdly lower than the governmental costs for accepting, confirming, processing and recording that information PLUS the FAA must create and deliver the requisite papers. Particularly since the values of some of the vehicles registered are in the multi-millions of dollars, it would appear worthwhile to conduct a study that would determine the efficient costs of registration and to at least increase the fees to those levels. The same exercise might examine a fair and reasonable fee for airman registration.
This function would appear to be ripe for an A-76 analysis. A private firm may be able to perform the ministerial work as well or better. The OMB process would assess the options of continuing as an internal operation versus the work being done by an outside contractor. The process would also provide exceptional insights into the quality/cost of the FAA shop and develop data on what a fair fee might be. The FAA would continue in a policy/standard setting role as well as performing quality control (QC)/quality assurance (QA) oversight.
The OIG has produced a valid critique of the FAA registry, but the report appears to point the finger at the existing QC and security inadequacies. A more penetrating critique might find that the Congressional funding is at fault and if that conclusion is affirmed, options (cost-based fees and/or A-76) might result in better and more secure registrations.Share this article: