Peggy Gilligan Retires from the FAA
Overcoming Many Hurdles & Leaving the FAA a Better Place
From: Gilligan, Peggy (FAA)
AVS Colleagues –
I want to share with all of you that I have just announced I will retire from FAA on March 31.
I have had the great good fortune to be a part of the FAA and the Aviation Safety organization during some of the most challenging — and most successful — times. By working together we have established the preeminent aviation safety organization in the world. In partnership with our certificate holders and stakeholders we have established a safety culture throughout our industry.
I am proud to have been a part of the safest time in this community and will watch closely as all of you build on the legacy we inherited from those who came before us.
Thank you for letting me lead this outstanding organization and thank you for all you do for aviation safety every day.
In the 1980s aviation was still a traditionally male occupation in the United States.
If you walked around in any aviation-related business building (private or federal), there likely would be very few women professionals. If, during that same period, you were a female attorney and walked into any FAA ACDO or GADO you would have likely felt a cold breeze into your face.
That was the environment in 1980 when Ms. Margaret Gilligan, Esq. entered the FAA’s Eastern Regional Offices in Jamaica, NY.
With her freshly minted law degree on the wall, she proved to be a terrier and pursued aviation safety with exceptional dedication, legal acumen and safety-driven inspiration. As an early colleague, Lorretta Alkalay (Regional Counsel for the Eastern Region later) commented:
“Peggy was a great friend and colleague to me at the FAA’s Eastern Region when we were both young attorneys. She was admirable in so many ways as an attorney – too many to list here – but what really distinguished her was how very deeply she cared about making sure the agency did the right thing, whether it was a personnel or enforcement case or any other legal issue she was asked to handle. She worked very long hours and her advice and counsel, even as a new attorney, were widely sought by many within and outside the region. ”
Peggy, as she is known, worked her way to Washington. She moved over and up in the Headquarters’ labyrinth. “Over” denotes that she escaped the Office of the Chief Counsel Office and “up” indicates that she moved to the 10th floor as the Administrator’s Chief of Staff, where she worked for 4 different Administrators (note: her bosses were political appointees with different party credentials, i.e. Peggy was so respected that successive AOA-1s recognized that her abilities were so exceptional that she was kept through these transitions).
That job is a difficult one—without the power of her boss, it is expected that she delivers assignments, bad news other directions to senior executives who have loftier titles. It is position with great potential for making enemies and thus for blocking potential avenues for future FAA positions.
Testimony to Ms. Gilligan’s interpersonal skills, she moved to be the Deputy of one of the brightest, most demanding, brilliant and incredibly visible Associate Administrators, Anthony Broderick. He was a whirlwind of action and required his Deputy to maintain the same demanding schedule. The times were difficult for aviation safety and Tony was frequently called to Capitol Hill to defend the FAA’s regulatory actions. It was during this period that the term “Tombstone Agency” was applied to the FAA. When Mr. Broderick retired, Peggy stayed on as Deputy and later she well served Nic Sabatini through his time in the Associate Administrator for Aviation Safety chair.
Following Nick’s retirement, Peggy was named to head this 7,000-employee work force. While the senior policy positions are located in Washington headquarters, many of the personnel responsible for the day-to-day surveillance of airlines, airplanes, manufacturers, pilots, repair stations are located in 9 regional offices, 4 directorate offices and more than 125 field offices throughout the world. The organization’s annual budget is more than $1 billion.
Due to some unfortunate Congressional hearings, which essentially destroyed the chain of command, the chief of FAA Safety Policies was limited in the ability to reach the line FAA personnel. Further, Peggy recognized that her organization, again through the “help” of the Hill, was likely to lose staffing through budget cuts. Efforts to create a standard approach to applying the FARs to the real world met resistance in the multiple layers of management from headquarters through to inspectors, much of the “independence” could be found at the lowest levels of the local staff.
The list of achievements, awards and legacy which Peggy will leave are too long to repeat; here are but a few of this exceptional woman lawyer’s track record:
- April 2006, Laurel Award from Aviation Week & Space Technology magazine for improving aviation safety and “reducing the risk of fatalities in world aviation” through CAST
- 2009, the Robert J. Collier Trophy in recognition of the Commercial Aviation Safety Team’s (CAST) work in developing an integrated data-driven strategy that reduced aviation fatalities in the United States by 83 percent over 10 years
- 2011, the Roger W. Jones Award for Executive Leadership. The annual award is given to two Federal senior executives who have shown exceptional leadership while devoting themselves to a career of public service.
