Submitted by Aaron Hilkemann, President & CEO
On Wednesday, I had the unique experience of testifying on Capitol Hill to the House Committee of Transportation and Infrastructure.
I was originally asked to testify because of my positon on the Board of Directors of the General Aviation Manufacturer’s Association (GAMA). However, House committee members expressed interest in hearing about the experiences of Duncan Aviation and our longstanding and sometimes complicated relationship with the FAA.
My goal in testifying was to show support for some excellent recommendations the FAA itself has that are important to industry companies like Duncan Aviation. The FAA Modernization and Reform Act of 2012 included Section 313, a provision designed to improve consistency of regulatory interpretation and enhance communications between the FAA Flight Standards and Aircraft Certification offices and industry, to promote better and more timely regulatory decision making. The Act required the FAA to establish an advisory panel to review and address findings of a report by the Government Accountability Office that cited inconsistent interpretation and application of regulations as one of the leading systemic issues affecting repair stations, air carriers and manufacturers.
In July of 2013, the FAA submitted a report to Congress with the recommendations of this advisory panel. I wanted to highlight two recommendations that are of particular interest to Duncan Aviation.
The primary recommendation was for FAA Aviation Flight Standards (AFS) and FAA Aircraft Certification Service (AIR) to consolidate the service organization-level regulatory and guidance libraries into a single Aviation Safety (AVS) master electronic database resource to allow the agency and industry access to relevant rules and documentation. Further, the FAA would conduct a review of all regulatory, guidance, policy, and interpretation documents to identify potential conflicts, cancel outdated material, and ensure proper cross-reference with applicable regulations. This ensures that FAA inspectors and industry representatives have access in one place to the regulations and all relevant interpretative material and acceptable methods of compliance to support consistent interpretation and application.
The Section 313 report also recommended that the FAA establish a Regulatory Consistency Communications Board (RCCB) comprising representatives from AFS, AIR, and the Office of the Chief Counsel (AGC) that would provide clarification to FAA personnel and certificate/approval holders and applicants on questions related to the interpretation and application of requirements. This promotes consistency of interpretation and application of regulations to determine acceptable methods of compliance. The RCCB would be the arbiter for all parties.
The establishment of the RCCB will help promote constructive dialogue between the FAA and applicants for the resolution of potentially adverse issues in an expeditious and fair manner.
I am hopeful that committee members understand the importance of approving and properly funding these two recommendations.
To share your support in support of these issues, I encourage you to contact your Congressional Representative.
Click below to read my written testimony.