IG’s Report on FSDO Certification Priorities overlooks less bureaucratic Options

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The interplay among Congress, US DoT Inspector General and the FAA about the delay in issuance of certificates leads to conclusions, typically critical, about Flight Standards District Offices. Review of those IG points and of Order 8900.1 suggest that there may be more basic solutions of the problem.

Congressman Cory Gardner (R-CO) wrote May 11, 2013 to ask the IG to examine whether the Denver FSDO has been negligent in processing new certification applications for both commercial and agricultural aviation operations. In response, the IG issued a report on June 12, 2014 finding significant delay problems with that office, also providing numbers on other FSDOs’ similar problems and not surprisingly, issuing a number of management, prioritization, resource and confused, changing guidance issues.

The IG report (see ↓below) began with an analysis of the Denver office. There it was found that this FSDO had unfulfilled positions, that the Region failed to detect this deficiency and that the local management diverted resources to “unplanned activities.” The IG compared this office’s certification’s productivity with other FSDOs in the region and found it deficient.

The IG then chose to expand the scope of its critique and to assail the lack of priorities set by the FAA senior management for certification. The current FAA practice is to respond to applications for air carrier or agricultural authority on a “1st Come 1st Serve” basis. The IG argues that the FAA should (maybe already has) permit dealing with “less complicated” certifications before the more complex applications. Unless the IG can create some “crystal ball” certification analysis, that is a very impractical suggestion.

For example, the mere fact that one request is for an agricultural authorization and the other involves demonstrating compliance with Part 135 would qualify, under the IG prescient test, the ag flight application as easier. That’s the intuitive judgment, but until the FAA spends some time with both applicant, the fact, that the simple agricultural flier has a marginally airworthy aircraft or cannot write the most basic of manuals, would not be known. Complexity of an application is rarely discernible from a mere review of the “cover’ of the documents.

It would be both inappropriate and unfair to create such exceptions to the “1st Come 1st Serve” rule. In fact, “easier” might become a colorably safe substitute for some other reason to move it up the inbox like the applicant is a friend. Such ambiguous criteria would be subject to abuse.

The next point of the report is the lack of a management tool to predict that each individual office’s capacity to handle the next certificate. The IG then suggests that if such a wait list predictor was available, the office manager could suggest that the applicant try another office. While not published in the Federal Register, most applicants know that one office is overworked and that others are not as backed up. In fact, the communication network among those who work on such certification applications provides good intelligence as which FSDO is most likely to be able to respond on a timely basis, which office has the best experts on specific problem areas or which office is most likely to “find” problems. Further the FAA rules provide the applicant with much latitude as to where to file its request. Not every “problem” is best solved with some bureaucratic mechanism as suggested by the IG.

The above chart demonstrates the next point of attack—changing guidance on priorities. The red, green and yellow dots on the chart indicate stop, go and pause. If one reads carefully and even the IG acknowledges this, it is clear that these conflicting directives were driven by Congressional and Administration alterations of the FAA’s budgets. FAA’s priorities are safety 1st and discretionary action 2nd. It is hardly fair to label this criticism as “Frequently Changing Priorities” which suggests that these variations were FAA decisions rather than exogenous budgetary matters.

The IG’s review did not identify three embedded FAA principles which are important to this issue.

First is FAA Order 8900.1 Volume 1 Chapter 3 Section 2 1-156, which establishes the daily priorities of the people whose job it is to process these applications. This Order makes it clear that the Aviation Safety Inspectors’ lowest responsibility is certification after surveillance and enforcement. This has been FAA policy for years, particularly since Congresses and Administrations have made conscious decisions to reduce the career staffing.

A second creative program, Qualified Certification Consultants for Part 121 applicants , eases the burden of FSDOs for new carriers. Requests for this authority involve complex paperwork and iterations of refinements of these documents. The identification of these external assets is a potential source of decreased time demands on these field offices.

A third unnoticed important development is another positive one. FAA Senior Aviation Safety Management has recognized that it is unrealistic to expect that its historic surveillance practices will continue; no longer will ASIs be able to visit facilities in order to gain their intelligence. The new discipline, part of a broadly based data initiative, is to use Safety Management Systems of the regulated and Safety Assurance System/ Safety Approach for Safety Oversight. The risks identified by SMS and further enhanced by the SAS/SASO will direct the focus of the ASIs and increase the efficiency of their work process.

Those tools should permit the FAA staff to allocate their time better and perhaps to prioritize their time better. If greater efficiency in surveillance is attained, the FSDOs may have greater resources to respond appropriately to certification requests. Between an informed universe of applicants who generally know where to go to get the best, quickest service and the FAA’s new approaches to maximize the deployment of the ASIs, there is reason to believe that the IG’s list of new bureaucratic solutions is superfluous.

REPORT: Weak Processes Have Led to a Backlog of Flight Standards Certification Applications

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