Around November 2014, the Southern Region of the FAA implemented a Pilot Program aimed at improving RVSM application processing. The program was implemented under the oversight of the Orlando, FL CMO (Certificate Management Office) and affected two FSDO’s (Flight Standards District Office) Tampa, FL or Birmingham, AL. The program allows an RVSM Application to be sent electronically to a Data Input individual. Once entered into the database a Avionics Inspector, (from Orlando CMO) working from his home in Pensacola, FL to address the Avionics portion, an Airworthiness Inspector to review the and approve the maintenance program and an Operations Inspector, (both of which are based in other locations throughout the Southern Region of the FAA) to address their particular portions. On the surface I was excited however, this has quickly changed with the Applications we have submitted. Now I must admit, if the program was fully implemented I would strongly consider filing a formal complaint under the authority of 14 CFR Part 13.5.
Let me explain. Due to the cyber attacks against the FAA recently, transmission of electronic application’s and the associated required attachments are limited to a maximum 5MB. This means that to submit a full application may take 5 to 15 emails to ensure you submit all of the required data. A bit time consuming but I must admit, much more timely then submitting paper copies. My real issue comes from the very same problems we have been experiencing lately. Inspector’s demanding changes or additions outside the guidance material. For example, the maintenance program submitted by our organization includes the textual description of the RVSM Critical Region as required by the guidance material. The Avionics Inspector would not accept the submission unless it also included a graphical picture of the RVSM Critical Region. Obviously, clearly outside the guidance material and only his opinion that it was needed. Opinions have been addressed within FAA Order 8900.1, Volume 1, which is clear. FAA Inspectors are not allowed to have an opinion other then the issue of compliance in accordance with the regulations and guidance material. The next problem under this program was even more frustrating. After leaving several messages at the Orlando CMO, I finally spoke to the Assistant manager and was informed that the Orlando CMO Supervisor was actually based in Birmingham. Again, leaving multiple messages for him has yet to return any phone calls or answers. I guess he is too busy as well, a pretty standard answer from the FAA lately and oh, by the way, also addressed within the 8900.1, Volume 1, which states the workload and staffing levels of the FAA are not the problem of its customers, (formerly stakeholders) and therefore should not affect the approval process but it obviously does.
Once again, a great idea, mis-managed and fouled up by the government agency do to a lack of accountability and management. Recently the FAA issued a Notice of Proposed Rule Making, (NPRM) removing the requirement of the FAA to approve RVSM Maintenance Programs. Again, I agree with this since the maintenance programs have already been reviewed and accepted by the Aircraft Certification Office, but at least we have a formal structure that when not followed by the FAA we have a little weight to deal with known as CSI and formal complaint 13.5 procedures. What happens when we reduce the structured review process with inspectors who can’t even follow the guidance they have already?