ARC Committee Report to FAA Encourages Standardization Through Consolidation

A government-industry rulemaking committee responsible for making recommendations to address the lack of consistency in regulatory interpretations issued its final report to the Federal Aviation Administration (FAA).

In late April, the FAA established the Consistency of Regulatory Interpretation (CRI) Aviation Rulemaking Committee (ARC), as directed by Congress, to review the October 2010 report by the Government Accountability Office on certification and approval processes (GAO-11-14) and to establish root causes and recommendations to address the issue.
 
The ARC concluded that the agency’s Aviation Safety organization, specifically, the FAA’s Flight Standards Service and Aircraft Certification Service should review all guidance documents and interpretations, identify and cancel outdated material and cross-reference (electronically link) material to the applicable rule.  Further, the ARC recommends the FAA expand its current Aviation Safety Information Management System initiative to consolidate the service organization-level libraries into a single AVS master electronic resource, organized by rule, to allow users access to relevant rules and all active and superseded guidance material and related documents.

 
“During the Committee’s exhaustive review, it was clear from the beginning that standardization cannot be achieved unless the FAA and industry are singing off the same sheet of music,” stated National Air Transport Association Vice President of Government & Industry Affairs Eric R. Byer, Industry Chair for the ARC.
 
Aeronautical Repair Station Association Executive Director Sarah MacLeod, a member of the ARC, concurred, “Consolidation of all guidance documents and interpretations, organized by rule and housed in one electronic database is the linchpin to success in resolving the lack of standardization with regulatory interpretations and making the FAA’s rules more accessible and easier for the public to understand.”
 
The report addresses several other issues that are predicated on the successful development of one master electronic database including the creation of a Regulatory Consistency Communications Board (RCCB) that would provide clarification to FAA personnel and certificate/approval holders and applicants on questions related to the application of regulations.
 
The ARC’s recommendations now head to the FAA for review and transmission to Congress in early 2013. The report is available at: http://arsa.org/wp-content/uploads/2012/11/ARC-313-Final-Report-112812-Submitted-to-FAA.pdf.
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