- 2014, Welch Pogue Award for Lifetime Achievement in Aviation. The award recognizes her visionary leadership in the aviation community and was given by Aviation Week & Space Technology and the International Aviation Club.
- Peggy demonstrated an important leadership talent—recognizing and rewarding the people within and without the FAA for their contributions to safety. Such positive reinforcement energized many apostles of reducing safety risks proactively.
- Testimony before the House and the Senate so many times that she may claim a parking space there by adverse possession and with such credibility she deserves an award from all of aviation for the public’s positive perception of aviation safety.
- Attendance at international and domestic events where her participation helped to significantly advance aviation safety.
Peggy’s name, signifying her leadership, vision an d ability to manage the cumbersome regulatory processes is found in Federal Register notices for these impressive, innovative and important safety initiatives:
- “One Level of Safety”
- The definition of what is legal under the set of rules known today as fractional operations,
- a government/industry review of Part 135 standards
- Flight and Duty Time, one of the most contentious FAR being reissued as “Flightcrew Member Duty and Rest Requirements’’ (77 FR 330), a standard which applied new, more relevant “fatigue” assessment.
- The move from “prescriptive,” detailed requirements to performance-based airworthiness standards for certification of Part 23 aircraft and the establishment of a new organization chart to assure that the new approach could be reasonably implemented
- The necessarily slow issuance of the UAS regulations after incredible industry pressure to issue them expeditiously because the US was losing ground to international drone development, which turned out to be an overstated threat.
- Working with industry to establish consistency in interpreting the FARs across the network of FAA offices.
- The development of a new enforcement policy which matched the new cooperative SMS approach to safety.
The single most impressive and hopefully permanent bequest which Ms. Gilligan has given the FAA, its safety mission, its limited human resources and aviation is the implementation of SMS. Here is the tortuous path which her skilled leadership was able to navigate:
- In 2008 the House of Representatives, Committee on Transportation & Infrastructure Oversight and Investigations Hearing held hearing entitled “Critical Lapses in FAA Safety Oversight of Airlines: Abuses of Regulatory ‘Partnership Programs.”Most of the Members took the position that the first level FAA inspectors were right and their managers were wrong. Perhaps because the manager was removed, the field was empowered to ignore and occasionally contradict the guidance of their local supervisors and managers as well as the chain of command up to the Association Administrator for Flight Safety. The consequence of this highly visible reprimand by the Members was an institutional inability to issue national policies.
- Glacier-like process of the issuance of regulations – the cumulative impact of the basic requirements of the Administrative Procedure Act plus multiple collateral statutes (like a Small Business Impact Statement) require significant time to draft and review a proposal. Then reviews, both within the FAA (policy, economics, legal) and above it (DOT, OMB), cause additional major delays. The gestation period from initial conceptualization to final implementation can consume as much as five to ten years. It is difficult, if not impossible, for the FAA to keep up with industry changes, the identification of new technical problems and new technology.
- For twenty or more years, the budget and staffing of the FAA have been reduced. Whether it is true or not, the internal perception is that the FAA’s capacity to regulate, following the modus operandi of the past, is less than its existing safety agenda. The assignment of inspectors, for example, to the P&W powerplants of one airline is no longer possible. Congress has sent the message that the FAA must do more with less.
- Consistency – the pattern of independent, inconsistent application of policy in the field was found by the OIG, GAO, industry and even an FAA ARC. That equates to different interpretations being applied to an airline depending on what ASI explained her/his view of the FARs as well as among airlines, on a macro level. This lack of consistency has subjected the Flight Standards organization to substantial criticism, to which senior management agreed.
- The press and the NTSB frequently criticized the FAA that it reacted to accidents; that their revisions to rules made it a tombstone organization. Upon reflection, FAA senior management decided that it needed to be more proactive in its approach. An initiative began to find techniques in which the regulator could “get out in front” of safety risks.
- ICAO and SMS—this UN organization decided that all civil aviation authorities should implement this state-of-the-art safety approach. Its basis is the analysis of meta data bases from shared airline information , extrapolating significant trends, assessing solutions, cooperative/consensus processes and quick implementation of preventative solutions. The cooperation element of SMS, which includes unions, the FAA and management, requires an open, trusting environment.
- The experience with SMS caused the FAA to realize that a punitive/enforcement tactic and a cooperative compliance approach were antithetical; so the Administrator issued a new Compliance Policy.
- The field, some of the same folks empowered by the 2008 Oversight and Investigation Hearing (#1 above), did not appear to agree with this new compliance approach.
- The Office of Chief Counsel reorganized its enforcement structure to assure that the compliance philosophy was understood and followed.
