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E. Top TPC Issues

E. Top TPC Issues

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E. Top TPC Issues

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  1. E. Top TPC Issues

  2. GAMA Priorities “Top 3” • ODA Improvement and Implementation • Stronger measurement of performance - metrics to measure whether intent is being realized • Help push accountability with FAA • Better understanding of FAA employee union impact on implementation of ODA – change mgmt • Get the most out of it/refine it for a stable platform prior to next quantum leap being defined by ARC 21/SMS • must ensure value and step forward if going to DO and need cost-benefit-analysis for small to medium companies considering DO • Shift from Conformity to Configuration Management • Reduce burden of non-value added FAA legacy system • Update/modernize way to accomplish conformity intent

  3. GAMA Priorities “Top 3” cont. • Accountability Framework – FAA Discretion • Better support for concepts to allow showing only compliance for things which are simple or commonly performed without issue • Consistency of Regulatory Interpretation • Employee behavior and culture has huge negative resource and cost impact on both FAA and Industry • ARC 313 – define implementation plan & vetting it between AIR-AFS-industry • Help push accountability with the FAA • AIR policy currently in place – being monitored/enforced?

  4. GAMA Priorities “Top 3” cont. • Foreign Validation Efforts and Fees • Ensure Full Utilization and Effectiveness of Agreement/TVP • Unleaded Avgas Replacement • Leadership and proactive support form FAA • CPR – Stabilization, Clarity and Consistency • CPR is out of control and needs to be brought back in • Too many unknowns/unpredictability for future programs • Help drive industry position to FAA and gather backing & harmonization from other regulatory agencies on behalf of industry • FAA GAMA coordination/communication • need to have AFS at the table and part of our cert solutions

  5. FAA/AIR Priorities “Top 3” • Full Utilization and Implementation of ODA • Proactive change management • Leadership must continue to drive cultural change throughout the ACO toward full utilization of ODA and systems oversight • Full unencumbered implementation of ODA responsibility per the regulation and Order • Acceptance and activation of pending ODA applications • FAAs resource problems • Sequencing projects • Should not be the way of doing business in the FAA • ACO Certification Project Activity Performance • Establish and monitor turn time metrics (i.e. cert plan approval, issue paper response, ICA review, etc) • Reduction in STC and MRA project PNL response time • AEG last minute evaluations • Implement SOP for resource prioritization • Identify opportunities for improvement

  6. FAA/AIR Priorities “Top 3” cont • Reorganization and Restructuring of FAA • Manner that fits within their long term budget projections • Fosters efficient internal processes, inter-agency coordination • Renewed purpose and culture for their workforce How can industry encourage and support such a dramatic but sorely needed change???

  7. FAA/AIR Priorities “Top 3” cont. • Harmonize oversight of Inspection UMs to avoid in person oversight • Why cant a DAR oversight by FAA be utilized in Lieu of an On-scene oversight inspection when backed by tele interviews and paper? • The education of FAA ACO/SAD staff on the practical implications of each STC amendment and application • Many problems are created by the FAA’s lack of practical knowledge regarding how the STC is implemented and what it affects on the existing approved design

  8. FAA/AIR Priorities “Top 3” cont. • ARC 312 implementation plan • Update implementation status monthly and ensure this top priority within the FAA is successful • Pull ARC back together to pulse and validate FAA’s measures of implementation progress to date • Increased leadership/assistance with international certification projects, especially China and EASA • Bilateral enforcement and following the BMR process • ICA delegation xx.1529 • Major/Minor • see some action on is the major / minor white paper that came from the Part 23 ARC • Benefit from getting an endorsement by FAA policy letter

  9. FAA/AIR Priorities “Top 3” cont. • Edit existing/Develop New Guidance • Guide to applicants in form of SAE or RTCA guideline to project management based on a WMS system (see MIL-STD-881) • Small company design organization manual (23ARC Rec) • Revised policy and decision on rulemaking for EME/structural lightening protection • Complete this activity per the Part 25.981 ARC recommendations • SC 216 and Security Policy including proposed special conditions.  • Scope of the issue needs GA viewpoint. The SC anticipates one process that fits all – not realistic- risks to low end GA are small and not commensurate with cost and effort proposed. • Non-TSO definition is all over the map in both guidance and policy as well as how it applied. Need appropriate consistent application of Non-TSO function at the appliance level and the aircraft level. Further, the “credit” for non-TSO functions at the installation needs to be clarified

  10. FAA/AIR Priorities “Top 3” cont. • Improve Communications • Centralized electronic library for all regulations, preamble, guidance, policy, etc (CRI-ARC Rec) • Use of SharePoint to communicate/submit docs with the FAA