EAA Government Advocacy
Key Issues; Key People
High-Ranking FAA officials visited Oshkosh in February for the EAA/FAA 2011 Recreational Aviation Summit, an annual meeting to address issues of importance for GA pilots and aircraft owners. Leading this year’s FAA delegation were John Allen, director of FAA Flight Standards Service; Dorenda Baker, director of Aircraft Certification; and Tony Fazio, director of Accident Investigation and Prevention. The General Aviation and Commercial Division, Small Airplane Directorate, GA Maintenance Branch, Regulatory Support Division, and Airworthiness Certification Branch were also represented.
Discussions focused on the following issues:
Among FAA’s top priorities is a desire to improve the amateur-built aircraft accident rate. EAA has committed to step up its safety activities and is already re-energizing the highly successful Flight Advisor and Technical Counselor programs targeting known causal factors leading to accidents. EAA is a member of the FAA’s General Aviation Joint Steering Committee working to ensure that non-regulatory safety interventions are well-targeted and data-driven.
New FAA policies governing warbird operations impose operational and airworthiness burdens on this community. EAA Warbirds of America and a consortium of warbird organizations have been working with the FAA to identify and mitigate the impact of these new requirements. FAA is exploring how to potentially delay the April 16 implementation while dialogue continues.
EAA continues to remedy issues with the sport pilot and light-sport aircraft rules as they are identified, such as the crediting of dual instruction from a sport pilot instructor toward higher certificates and ratings. The FAA also is examining LSA manufacturers closely for compliance and identifying where certification and quality standards need enhancing.
E-LSA FLIGHT TRAINING
The long-awaited guidance for E-LSA flight training was released by the FAA late last year, but it failed to allow primary training in low-mass/high-drag E-LSA or gyroplanes. To grow these segments of aviation, an adequate training fleet is essential. That fleet has yet to materialize in the special light-sport aircraft market, necessitating that previously exempted E-LSA for flight training be allowed to continue.
EAA requested a briefing on the FAA’s vision for NextGen as it relates to and impacts GA. EAA is concerned about potential significant mandatory equipment costs and whether such equipment would result in improved airspace access, information services in the cockpit, or safety over that provided by today’s equipment.
SAFETY MANAGEMENT SYSTEM (SMS)
SMS is a systemic approach to safety being implemented for air carriers, airports, and manufacturers. While the agency is currently focused on these larger organizations, EAA is concerned with the FAA’s vision for SMS as it applies to GA. The FAA has no near-term plans to implement SMS for small GA businesses, but it would like GA to adopt some of the concepts in the future. EAA is submitting comments to the air carrier SMS notice of proposed rulemaking because it contains requirements that could form the framework for a future GA SMS program.
TRANSITION TO AN UNLEADED AVIATION FUEL
With the FAA’s formation of the Unleaded Avgas Transition Aviation Rulemaking Committee to advise the agency on moving toward an unleaded piston aviation fuel specification, the agency has demonstrated a higher level of commitment to the unleaded fuels issue. EAA urged the FAA to ensure the continued regulatory availability of 100LL avgas until a suitable and safe alternative is developed and approved for the existing GA fleet of piston aircraft.
AIRWORTHINESS DIRECTIVES AND EXPERIMENTAL AIRCRAFT
For decades it has been understood that airworthiness directives (ADs) do not apply to experimental amateur-built aircraft or to type-certificated products, such as engines and propellers, installed on them. Despite this, some legal interpretations in recent years have claimed otherwise. EAA seeks clarification that ADs do not apply to experimental aircraft, while acknowledging that owners are required to address any known unsafe condition identified by an AD.
The FAA received more than 900 comments expressing concern about proposed changes to the A&P-IA renewal policy. The FAA reaffirmed it did not intend to change how A&P mechanics with inspection authorization renew their privileges, add new burdens, or put people out of business. Nor was the traditional view of “actively engaged” intended to be altered; rather, this change was an attempt to clarify the requirements. The FAA recognizes and supports the need for part-time A&P-IA mechanics and the unique expertise they bring to aviation safety.
Homebuilding: Growth and Challenges
EAA recently issued its annual report to homebuilders covering the current status of the community, its growth, and, most importantly, safety.
The amateur-built fleet has shown the most consistent growth of any aircraft category in the United States over the past 20 years, with new homebuilts outpacing production aircraft in 2010. The total number of homebuilt aircraft certificated in the United States now exceeds 32,000, more than double of what it was 20 years ago.
The hours flown by amateur-built aircraft increased from 482,000 per year in 1995 to 983,000 in 2010, representing an increase of 104 percent. In that same period, the number of fatal accidents rose 5 percent, from 64 to 67.
The use of EAA’s technical counselors, the standardization of aircraft kits, and builder experience have greatly increased the quality of the aircraft; however, the majority of accidents remain pilot-related. Builders must keep their flying skills proficient during the building phase, understand that each homebuilt model has unique flying characteristics, and seek transition training before beginning a flight-test program.
The AOPA Air Safety Institute (ASI) also released its annual Nall Report covering accident trends and factors. In the section on amateur-built aircraft the report stated that “experimental LSAs accounted for almost 15 percent of all time flown by amateur-built aircraft.” EAA strongly encouraged the ASI not to include the accidents and hours flown by E-LSA in the amateur-built fleet because it does not accurately reflect homebuilt aircraft totals. We continue to with work with AOPA, the FAA, and the General Aviation Joint Steering Committee to come to a common understanding regarding how to account for amateur-built safety data.
Teamwork: A Benefit for Both EAA and FAA
Our Aviation Freedomes are truly privileges. Simply look at the state of other countries’ civil aviation systems, and you realize how favorable our aviation environment is in the United States. It is a future we all must be vigilant in tending.
One of EAA’s jobs is to continuously preserve our privileges, seeking new opportunities for participation while embracing and promoting improvements that enhance safety. Nobody wants friends or colleagues to be harmed, and every serious accident moves us closer to onerous new regulations and a shaken public perception of recreational aviation as a safe and legitimate pursuit. Staking out and protecting our turf, while helping to shape safety improvements, is certainly in the best interest of all.
The FAA recently unveiled a revitalized General Aviation Joint Steering Committee (GA-JSC) that will allow EAA to achieve a new level of collaboration on safety matters. There are many avenues to the conduct of advocacy; in EAA’s experience, the best path is one of collaboration.
This GA-JSC will partner with industry in developing policy and guidance for improving general aviation safety. It is a proven model that recognizes the need for input from subject matter experts and follows a process, driven by data, for achieving outputs. Earlier this year, EAA attended the first meeting of this new GA-JSC where this strategy was outlined. After participating in the discussions, I am excited about the new approach. EAA, along with a number of other aviation associations, is on board and ready to work as a team with the agency. We all want to ensure and improve safety without creating new barriers and burdens.
Read more about out what else is happening in the world of EAA's government relations.
EAA's Government Relations department works to preserve the freedom of flight and reduce the regulatory barriers affecting affordability and access to EAA members’ participation in aviation. Protecting the freedom to fly is the foundation on which all of the organization’s advocacy initiatives are built. EAA fights to preserve this freedom by providing clear solutions and practical alternatives backed by hard work and dedication. EAA’s 55-year history of success is a testament to that philosophy.