Managing and Enhancing Your FSDO Relationship
Or "How to Stop Worrying and Love the Feds"
October 30, 2006
By Dave Hewitt, NetJets, Inc.
Everyone has their favorite FAA story, and a few of them are even true. Statements like “You can’t believe what they made me do…” or “He
told me he would shut us down unless…” are almost as widespread in aviation lore as our favorite pilot story lead-in “There I was….” But,
as a certificate holder, you have to stay safe, compliant, and make enough money to stay in business. Are those goals mutually exclusive? Can
sanity be maintained in the world of a highly regulated business? I think so, but first, let’s take a walk in the shoes of an FAA General
Aviation Safety Inspector.
Life on the Inside
Contrary to popular opinion, it is quite an involved process to become an FAA Aviation Safety Inspector (ASI). This is what your beloved Principal
Operations/Maintenance/Avionics Inspector is named in official FAA parlance. In most cases, the individual who desires to become an ASI will have
significant aviation experience in their chosen field. For example, an ASI-Operations will likely have a great deal of piloting and/or management
experience in Part 121 or Part 135 operations. As you might expect, just applying for an ASI position involves federal paperwork of biblical proportions – which
I suspect is part of the culling process. After the paperwork is submitted, the federal wheels grind away for some period of time (measured in
epochs) while the applicant waits to hear of his or her future. If found worthy, the applicant then interviews with the hiring FSDO. This
is typically a panel interview with other Inspectors. If an operations applicant, he or she can also look forward to a pseudo check ride in which
piloting skills are evaluated. After all this is completed, the wheels grind again and if successful, the applicant receives a call from the FAA
congratulating them on their acceptance.
After reporting to the hiring FSDO, training begins with the assignment of a “mentor” who guides you through the OJT (on the job training)
process. In addition, you are scheduled for attendance at the FAA Academy in Oklahoma City, OK. The training at the FAA Academy varies from
poor to quite good depending on the course and the instructors assigned. The purpose is to give all Inspectors a common background of information
and each inspector will spend approximately three months at the Academy attending courses. Operations Inspectors will also take flight standardization
courses in both single and multi-engine airplanes to teach them how to assess performance to FAA standards. After completion of Academy and OJT
training, the ASI is now eligible for assignment as a Principal Inspector in his or her specialty.
The workload of a general aviation ASI is quite varied and some insight here will help you understand why it sometimes takes forever to get a piece
of paper through the FSDO. First of all, when an ASI is assigned as your Principal Inspector, it is likely that they are also the principal of
several other certificates or regulated entities. For example, a Principal Operations Inspector (POI) may be the principal for seven Part 135 certificate
holders, 2 Part 141 flight schools, and oversee eight designated pilot examiners. In addition, a POI may be conducting pilot reexamination checks,
checks on pilots with medical status issues, and last but not least, they are required to fly a certain number of hours per quarter to maintain currency. Oh,
I forgot to mention, that if they become aware of a violation, they must prepare and file an enforcement investigation report and jump through all the
hoops with FAA legal to ensure that the bad guys really do get caught (yes, there really are bad guys out there). And, your Inspector will also
be responsible for investigating some of the accidents and incidents that occur within the jurisdiction of the FSDO. All this must usually be accomplished
in an eight hour workday, since government employees are quite limited on the amount of overtime they can work.
Making Life Easier
So, now that you know a little about life on the inside, what can you do to get the best service from your Principal Inspector and FSDO? Here’s
the top ten list on how to accomplish that feat:
- Know your stuff. Anything you submit to your principal should be in final form, meet all regulatory requirements and applicable guidance material,
and be organized in a manner that will make it easy to accept or approve. The last thing you or your principal need is the inevitable “ping-pong” match
of sending stuff back and forth. Remember, every time you have to resubmit something, it will likely end up on the bottom of the principal’s
pile of work. (They will get to it right after giving someone a light gun test for color blindness!)
- Get involved with industry groups. This is the number one thing you can do to “see it coming”. Ever found out at the last
minute that some new requirement goes into effect tomorrow? Well, whose fault is that? Get involved and learn how rules and guidance materials
are developed and guess what, if you do, you will probably get to help the FAA develop them – which is a win / win for everyone!
- Do most of the work first. Handy hint: if what you are asking your principal to accept or approve is based on certain guidance material, send
copies of the material with your submission. That saves them from having to research the issue and makes it more likely that your requests will
gravitate to the top of the pile.
- Really know you stuff – really.
- Take the time to get to know the FSDO supervisors and the office manager. This is a good thing and will help you gain perspective. Invite
them to tour your facility, or just have them over for a briefing on your business and the challenges you face.
- Be prepared. You are a professional in a highly regulated business. You should know more about your business than anyone. Know
your stuff (yes, again) and be willing to explain the intricacies of your business in a non-confrontational manner.
- Always treat FAA personnel with dignity and respect. It really goes back to kindergarten, doesn’t it? If you don’t do this,
you can count on your stuff being buried in the bottom of the stack for millennia.
- Don’t be afraid. OK, there may come a time when you will have a “difference in interpretation” with your principal, FSDO,
or other FAA person. First, review items 1 through 7 above. If you know your stuff and really do differ in your interpretation, make sure
you have all the facts, you have all the regulatory and guidance material regarding the issue (not just the portions that support your position-nice
try!), and ask to have a rational meeting. Don’t get excited or confrontational (review items 1 through 7 above) but make your point. This
is where taking the time to know the FSDO management may come in handy. If you can’t resolve the issue with the principal, calmly ask to
meet with the supervisor and/or office manager, ALONG WITH YOUR PRINCIPAL, and try to reach a workable solution. If that does not work, you can
appeal to the FAA regional office or Washington headquarters, which leads us to….
- Use the resources available from NBAA and others. They have connections you may not have and they will help you to know your stuff. (It’s
a common theme, isn’t it?)
- In the end, it’s all about relationships. While there are some FAA Inspectors out there who are immortalized with those wonderful horror
stories, the vast majority are just hard working, overloaded people trying to get everything done they have to get done that day – just like
you. A little understanding and investment of time on your part will go a long, long way.
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