Simplistic criticism ignores Reality of Complex Safety Rule Agenda FAA Faces

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ARTICLE: FAA delays new safety rules for airline pilots

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Aviation and the safety regulation thereof must be intuitive. The attached piece recently published in VOXXI and picked up by a number of others makes it clear that an agency’s performance can be assessed under a simple standard:

“The law is only as strong as the regulations that come from it so this (implementation) process is the true measuring stick of how this law will ultimately be viewed.”

The quotation and the article assert that the agency has failed based on its inability to meet deadlines imposed by Congress to amend the rules as to pilot training, tiring work schedules, lengthy commutes and relatively low experience levels for pilots at some regional carriers.

These conclusions ignore certain realities. Here and here are but a few examples of the major regulatory assignments facing the agency:

  • Pilot Certification and Qualification Requirements (formerly First Officer Qualification Requirements) (HR5900)
  • Flight Crewmember Mentoring, Leadership and Professional Development (HR 5900)
  • SMA rules for Part 139 certificate holders
  • Major revisions to the Part 21, 23 and 25 Certification Standards
  • Air Carrier Contract Maintenance Requirements
  • Protection of Voluntarily Submitted Data
  • Pilot experience rule delayed
  • Large Aircraft Security Program
  • Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers
  • Supercooled Large Droplet Icing Conditions
  • Photo Requirements for Pilot Certificates
  • Air Ambulance and Commercial Helicopter Operations; Safety Initiatives and Miscellaneous Amendments
  • Operation and Certification of Small Unmanned Aircraft Systems (sUAS)
  • Prohibition Against Certain Flights Within the Territory and Airspace of Afghanistan
  • Requirement for Wildlife Assessments at Certificated Airports
  • Regulation Of Flight Operations Conducted By Alaska Guide Pilots
  • Air Carrier Maintenance Training Program
  • Installed Systems And Equipment for Use by the Flight Crew
  • Safety Management Systems for Part 121 Certificate Holders
  • Slot Management and Transparency for LaGuardia Airport, John F. Kennedy International Airport, and Newark Liberty International Airport
  • Part 121 Exiting Icing
  • Orbital Debris Mitigation Requirements
  • Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside of the United States
  • Requirements for Chemical Oxygen Generators Installed on Transport Category Airplanes (Chemical Oxygen Standards)
  • Production and Airworthiness Certification II
  • Prohibition of Tail End Ferry in Part 121 (Reauthorization)

Many, if not all of these major initiatives, are the result of a finding of substantial safety benefits by the FAA, the NTSB or Congress that the rules must be revised immediately. Every one of these proposed regulations ALSO have critics that vehemently oppose the amendment for a variety of not inconsequential safety, operational, maintenance or other rationales.

The FAA resources for the writing and revising of the rules have been reduced by the same legislative body that has imposed these projects on the agency. Rulemaking is not the only mission of this safety body; the Aviation Safety staff also has the job to surveil the hundreds of certificates held by airlines, airports, AT towers, repair stations, pilots, mechanics and type/production certificates plus a range of other aviation concerns.

The measuring stick mentioned above may not be a single line, surely occupies multiple dimensions, is not held in a single location and has a scale that is altered by external authorities constantly. The quote ignores all of the complexity and dynamic nature of the multiple priorities. The FAA is doing all that it can do as soon as it can, given its limited resources. If there is anyone so omniscient that he/she can tell the bureaucrats what on the above list should be delayed in favor of what other projects, let them speak.

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