Avionics News April 2012 - 26

the view from wAshiNgtoN
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severe cost to do this. Small businesses are unable to recover the investment they have in a customer’s aircraft until the aircraft is declared airworthy and returned to the customer. Customers are not interested in having their aircraft grounded while pending the 90-, 180- and, in some cases, 270-day review. There should be a reasonable, expeditious process for field inspectors to receive an acceptable, documented answer to a question and minimize the burden to the small businesses. We understand the desire to use the “chain of command.” But, it is wholly unacceptable for small businesses to bear the cost of the agency’s unyielding hierarchy. It is essential that an ASI be able to get an official answer directly from headquarters, while keeping the chain of command abreast of the challenge and decision. In addition, jobs are bid based on current regulations, policy and guidance. While a policy change is not supposed to affect the public, it often does (i.e. the field approval policy). When changes are made to the policy that could affect a business, there should be a realistic implementation period before the policy becomes effective. Policies that directly or indirectly affect the performance of a repair station or maintenance and alterations should have a minimum 60-day implementation period.

ing each year: technical, regulatory and business, with both live and online training options. The avionics inspectors need the training. The FAA inspectors are welcome to attend any and all of the training offered by the AEA. We offer all national aviation authorities the same option to attend our training. We’re in this together, and by learning together, we can minimize inconsistent communications and promote safety.

inspector tools to challenge Previous Administrator Approvals

inspector training

It is difficult for our technicians to keep up with changing technology. The pace that products are being introduced with new integrated technologies is overwhelming. Our technicians have a hard time keeping up, and FAA inspectors are falling behind. The AEA provides more than 100 hours of train26
• 2012

We run into a number of situations where an inspector finds a discrepancy, or suspected discrepancy, and recommends that the aircraft be grounded until the issue can be resolved at the headquarters level. This is unacceptable. In most cases, it’s an administrative issue, not an airworthiness issue. However, the FAA has not provided a mechanism for the inspector to start a review and receive immunity from liability, while at the same time allowing the owner/ operator to operate the aircraft. It is a black-or-white, yes-or-no issue. But, the reality is, it is almost always grey. The FAA employee should be able to do their job and not “take” private property without confirmation of a problem, and, as my attorney friends say, due process. This is a major issue, and it needs a viable solution. The FAA should develop an internal process for its workforce to be able to raise an issue internally before involving the public. Let the inspector identify a concern and raise it internally while not taking public property (grounding the aircraft) in the process.

FAA order Philosophy

There has been a general shift in FAA employee policies. Traditionally, the order told the inspectors what

“not” to do. Today, the belief is that the orders tell the inspector what “to do.” I believe part of the problem is how policies are written, how often an inspector gets challenged and what the FAA Academy is teaching. The agency should define its approach, write the policies to support this approach and ensure the academy is teaching (directly and indirectly) to this standard. The road to consistency and standardization begins and ends at the academy. Headquarters can write the best policy around, but if it’s taught with an “us against them” mentality, or what I affectionately call a half-empty glass mentality, headquarters efforts are in vain. At the conclusion of the presentation, the discussion of “relationship” was brought up by an attendee. I could not have agreed more; the ease at which issues are resolved are predicated on relationships. But, as I pointed out, the agency tends to rotate the inspectors through a revolving door of small maintenance facilities. Just when a relationship has been developed, a new inspector arrives; again, causing the small business to bear the cost of “training” the newbie. It makes perfect sense for the local FSDO to break in the new person with a low-risk repair station, but these are the facilities who can least afford the price. When the FSDO opts to use the low-risk small business as a learning tool for new inspectors, the FSDO management must assume the “relationship” that the repair station is unable to establish and maintain by an inspector’s short assignments. We look forward to continuing the dialog with the agency to enhance the industry’s relationship and identify areas where improvements and efficiencies can be achieved. q

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Avionics News April 2012

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