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Transforming the Way the FAA Does Business

On Wednesday, the FAA sat down with industry to discussed what the next generation of the FAA will look like.  The FAA has a very ambitious plan to change the way that aerospace manufacturing operates, and to make concurrent changes to the FAA itself to reflect these new paradigms.

“What we are talking about is a transformation in the way we do business”
— FAA Executive Chris Carter

The FAA’s goal is to have a more efficient way to perform certification.  This should allows applicants (for approvals like TCs, STCs, PMAs, TSOAs, etc.) to have more control over the approval/certification schedule.  But that control will come at a price – the FAA will expect the applicants to have a greater level of accountability for the design process.

At the root of the FAA’s changes is a transformation from compliance control (in which the FAA acts as a gatekeeper, accepting industry inputs and then judging the inputs for compliance) and moving to compliance assurance model. Companies would have their own compliance assurance systems which would help ensure that the company continues to maintain compliance with each new design.  Instead of making a showing to the FAA, the company would make the showing to the resources within its own system, and then its won system would review the data and ensures continued compliance within the system. Under the compliance assurance model, instead of looking at data to assess compliance, the FAA will oversee the compliance systems of the companies.  This means that each company would have a self-correcting system and the FAA’s job would be to ensures that the systems work.

One of the challenges facing the FAA is making this scalable.  Scalable system will need to be able to fit the needs of the largest and the smallest companies, and will need to fit a range from mature businesses with robust systems to brand new market entries who do not yet have mature systems.

The FAA envisions a system that resembles a multi-lane swimming pool.  The lanes will represent new companies that need significant FAA attention, mid-life companies who need FAA support but do not demand the same attention as new companies, and to mature companies with mature systems.  The last category will be the “independent lane” and the FAA expects that there will be tremendous incentives to be in that lane, as it would permit a company to more independently pursue projects – without direct FAA involvement in certification that can slow a project down.

Chris Carter of the FAA stressed that industry needs to be a willing participant in order to make this work, because it will require industry to shoulder new burdens.  If industry is not a partner then this will not work.

The FAA expects to have headquarters units under the reorganization that have very specific roles, like ensuring that changes are properly managed.  Under the concurrent reorganization, it is expected that existing FAA field structure will be replaced with centers of excellence around the country.  Those centers will report directly to headquarters. They will feature employees from many or all of the new divisions of aircraft certification.  It is possible that PMA applicants may be directed to a center of excellence that is geographically distant from their location, but that robust communications are still expected using modern technologies.

There are many reasons for doing this, but one of them is the FAA’s awareness of the growing globalization of the market.  Other countries are entering the market.  Nations like Japan and China want to be part of the international discussions.  A recent deal among four authorities (ANAC TCCA EASA and FAA) highlights the need for other nations to join the discussion as their citizens begin to develop airframes and engines.

The FAA’s transformation is still a work in progress, but as more ideas become solidified we hope to continue to bring the industr ynews of what the next generation of the FAA will look like.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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