GA ASIAS test without Enforcement- permanent rule for all?

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General Statement of Policy: Aviation Safety Information Analysis and Sharing Project Demonstration for

General Aviation (ASIAS for GA Project Demo)

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The FAA has issued a General Statement of Policy and that is an unusual event. What is said is potentially very significant—the FAA is testing its data rich, proactive safety approach to General Aviation.

As noted in the GSP, GA “has experienced little to no decrease in the number of fatal accidents over the past five years”; that is, this regulatory sphere has great potential for safety advancement. To try to extend the commercial carrier positive recent track record to this different segment of flying, the FAA announced a test of the Aviation Safety Information Analysis and Sharing (ASIAS) in the KPHX area. The numbers generated by that multi-source project have been credited with focusing the attention of Part 121 operators on key factors to improving safety performance.

The concept of applying ASIAS to the Part 91 is not new nor is it without concerns about the GA operators’ capacity to submit the data needed with the less sophisticated and less robust (totally absent?) administrative support atmosphere of these primarily individual fliers. For example, this aircraft fleet is far less likely to have the equipment needed to feed FOQA.

In order to get to the level of granularity and accuracy of information which feeds ASIAS, reports need to be carefully written with consistent terminology. The ordinary GA pilot lacks the time and training to meet those thresholds. The concentration of this test in the Phoenix area and populating the community with trained volunteers may provide a basis to meet these likely deficiencies among the pilots.

The GSP acknowledges one of the perceived problems with ASIAS, the propensity of the FAA lawyers to grab information voluntarily submitted and take enforcement action (under the broadly interpreted exceptions of the policy). To assuage these fears, which are likely to be more pronounced among the GA pilots who do not have company/union lawyers to defend them, the FAA implemented one degree of separation and restated its legal “limitation”.

By making the University of North Dakota the repository for these submissions, that creates more than an appearance of insulation. The record keepers there will “de-identify” the names and any other marking facts. The perception of this different library for the data may reduce the concerns.

In a separate section labeled “Enforcement Policy “, the GSP clearly states

“…none of the data that is being collected during this demonstration project will be accessed or otherwise used for any enforcement activities.”

No exceptions for intentional actions; plain and simple a prohibition. What will be interesting is WHAT the FAA does after this test. Will this absolute prohibition be extended when the GA ASIAS program becomes permanent? Even more significantly, will this test justify an amendment to the Parts 121 and 135 ASIAS?

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