The FAA is closing its International Field Offices; does it matter?

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The FAA has global jurisdiction, surveillance and relationship duties. As of September 15, 2015, the Frankfurt office, the last of its International Field Offices on foreign soil, will close. One must respect the hard budgetary decisions which the Administrator must make and recognize that with limited appropriations that he is forced to make Hobbesian choices between two bad options. The Members who speak up about the difficulty of US manufacturers to get foreign certification and who believe that foreign repair stations constitute a substantial risk to global aviation (read US jobs), ought to make oversight decisions about their expressed priorities and the FAA budget before them. If the IFOs matter, perhaps Congress should provide the necessary dollars.

What does an IFO do? Here’s how their functions are described in

  • Authorize operations to the United States by foreign air carriers
  • Approve maintenance programs and MELs and authorize certain other operations for U.S. registered aircraft used by foreign air carriers
  • Conduct surveillance of foreign air carriers operating into the United States
  • Conduct certification and surveillance of U.S. Foreign Repair Stations”

That’s the explicit task list; U.S. and foreign certificate holders (Parts 23, 25,121, 129, 145 and others) have regarded Frankfurt, London and Singapore as their eyes and ears in the complex business of international aviation safety regulation. If, for example a repair station located in the Middle East needed help understanding a complicated Airworthiness Directive, it could place a call one time zone away rather than a half a day behind.

Equally, an American carrier seeking to start up a new station on the Continent could call the IFO to get insights into the local aviation situation. Even the best State Department Commercial Affairs office cannot provide the insights into such technical relationships.

The relationships developed in those communications to/from the IFO used to add to the FAA’s knowledge and influence wherever the FAA staff was located. It has been a subtle network around the globe’s safety

Although the FAA will maintain a regional office in Brussels, the resources to perform, for example, inspections of the dreaded Foreign Repair Stations will be withdrawn to nearby Miami, FL and Dallas, TX. The travel costs to/from the overseas sites as well as the time away from their home station may cause the personnel from Miami and Dallas to limit their time scrutinizing these organizations which form a vital element of US aviation safety.

Congress deleted the word “promote” from the FAA mission, but it is well established that the equivalent authorities around the world have no compunctions in pushing its country’s product. Helping US products overseas was not an IFO function, but their availability to answer technical questions on our powerplants and airframes must have helped.

The aeronautical business is already global and more countries are joining that community. That means not only does the US have to certificate the products of other countries, but the increasing American OEM reliance on overseas sources translates to FAA surveillance of those international subcontractors. Those developments have driven the FAA to rely on foreign CAAs to assist in some of those assignments by a system of Bilateral Airworthiness Safety Agreements. If IFOs will be extinct, the need to extend BASAs may increase.

There is a difficult calculus is balancing safety versus budget. The benefit/cost ratio for an IFO involves factors which are very subjective. How does one value an effective relationship with local authority? If one can make an estimate of such a “return”, how do you compare to adding/retaining a domestic Aviation Safety Inspector? Such “grayness” is a gradation with which Congress is familiar; in their review of the FAA’s FY 2016 budget, they should match their prior statements on international certification, foreign repair stations, etc. with budgetary decisions on whether IFOs merit the dollars.

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