THOUGHTS ON OVERELIANCE ON COMMITTEES, ARCs, TASK FORCES, etc. – 800 Independence Annex

By developer • July 23, 2023

JDA Aviation Technology Solutions

Every time a problem besets the FAA, the Congress, the DOT Secretary or the Administrator likely will decide that the resolution of these safety conundrums must be found among resources outside of the FAA Staff. Below is a list (possibly partial) of ~40 external teams that have recently been chartered. This formula, clearly overused, has several less than positive impacts on defining fixes, speed and on future staff initiative.

As to the Aviation Rulemaking Advisory Councils, their compositions are ordinarily individuals who have practical insights into the rule being considered. The collective experiences of these participants tend to help refine the criteria, process, records and language of the NPRM to be. Recent ARAC proposals, however, have seen long periods between the committee’s final report and the posting in the Federal Register. Agency wordsmiths may not be comfortable with the words in the recommendation. Externally, it appears that these delays may be attributable to inadequate initial FAA staff briefing– what constitutes an enforceable rule, the need for exquisite clarity in the verbiage, Administrative Procedure Act requirements and all of the OIRA justification requirements. With a thorough early education, revisions by the FAA and DoT employees may be minimized

Appointment of these outside savants must be a matter of matching outside knowledge with the task at hand. An impressive name, without currency on the technical elements of the task, looks great in the Washington Post, but imposes a burden of updating them from minutiae to macro policy consideration. Without independent information, the committee member’s primary education frequently comes from the career public servant who was part of the reason for the task force.

The sheer volume of consultative exercises (see above hypothetical annex above) adds to the FAA’s workload. Beyond the aforementioned transfer of the background, internal personnel must take the Task Force’s meeting notes, schedule meetings, prepare material, coordinate participants schedule, collate the papers produced by the members. The ability to guide the search for answers without trying to justify a previous option is commensurate to diplomatic skills in an international crisis.

Individuals who have the valued knowledge for these tasks are recognized as being valuable by their private employers. Some of the SMEs work for companies who recognize the merit of “donating” their time to the projects. Not all aerospace management are so enlightened and are not comfortable with their designee losing time on her/his work schedule. Dilution of this participation limits the Advisory work.

CONSIDER the impact on the career employees who were assigned to the now problematic project. He/She now meets the “know-it-alls” brought in to address the issue. That uncomfortable situation may result in loss of confidence within the building.

THIS IS NOT TO SAY THAT THESE ANCILLARY RESOURCES SHOULD BE TERMINATED. Rather, reliance on these SMEs should be employed when there is a very specific technical puzzle and the community of relevant expertise with adequate time available.

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