This Could by Good News; This Could be Bad News

Guest Editorial by 'Hippolyte Bouchard'

The FAA has started another new policy to implement consistency among the FSDO networks in response to public complaints. The new policy, as recently announced by the Administrator, is perhaps a good change, but it does not do much to address the original complaint: the inconsistencies in the field approval process.

This happens a lot: one FSDO office may approve a small modification for an aircraft, and the pilot’s buddy (in another FSDO district) who wants to alter his aircraft in the same way is told that the alteration cannot be field-approved. The FAA has tried to change that in typical government fashion by issuing more-precise guidelines, more centralization, less autonomy of the field inspectors; and the old government standby -- longer paper trails, involving more people, to share the responsibility. That did not work; it just made field approvals much harder to get. To find a solution, the problem must first be identified.

If it's not broken, don't mess with it.

The field approval process was not 'broken.' It worked very well over the years. Mistakes were made with field approvals, but not because of the process; most of the breakdowns came as a result of FAA's hiring practices and attitude. Let’s face it, the FAA has some 'sky gods' to be sure, but it has a greater number of people who don’t have any real experience with general aviation. Those who are experienced move out of GA, leaving the least-experienced to attend to our needs. That in itself keeps GA at the bottom of the FAA food chain.

Responsibility? You're creepin' me out!

Combine that with the fact that giving a field approval means that the field inspector is taking some responsibility, something that government employees are not known for -- it is a wonder that the FAA hasn’t stopped field approvals altogether! The attitude that 'if someone can read and follow instructions, he can do the job,' is wrong. An inexperienced person can muddle through a field approval, but it takes a lot of time from everyone involved. It takes two days to install a radio -- and up to six months for approval.

A bigger problem, found in the psyche:

FAA field inspectors also have another problem in admitting that they don’t know. Somehow, I suspect that this is the root of the evil. It is a very human reaction (and very common to employees of large entities with a corporate ladder to climb) to not admit that they don’t know. It’s easier to say that an alteration cannot be approved, so the problem will go away. That is the inconsistency that has generated so many complaints.

She hears, but doesn't understand...

The administrator, Marion Blakey, has listened to the people. She just didn’t hear what they were saying. She has the right intentions and has given a step forward to the solution of inconsistency among FSDOs.

• To get better service from the FAA is going to take more than being able to question the inspectors' decisions. The FAA needs to find personnel with experience in the areas involved, and keep them there. Career-wise, within the FAA, GA must be considered as equal to the heavy metal, instead of a place from where to start climbing the FAA corporate ladder.
• The training program for field approval authorization needs to be scrapped. The solution will take a school where the people are educated on the subject, where they learn to think, not a 'diploma mill,' where they are trained like a monkey,  getting a treat for pushing the right button.
• The field inspectors must realize that unnecessary delays in approvals are very harmful to the industry. The process should be streamlined instead of burying it in more layers of bureaucracy -- those only serve to delay and increase costs with no benefit to the public.
• A system should be put in place that when an inspector is asked for approval on an aircraft alteration that they may not be familiar with they can find within the FAA someone who is, and consult with them.
• The Instructions for Continued Airworthiness which is incorporated in field approvals needs revision to better its disposition and make itself useful to someone other than the FAA. Streamlining any AFM changes associated with field approvals is sorely needed.

Please note:

Streamlining does not mean "less safe" and more bureaucracy does not mean "more safe." The FAA (as well as the media) needs to learn this.

It’s not all the FAA’s problem. Peter Pilot has a habit of talking to the inspector to get to the bottom of the delay (and thus creates a fair share of misery for all involved, as he often knows less than nothing about the process and gets his facts very confused). But it’s his airplane and if he chooses to delay in this manner, it’s his right, but he shouldn’t blame the FAA, as he often does. All of this and more contribute to the FAA "inconsistencies" and if history is any indication, it won’t get better. Be careful what you wish for: you might get it.

(To the editor: If this gets published, for God’s sake don’t use my real name. I could end up on some terrorist list somewhere and a goon squad will hunt me down and take my nail clippers!)

FMI: www.faa.gov