Congress has never appropriated enough dollars to hire FAA inspectors to be present at every step in the airworthiness process of analyzing every element of an engineering review. The FAA created, and Congress has reviewed with approval, the Designated Airworthiness Representative, the Designated Engineering Representative as well as the Organization Designation Authorization (DAR, DER and ODA respectively). The transparency and validity of these extensions of the Administrator’s authority are well documented by the FAA. The system is far from perfect, but without this tested regulatory concept, the FAA could not accomplish its mission.
Gerald Dillingham of the Government Accountability Office submitted testimony questioning the efficacy of the Designee system. His testimony openly acknowledged that the FAA is resource constrained, but asserts that better data will provide the FAA with a clearer picture of the risk profile and interaction among the FAA, the DER/DAR/ODA and TC applicant. The GAO study also notes that more certification projects and more innovative technologies (which will challenge the FAA staff) equates to a substantial increase in the FAA’s burden.
What is surprising is the absence of any comment by Mr. Dillingham about the promising developments that are derived from a recent FAA ARC on Part 23. That group defined a new rubric in which the design would refine the regulatory requirements. This new approach would identify the critical points in the certification process and could pinpoint what designees are needed. With such sharp focus, the FAA’s use and surveillance of such authority would become more precise.
Maybe the answer is to do things smarter as proposed by that FAA and industry group. As one commentator quipped, “We can get twice the safety at half the cost.” Maybe the answer is thinking outside the box.Share this article: