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November 2, 2012
By Dan Namowitz
AOPA and six other aviation associations have requested that the FAA delay action on a proposed revision of its designee management policy and provide more time for the industry to study the 500-page document.
The FAA published the policy revision Aug. 31 with little notice or outreach to the aviation community, leaving little time for stakeholders to analyze it and offer comments, the associations said.
The agency described the order as a consolidation of policies of the FAA’s Aircraft Certification Service, Flight Standards Service and Office of Aerospace Medicine. “However, what we have discovered is that this draft policy appears to institute significant changes to the way the FAA manages the various designee programs,” the associations wrote in a Nov. 1 letter to John Allen, director of the FAA’s Flight Standards Service.
“We are also surprised to see that this policy is based upon a yet to be developed software system and that the FAA expects that during our review and comment we will ‘accept references to [this software system’s] functionality at face value.’”
FAA designees include aviation medical examiners, designated pilot examiners, designated mechanic examiners, designated parachute examiners, training center examiners, as well as engineering, airworthiness, and manufacturing inspection designees.
The associations said they were unaware of any FAA effort to make the document’s availability known through a Federal Register notice, leaving the “vast majority” of the industry unable to complete a review before the original 30-day comment period expired. The FAA extended the comment period to Nov. 1, but the delayed reviews remain incomplete, they said.
The aviation groups expressed concern that preliminary review indicated that “enactment may well lead to a reduction in the number of available designees across all lines of business,” as well as increased workload for designees and FAA administrative staff.
AOPA and the other associations were continuing to review the policy and will work to ensure that it does not restrict access to designees, raise costs, or create other obstacles, said Rob Hackman, AOPA vice president of regulatory affairs. That goal was consistent with the FAA’s stated policy of making greater use of designees to support general aviation’s certification needs, “in light of budgetary challenges,” he said.
Other associations signing the letter included the United States Parachute Association, the Aircraft Electronics Association, National Business Aviation Association, National Association of Flight Instructors, Experimental Aircraft Association, and the National Air Transportation Association.
Hackman also urged FAA designees to review the proposed policy and share their evaluation of its effects with AOPA, adding that industry comments would help the FAA enhance the efficiency and success of the designee program.
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