FAA's Regulatory Consistency Comm. Board
10-06-2016, 09:09 AM
#1
New Hire
Thread Starter
Joined APC: Jan 2016
Posts: 6
FAA's Regulatory Consistency Comm. Board
FAA Consistency
FAA’s Regulatory Consistency Communication Board
Learned folks like Emerson, W.E.B. DuBois, Wilde, Huxley, Senator Chaffee and Ramadan have eloquently expressed thoughts on consistency—its value, its derivation, its consequences, its creation and its relative merit. Constitutional experts, Canonical lawyers, the most exalted tafsir of the Quran and Talmudic Scholars, to name a few, who are recognized for their ability to parse important words would likely be befuddled by trying to synthesize the meaning of the above 6 quotes.
ARSA issued a press release, entitled “FAA Consistency Board May Rein In Regulatory ‘Wild West’”, announcing the early actions of the Regulatory Consistency Communication Board. ARSA, almost single-handedly, convinced the FAA to establish the Consistency of Regulatory Interpretation Aviation Rulemaking Committee and that ARC was the aegis for the RCCB.
Consistency is something which the aviation has sought for years from the FAA. In fact, in response, to industry concerns and a Congressional mandate, the Administrator and Aviation Safety have been working to incorporate that concept within the agency’s culture particularly as it applies to the interpretation and application of the FARs. That is an immense challenge and many have doubted whether it could be done effectively.
The FAA faces a very difficult challenge. It must apply, on a consistent basis, a statute with many undefined terms and over 1,000 pages of the Code Federal Regulations, which are amended periodically.
The FAA organization, charged with enforcing the statutes and rules, starts with a single Associate Administrator, follows a pyramidal organization down through a large headquarters organization through layers of regional offices down through FSDOs, ACOs, MIDOs, CHDOs and a host of other field offices and hits the geographically dispersed front line of principals, inspectors and a host of individuals “empowered” to interpret the rules.
Add to that mix, hundreds of thousands of handbooks, orders, ADs, ACs and many, many formal/informal documents.
An added level of complexity derives from the diversity of the regulated-air carriers, airmen, repair stations, training institutions, etc.; fixed wing, rotorcraft, powerplants, airframes, and avionics; large/complex, small/simple; operating or located in incredibly diverse environment/locations; etc. The operational circumstances of these certificate holders and the associated regulations require exquisite judgment to assure equivalent compliance by a huge company like United Continental and a Mom-and-Pop air taxi operation in Alaska.”
[Continue reading: Can FAA RCCB Bring Consistency In FAR Interpretation To The REAL WORLD?]
FAA’s Regulatory Consistency Communication Board
Learned folks like Emerson, W.E.B. DuBois, Wilde, Huxley, Senator Chaffee and Ramadan have eloquently expressed thoughts on consistency—its value, its derivation, its consequences, its creation and its relative merit. Constitutional experts, Canonical lawyers, the most exalted tafsir of the Quran and Talmudic Scholars, to name a few, who are recognized for their ability to parse important words would likely be befuddled by trying to synthesize the meaning of the above 6 quotes.
ARSA issued a press release, entitled “FAA Consistency Board May Rein In Regulatory ‘Wild West’”, announcing the early actions of the Regulatory Consistency Communication Board. ARSA, almost single-handedly, convinced the FAA to establish the Consistency of Regulatory Interpretation Aviation Rulemaking Committee and that ARC was the aegis for the RCCB.
Consistency is something which the aviation has sought for years from the FAA. In fact, in response, to industry concerns and a Congressional mandate, the Administrator and Aviation Safety have been working to incorporate that concept within the agency’s culture particularly as it applies to the interpretation and application of the FARs. That is an immense challenge and many have doubted whether it could be done effectively.
The FAA faces a very difficult challenge. It must apply, on a consistent basis, a statute with many undefined terms and over 1,000 pages of the Code Federal Regulations, which are amended periodically.
The FAA organization, charged with enforcing the statutes and rules, starts with a single Associate Administrator, follows a pyramidal organization down through a large headquarters organization through layers of regional offices down through FSDOs, ACOs, MIDOs, CHDOs and a host of other field offices and hits the geographically dispersed front line of principals, inspectors and a host of individuals “empowered” to interpret the rules.
Add to that mix, hundreds of thousands of handbooks, orders, ADs, ACs and many, many formal/informal documents.
An added level of complexity derives from the diversity of the regulated-air carriers, airmen, repair stations, training institutions, etc.; fixed wing, rotorcraft, powerplants, airframes, and avionics; large/complex, small/simple; operating or located in incredibly diverse environment/locations; etc. The operational circumstances of these certificate holders and the associated regulations require exquisite judgment to assure equivalent compliance by a huge company like United Continental and a Mom-and-Pop air taxi operation in Alaska.”
[Continue reading: Can FAA RCCB Bring Consistency In FAR Interpretation To The REAL WORLD?]
10-06-2016, 05:49 PM
#2
Gets Weekends Off
Joined APC: Oct 2008
Position: JAFO- First Observer
Posts: 997
Ok, I'll nibble on the hook a little bit...
1. Never heard of the RCCB. If it is real, I guess I missed that Memo.
2. Have heard that the Regions in the graphic will be gone within a year. Complete realignment....
3. Also heard that the new "compliance philosophy" is in full swing and is being closely monitored internally for consistent application. It's never been a better time to make a mistake and learn from it without fear of punitive actions.
1. Never heard of the RCCB. If it is real, I guess I missed that Memo.
2. Have heard that the Regions in the graphic will be gone within a year. Complete realignment....
3. Also heard that the new "compliance philosophy" is in full swing and is being closely monitored internally for consistent application. It's never been a better time to make a mistake and learn from it without fear of punitive actions.
Thread
Thread Starter
Forum
Replies
Last Post
