Aeronautical Repair Station Association

FAA Standardization: Complicating What Is Simple

Eric ByerRecently, a congressional panel reviewed (among other things) the Federal Aviation Administration’s (FAA) plan to implement the recommendations issued by the FAA Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI-ARC) that Sarah MacLeod and I served on for over 18 months.

Without boring you, the main thrust of the CRI-ARC was a recommendation to unite regulatory materials into one centralized, master database available to all. Guidance, letters, interpretations and all other advisory material related to a regulation would be consolidated and cataloged within this master database. By having one centralized, master database, the burden to secure consistent application of regulations would be reduced dramatically because all parties would utilize the same resource. Pretty simple concept, correct? Not so fast; this is the government we are dealing with here, folks.

After the CRI-ARC issued its recommendations, the FAA had to provide its congressionally-mandated strategic plan to implement the items outlined in the report. While there is certainly good intent to accomplish fruition, especially the master database, the fact is the FAA strategic plan does nothing but overly complicate recommendations that are meant to accomplish the exact opposite. The plan includes studies to review studies and proposals to develop more plans; it regularly highlights the lack of resources to execute the recommendations.

The folks at the FAA who served on the CRI-ARC and developed this plan are indeed wanting to standardize regulatory interpretations. FAA leadership must recognize the CRI-ARC’s recommendations serve as a means to ease the financial and resource burden on both the agency and industry.

Change is never easy. This is why we have federal bureaucracies that only know how to kick the can down the road, not accept change as the means to resolving problems. It is time for 800 Independence Avenue to stop complicating a report that ultimately set out to achieve one primary mission:  simplification.

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October 30th, 2013

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