To follow the Charles Dickens’ analogy, when the FAA arrives, “it is the worst of times”. An inspector’s visit usually means that something may be wrong; with the current FAA field staffing levels, it would be most unusual for a POI or ADO person to stop by for a social visit. The usual reason for their coming to your office is because somehow the FAA has information that all is not perfect with your certificate.
One way of limiting such occurrences is establish a proactive program with your FSDO, ADO, ACO, MIDO, CMO, etc. The general concept is to create a dialogue, initiated by you, which makes it clear that you and your team want to develop a state-of-the-art compliance disposition. Over time, for example, you can learn what the local office’s agenda is and then reflect such priorities in your regulatory compliance program. This is but one aspect of a far more comprehensive set of actions designed to get you and the FAA on the same page.
Comparing the reports of these two cases suggests that Bangor International Airport had created a positive relationship with its ADO and the Albuquerque FSDO did not hold the local airline in high regard.
1. BGR was the site of an aircraft sliding off a taxiway
a. In response thereto the FAA took an unusual step in sending a Notice of Proposed Civil Penalty with a suggested sanction of $95,000.
b. The management of BGR took immediate and appropriate actions intended to cure the deficiencies related to the taxiway excursion.
c. The FAA again took an unusual step (but totally justified) of reducing the civil penalty to $35,000.
d. An FAA follow-up inspection demonstrated BGR’s compliance
> Lesson of the story, BGR had created, BEFORE this incident, some level of credibility. That residue of trust was a critical predicate to the FAA’s lowering of the sanction.
2. NMI was found to have major problems in its maintenance or its aircraft in December
a. The entire fleet was grounded and five of its six Cessna 208B Caravan 675 are still grounded
b. Its chief pilot and director of operations have left and been replaced
c. Its President has been fired
> Clearly, the FSDO appear to have entered this matter with less than positive impressions of the carrier. Remedial actions by NMI have not staunched the bleeding.
Regulatory affairs include something akin to goodwill. In broader terms, and aviation jargon, would identify this as Preventative Maintenance of the entities’ FAA authority. Devoting time to assuring that the FSDO, ADO, etc. is aware of what is being done to comply is equally important to work done on the line or on the field to prevent deterioration of the engine or runway. If the FAA does not believe that the certificate holder is working hard to comply, they enter any visit to your offices with suspicions and few safety organizations are perfect; an investigator can find problems under such circumstances. If the FAA suspends or revokes the certificate, all exercise of that authority ceases. All existing assets have no operating value.
This tale of two tickets demonstrates that devoting time, talent, effort and budget to Regulatory Affairs is a wise investment.
Acronyms used in this article (in order):
POI: Principal Operations Inspector
ADO: Airport District Office
FSDO: Flight Standards District Office
ACO: Aircraft Certification Office
MIDO: Manufacturing Inspection District Office
CMO: Certificate Management Office
BGR: Bangor International Airport
NMI: New Mexico Airlines
TELEVISION NEWS: NM Airlines president fired for unknown reasons