FAA AIR Transformation
21st Century Infrastructure for America
Rep. Lo Biondo, R-NJ, Chairman of the Aviation Subcommittee of the House T&I Committee, called a hearing, February 15, 2017, entitled “Building a 21st Century Infrastructure for America: State of American Aviation Manufacturing“. The Aviation Chairman and Full Committee Chairman Shuster, R-PA, gave opening statements recognizing the bimodal distribution of the FAA’s certification mission:
Shuster—“It is important that the FAA’s regulations and oversight activities are effective. But it is also important that the FAA’s regulatory processes are efficient and consistent. We shouldn’t have to sacrifice either one for the other.”
LoBiondo—“Yet, the certification process has its problems. As manufacturers design and build to meet these standards, they can experience needless and harmful bureaucratic delays, both internationally and domestically. These delays can be very detrimental to U.S. manufacturers trying to compete globally where every day of delay can mean real losses in both profits and jobs.”
Congress is exceptional at speaking the right words. The term hearing may be a bit of a misnomer—the witnesses are not always heard. The panel expressed good ideas of how to improve American Aviation Manufacturing.
The witness list included:
- Ms. Peggy Gilligan, Associate Administrator for Aviation Safety of the Federal Aviation Administration (Accompanied by: Ms. Dorenda Baker, Director, Aircraft Certification Service, FAA) | Written Testimony
- Dr. Alan Epstein, Vice President, Technology and Environment of Pratt and Whitney | Written Testimony
- Mr. Michael Thacker, Senior Vice President for Certification of Textron Aviation | Written Testimony
Ms. Gilligan, who appeared at her last Congressional Hearing (she is retiring March 31, 2017), highlighted her legacies with the AIR organization:
- Completion of the Section 312 requirement and the other sections of the FAA Modernization and Reform Act
- Issuance of the revised Part 23
- Transforming the certification organization through three initiatives:
- Refresh the certification strategy,
- Invest in management systems to improve performance, and
- Improve our organization and invest in our people.
Her specific text was non-committal as to the next major AIR task—the review and rewriting of Part 25, the existing certification standards for Commercial Aircraft. One rationale might be that it would be unfair for her to burden her successor with any schedule; alternatively, she may have been conscious of the delays which occurred with the Part 23 exercise. The tardiness caught the attention of the Hill, which passed a bill to force the FAA to act of the proposal. A third possible explanation is that Ms. Gilligan senses that the AIR field staff is resisting this transition; so much so that she has realigned the reporting structure among the certification offices.
In any event, it seems as though her fellow panelists agreed on the steps which Ms. Gilligan proposed, but perceived greater urgency to the tasks’ completions.
In particular, John Hamilton, Vice President of Engineering for Boeing Commercial Airplanes, made the case for a more immediate transformation of the rules by which the Boeing Company’s aircraft are certificated:
The Aircraft Certification Service at the FAA cannot efficiently complete these critical validation activities without support from Congress and a commitment by FAA senior leadership to make this work a priority. Type certificate validation by other governments cannot be viewed as a secondary or lower priority function of the FAA. It is a critical priority for Boeing and for all US exporters in aerospace, and Congress must continue to support and prioritize these efforts too.
With respect to our day-to-day interactions with the FAA on certification activities, we have seen progress in efforts to streamline the process and hope that with continued partnership we will see continued progress. Dorenda Baker, the Director of the Aircraft Certification Service at the FAA, has embarked on an effort known as “Air Transformation” to reorganize and better align the Agency’s activities with the strategic imperatives for certification in the coming years. This is a step in the right direction and is worthy of Congressional support and prioritization. This process, as it continues to unfold, must enable the FAA to shift resources to areas of greatest safety impact, including engagement with Europe and other regulatory authorities around the world. Doing so will help the FAA retain its global leadership status, and enable the United States to compete on a level playing field. I want to stress that last point. The FAA must be a global leader in aircraft certification, and: – adhere to risk-based oversight principles that focus the agency’s resources on areas of highest risk, – provide timely and consistent requirements to applicants, – and fully support and promote U.S. exports of aerospace products and services.
Further, he emphasized:
“’This process is not meant to be a re-certification.’ Hamilton said during a House Transportation and Infrastructure subcommittee hearing. ‘A validation should be just that — validating that the FAA conducted the type certificate work to the standards of the foreign regulatory authority in question.’
‘This is a time consuming task and requires FAA resources and, more importantly, a strong working relationship between the FAA and foreign regulators.’
‘Type certificate validation by other governments cannot be viewed as a secondary or lower priority function of the FAA,’ Hamilton added.”
Congress knows how to enact statutes which require the FAA to issue what Mr. Hamilton requested. That only is effective if Ms. Gilligan’s successor has enough talented staff to complete all of the required tasks. The Members in attendance, hopefully, heard the witnesses that Congress should give AIR support and set their work as a priority.