- Duncan suggested that streamlined teams would manage this new comprehensive strategy.
→ Now instead of waiting until major changes to the FARs must be subjected to the languorous NPRM process, the SMS teams can design and implement IMMEDIATE solutions.
→ Finding fault will be replaced with defining consensus.
→ Proactive will reduce the need to be reactive.
→ FAA subject matter experts will be comfortable engaging in dialogue with the certificate holders about the intent of the FAR and then enter into a discussion of the best way to reduce risks. Confrontation and the ticket writing mentality will abate.
→ The need to promulgate an endless list of new requirements will be obviated by the fact that the problem has been solved already.
→ “One size fits all” will be supplanted by the correction which will address your airline’s particular problems.
→ Getting unnecessary advice from OST/OMB will become irrelevant and using statistical probabilities to anticipate the highest risk of your airline will be the rubric to higher safety.
Ms. Gilligan’s legacy in moving the FAA from a reactive to a proactive organization is detailed here and symbolized by this image:
Flashback to 1980 when the young, woman lawyer joined the FAA and recall the prospects which faced her. Ms. Gilligan changed the culture of this conservative (safety is not a profession which is comfortable with risk-taking) organization. THAT’S EXTRAORDINARY!!!
Upon announcing her decision to retire, praise has come from many sources:
- “In announcing her planned departure, FAA Administrator Michael Huerta praised ‘her knowledge, passion and commitment to ensuring the safety and efficiency of our aviation system.’ He added, ‘During her tenure here, our aviation system has become the model for all modes of transportation and for many other industries. When we think about where aviation safety was versus where it is today, we can all agree that our collaboration with the aviation industry and the safety measures Peggy has championed have had amazing results.’”
- “Throughout her 37 years at the FAA, Peggy Gilligan has been a dedicated public servant focused on ensuring the safety of our skies,” GAMA President and CEO Pete Bunce “She has always been willing to work with industry to improve aviation safety, including efforts to use a data-driven approach to dramatically reduce the number of aviation fatalities in the United States. We applaud her for the many contributions she has made, and wish her the very best in her retirement.”
- “Peggy has been the heart and soul of the FAA’s effort to improve aviation safety for many years. The numerous awards and recognitions she has received throughout her career speak to her tireless dedication to making flying safer. The results of her work are demonstrated in something the public now takes for granted – ever improving accident rates. NATA also deeply appreciated her commitment to improving the interaction between the agency and aviation businesses community and her focus on partnership with industry toward common-sense regulation. Her leadership will be missed,” said NATA President Martin H. Hiller.”Peggy has been the heart and soul of the FAA’s effort to improve aviation safety for many years. The numerous awards and recognitions she has received throughout her career speak to her tireless dedication to making flying safer. The results of her work are demonstrated in something the public now takes for granted – ever improving accident rates. NATA also deeply appreciated her commitment to improving the interaction between the agency and aviation businesses community and her focus on partnership with industry toward common-sense regulation. Her leadership will be missed,” said NATA President Martin H. Hiller.NATA President Martin H. Hiller: “Peggy has been the heart and soul of the FAA’s effort to improve aviation safety for many years. The numerous awards and recognitions she has received throughout her career speak to her tireless dedication to making flying safer. The results of her work are demonstrated in something the public now takes for granted – ever improving accident rates. NATA also deeply appreciated her commitment to improving the interaction between the agency and aviation businesses community and her focus on partnership with industry toward common-sense regulation. Her leadership will be missed.”
- “An advantage of a long career is experiencing the growth, maturation and long-term success of others devoted to good government and public service. If you seek an exceptional example of a representative for those principles, look no further than Peggy Gilligan. From the FAA’s eastern region to the chief counsel’s office to chief of staff for four different administrators and finally serving more than 20 years in the Aviation Safety organization, she has always been an honest, forthright broker unstintingly serving her country and the flying public through shifting political crosswinds. She earned the respect of the international aviation industry and certainly has mine.
- “In Peggy’s message announcing her retirement, she joked about having joined the agency before some of her staff were born. We can only hope they absorbed a smidgen of her knowledge and experience; the depth and breadth of her impact on international aviation is the result of hard work, active listening and thoughtful interaction with the industry, legislators, regulators and colleagues.
- “ARSA looks forward to working with whomever will assume her role, but we all recognize that nobody can take her place. Thank you, Peggy, and best wishes.”
- And many other compliments are likely to be issued in the next days.
Ms. Gilligan overcame many hurdles in her career and leaves the FAA a better place which deals with aviation safety on a proactive basis.Share this article: