FAA Field Approval Process Improvement

The following is a statement from the Aircraft Owners and Pilots Association (AOPA) Statement presented to the Federal Aviation Administration (FAA) for a public meeting held on July 19, 2001:

AOPA, representing the interest of approximately 75% of all aircraft owners and 370,000+ pilots is extremely interested in the topic of Field Alteration Approvals (Field Approvals) conducted by the local FAA Flight Standards District Office (FSDO). These have been a vital method for safety enhancements to the General Aviation community for many decades. If it were not for the Field Approval process, many of the alterations and equipment installations intended to improve safety and increase the utilization of the General Aviation fleet would not have been realized.

Unfortunately, AOPA has noticed a marked decline in the ability of aircraft operators to readily obtain Field Approvals for a variety of alterations and installations over the past several years. This is important for the installation of GPS and other avionics improvements. The aviation industry and the FAA are at an impasse in the use of Field Approvals. The industry contends the FAA doesn't want to take the time for their approvals, while some in the FAA argue that many Field Approvals do not meet the regulatory requirements and, hence, create a safety concern. AOPA questions this supposition and was unable to identify any safety related study that validates this safety concern. It was only after much persistence on the part of the General Aviation community that the FAA elected to address this issue of decline through the formation of the FAA Field Approval Task Force and the Field Approval Process Improvement Team (FAPIT).

Although AOPA supports the FAA's goal to improve the Field Approval process and improve service, we believe that this effort is lacking the necessary ingredients needed for an optimum, mutually beneficial outcome. Rather than simply criticize, AOPA offers the following recommendations to improve the process:

The FAA must be willing to commit more dedicated inspector resources in each FSDO for the conduct of Field Approvals, including reallocating and training existing inspectors.
The FAA can improve the efficiency and productivity by using FAA Designated Engineering Representative (DER) and FAA Designated Airworthiness Representative (DAR) in the Field Approval process. In most cases, FAA inspectors can simply provide designee oversight in the Field Approval process.
The FAA should identify agency various field offices that can be used to assist other FAA inspectors, DERs and DARs in more complex or novel circumstances.
The FAA should revamp FAPIT by including expert industry representation. Expert industry representation and participation in FAA initiatives, such as FAPIT can produce mutually beneficial results in the shortest amount of time.
FAA management must insist that the Field Approval Process be given a higher priority if General Aviation is to take full, immediate advantage of new safety enhancing technologies.

AOPA is committed to working closely with the FAA to improve the Field Approval process. We believe that the Agency must make a commitment to increasing the use of this important authority.

Submitted by,

Lance Nuckolls
Director - Regulatory and Certification Policy
July 19, 2001