News Archive

Ticket program finally dead
AOPA says FAA responded to industry concerns with new ‘Streamlined Administrative Action Process’

The FAA “ticket program” is officially dead, with the last shovel of dirt piled on the grave July 15. That’s when the Federal Aviation Administration publicly announced the details of the ticket program’s replacement, the Streamlined Administrative Action Process (SAAP).

“The FAA responded to AOPA’s major concerns and answered all our questions,” said Phil Boyer, president of the Aircraft Owners and Pilots Association. “There won’t be any ‘ramp cops’ handing out tickets to pilots. The new SAAP is marked improvement from the ticket program.

“We all yelled long and loud, and the FAA heard us.”

When the FAA first proposed SAAP last December, AOPA said the devil could be in the details. “Now that we know the details, SAAP appears to maintain the same level of fairness as the existing Administrative Action Program,” Boyer said.

SAAP eliminates the “on-the-spot ticket” and provides for faster notification and resolution of administrative actions. Pilots will also have 30 days to respond to the action with additional information to explain or mitigate the alleged violation.

AOPA and its members worked with the FAA for a year and half to get an acceptable program. “AOPA’s questions were very helpful in addressing the concerns to the original program,” said Mike Henry, assistant manager of the General Aviation and Commercial division in the FAA’s Flight Standards Service, during a private briefing for AOPA officials July 6.

The FAA first proposed the ticket program in February 1998. It brought immediate opposition from AOPA and a united aviation industry. In both formal and informal meetings, AOPA told Administrator Garvey and other FAA officials the ticket program was unfair and a setback for safety.

The FAA began revising the program, and by October 1998, Garvey told the AOPA Expo ’98 convention in Palm Springs, “The FAA ticket program, as you know it, is dead.”

During an industry/FAA meeting in December 1998, Garvey told AOPA’s Boyer, “Phil, we got your members’ cards and letters, we heard the message, and we’re taking appropriate action.” The FAA unveiled an outline of its modified program, called SAAP, on December 21.

But the outline wasn’t enough for AOPA. The association wanted program details. AOPA sent the FAA a letter January 8 outlining six key questions, questions the FAA used to refine SAAP.

The FAA maintains SAAP will reduce paperwork. That will shorten the time it takes to resolve violations that don’t pose a serious threat to aviation safety and that don’t require legal enforcement action.

The existing Administrative Action Program (FAA Order 2150.3A) is still the basis for SAAP. A new bulletin supplementing that order will be issued, FAA inspectors will get a new form (“job aid”), and the FAA will automate much of the administrative action process.

After a minor infraction is discovered, an inspector will discuss the problem with the pilot and complete the job aid. The inspector will return to the office, review the pilot’s “compliance history,” and determine the appropriate administrative action.

Information from the job aid will be entered into the FAA’s Enforcement Information System computer database, which will automatically generate a “warning notice” or “letter of correction,” to be mailed to the pilot from the FAA’s Oklahoma City offices.

(A warning notice simply states the alleged violation and admonishes the pilot to comply with regulations in the future. A letter of correction adds a record of remedial action taken. These letters are not considered legal enforcement actions but do remain on the pilot’s record for two years.)

The letter will be mailed to the pilot within three days. That’s a big change. Today the FAA needs an average of 75 days to get a letter out under the current manual processing system.

The pilot may respond to the letter within 30 days, providing information that may explain or mitigate the alleged violation. The FAA could withdraw the administrative action based on that submission and remove the alleged violation from the pilot’s record.

“We support an informal counseling approach, which we believe will have a beneficial effect on aviation safety,” said Boyer. “And we commend the FAA’s efforts to become more efficient.”

But Boyer added a note of caution.

“Just because it will be easier for inspectors to issue administrative actions, we hope they will continue to use good judgment and apply the minimum sanction necessary to ensure compliance,” said Boyer. “A blizzard of computer-generated enforcement letters won’t make us safer.”

Boyer asked that the FAA use the computer database to provide AOPA a regular summary of the most common violations. He pledged that the AOPA Air Safety Foundation would address those violation areas in the more than 300 free safety seminars it conducts each year.

“This kind of dialogue, education, and cooperation between the FAA and industry are keys to improved aviation safety,” Boyer said.

The 350,000-member Aircraft Owners and Pilots Association is the world’s largest civil aviation organization. More than one half of the nation’s pilots are AOPA members.

99-3-013

July 15, 1999