Aviation is part of the federal critical infrastructure as defined by the United States Government’s Cybersecurity and Infrastructure Security Agency (CISA). This means that the FAA needs to ensure that aviation can continue to function, while performing its own safety oversight and also protecting the health of its own employees. This is a pretty tall order, but the FAA is up to the challenge.
Ali Bahrami hosted a teleconference yesterday afternoon and invited industry leaders to discuss the FAA’s ongoing work to support aviation safety during the Covid-19 crisis. Bahrami is the FAA’s Associate Administrator for Aviation Safety but he used to be with AIA so he understands the industry perspective, and the importance of transparency in government. He was also the head of the FAA’s Transport Directorate so he very familiar with PMA and certification issues.
Bahrami expects the current health situation to impact the FAA for about 60-90 days, and the FAA has been planning accordingly. The FAA expects to issue new policy statements and extensions in order to facilitate aviation business while maintaining aviation safety. They expect the first of the new guidance documents to be released by the end of this week.
Risk-Based Approach
Last week and this week the FAA has been working on using a risk-based approach to identify and categorize the tasks the FAA performs. The FAA has used this approach to distinguish which tasks can be delayed and which ones must be accomplished as planned in order to preserve the expected level of safety. Among those that must be performed as planned, they are investigating how best to ensure health and safety when they perform the tasks. Some examples include:
- The FAA is publishing guidance on how technologies can be used to perform remote oversight during the Covid-19 crisis;
- Expiring class one medical certificates will be extended for 90 days so that holders will not have to visit aviation medical examiners during the Covid-19 crisis;
- The FAA is investigating ways to mitigate the health dangers of Covid-19 in confined spaces, like health risks to to inspectors, trainers and students in simulators;
The FAA has been coordinating its plans with the International Civil Aviation Organization (ICAO) in order to help ensure that the FAA’s practices are consistent with those of the rest of the world, and will not adversely affect acceptance of US aviation products in the rest of the world.
FAA Aircraft Certification Service
Earl Lawrence is the Executive Director of the FAA’s Aircraft Certification Service. He’s also a former trade association guy and an old friend – having worked for EAA for many years. Lawrence joined the call to talk about FAA oversight of design and production.
ODA, DER and Other Designee Extensions and Privileges
Lawrence understands the importance of the designee community to our industry. The FAA is already working on the guidance to ensure uninterrupted designee coverage. New guidance for the Covid-19 crisis will be modeled on the approach that the FAA adopted during the last government shutdown.
During the last government shutdown, we worked with Lawrence on protocols for extending designees’ recurrent training and extension requirements. Under those protocols, those who needed training during the shutdown would be able to wait and get the training after the shutdown; and those whose authority expired during the shutdown would be permitted to operate until after the end of the shutdown (the guidance included a window of time after the shutdown, because of the recognition that the FAA would not be able to process everything immediately, after the shutdown ended). Lawrence told us that this is the model for the current guidance being developed for treatment of designee renewal and training during the Covid-19 crisis.
The new designee guidance is being developed jointly with the Flight Standards Service to make sure that all Flight Standards designees are covered, too. He expects it to be issued next week.
Remote Oversight and Designee Activity
Lawrence explained that his office is also working on how best to use technology during Covid-19 to accomplish their oversight goals. In fact, his office is working on two pieces of guidance:
- Deviation authority to permit use of remote technologies to carry out FAA oversight responsibilities; and
- Deviation authority to permit use of technology to accomplish testing, oversight, witnessing and approval in FAA projects (targeted as a deviation from FAA Order 8000.95).
Lawrence expects both of these documents to be in draft form for his review by today, and hopes to have them issued by early next week.
FAA is Still at Work
Bahrami highlighted that one big difference between the shutdown and the current situation is that the FAA is still working – albeit many of them are teleworking from home (Bahrami is working from his apartment). This means that he has the personnel to get the job done – he just needs to issue guidance to give them permission to do the job in a way that makes sense during the a Covid-19 crisis.
The FAA has internal procedures for telework that are covered by their information security guidance. FAA employees typically have access to their email accounts, and many of them are still reachable on their cell phones.. If you are having trouble communicating with your FAA contacts, then (1) be patient – they are answering a lot of questions right now, (2) if you’ve been patient but still received no response then reach out to the FAA local office management to make sure your contact is OK, and to obtain a new FAA contact if your old contact is no longer able to support your needs, and (3) if you still cannot get a response, then contact the trade association so we can work with you and the FAA to ensure that the FAA remains open for business.
Lawrence noted that many companies are shutting down their certification projects for now. This means that ACO engineers may be less busy than normal. Many PMA companies have small engineering departments that can work from home, so this could be an ideal time to continue working on PMA approvals and get them through the FAA. Airlines are experience severe economic distress, so PMAs that offer price competition and reliability improvements would be especially appreciated by the air carrier community!
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