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REVIEW OF FAA’S CERTIFICATION PROCESS: 

ENSURING AN EFFICIENT, EFFECTIVE, AND 

SAFE PROCESS 

(113–40) 

HEARING 

BEFORE THE

SUBCOMMITTEE ON 

AVIATION 

OF THE

COMMITTEE ON 

TRANSPORTATION AND 

INFRASTRUCTURE 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

OCTOBER 30, 2013 

Printed for the use of the 

Committee on Transportation and Infrastructure 

( 

Available online at: http://www.gpo.gov/fdsys/browse/ 

committee.action?chamber=house&committee=transportation 

(II) 

COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE 

BILL SHUSTER, Pennsylvania, Chairman 

DON YOUNG, Alaska 

THOMAS E. PETRI, Wisconsin 

HOWARD COBLE, North Carolina 

JOHN J. DUNCAN, JR., Tennessee, 

Vice Chair 

JOHN L. MICA, Florida 

FRANK A. LOBIONDO, New Jersey 

GARY G. MILLER, California 

SAM GRAVES, Missouri 

SHELLEY MOORE CAPITO, West Virginia 

CANDICE S. MILLER, Michigan 

DUNCAN HUNTER, California 

ERIC A. ‘‘RICK’’ CRAWFORD, Arkansas 

LOU BARLETTA, Pennsylvania 

BLAKE FARENTHOLD, Texas 

LARRY BUCSHON, Indiana 

BOB GIBBS, Ohio 

PATRICK MEEHAN, Pennsylvania 

RICHARD L. HANNA, New York 

DANIEL WEBSTER, Florida 

STEVE SOUTHERLAND, II, Florida 

JEFF DENHAM, California 

REID J. RIBBLE, Wisconsin 

THOMAS MASSIE, Kentucky 

STEVE DAINES, Montana 

TOM RICE, South Carolina 

MARKWAYNE MULLIN, Oklahoma 

ROGER WILLIAMS, Texas 

TREY RADEL, Florida 

MARK MEADOWS, North Carolina 

SCOTT PERRY, Pennsylvania 

RODNEY DAVIS, Illinois 

MARK SANFORD, South Carolina 

NICK J. RAHALL, II, West Virginia 

PETER A. DEFAZIO, Oregon 

ELEANOR HOLMES NORTON, District of 

Columbia 

JERROLD NADLER, New York 

CORRINE BROWN, Florida 

EDDIE BERNICE JOHNSON, Texas 

ELIJAH E. CUMMINGS, Maryland 

RICK LARSEN, Washington 

MICHAEL E. CAPUANO, Massachusetts 

TIMOTHY H. BISHOP, New York 

MICHAEL H. MICHAUD, Maine 

GRACE F. NAPOLITANO, California 

DANIEL LIPINSKI, Illinois 

TIMOTHY J. WALZ, Minnesota 

STEVE COHEN, Tennessee 

ALBIO SIRES, New Jersey 

DONNA F. EDWARDS, Maryland 

JOHN GARAMENDI, California 

ANDRE ́ CARSON, Indiana 

JANICE HAHN, California 

RICHARD M. NOLAN, Minnesota 

ANN KIRKPATRICK, Arizona 

DINA TITUS, Nevada 

SEAN PATRICK MALONEY, New York 

ELIZABETH H. ESTY, Connecticut 

LOIS FRANKEL, Florida 

CHERI BUSTOS, Illinois 

SUBCOMMITTEE ON AVIATION

FRANK A. LOBIONDO, New Jersey, Chairman 

THOMAS E. PETRI, Wisconsin 

HOWARD COBLE, North Carolina 

JOHN J. DUNCAN, JR., Tennessee 

SAM GRAVES, Missouri 

BLAKE FARENTHOLD, Texas 

LARRY BUCSHON, Indiana 

PATRICK MEEHAN, Pennsylvania 

DANIEL WEBSTER, Florida 

JEFF DENHAM, California 

REID J. RIBBLE, Wisconsin 

THOMAS MASSIE, Kentucky 

STEVE DAINES, Montana 

ROGER WILLIAMS, Texas 

TREY RADEL, Florida 

MARK MEADOWS, North Carolina 

RODNEY DAVIS, Illinois, Vice Chair 

BILL SHUSTER, Pennsylvania (Ex Officio) 

RICK LARSEN, Washington 

PETER A. DEFAZIO, Oregon 

EDDIE BERNICE JOHNSON, Texas 

MICHAEL E. CAPUANO, Massachusetts 

DANIEL LIPINSKI, Illinois 

STEVE COHEN, Tennessee 

ANDRE ́ CARSON, Indiana 

RICHARD M. NOLAN, Minnesota 

DINA TITUS, Nevada 

SEAN PATRICK MALONEY, New York 

CHERI BUSTOS, Illinois 

CORRINE BROWN, Florida 

ELIZABETH H. ESTY, Connecticut 

NICK J. RAHALL, II, West Virginia 

(Ex Officio) 

(III) 

CONTENTS Page 

Summary of Subject Matter .................................................................................... iv 

TESTIMONY 

PANEL 1 

Dorenda Baker, Director of the Aircraft Certification Service, Federal Aviation Administration, acccompanied by John S. Duncan, Director of the 

Flight Standards Service, Federal Aviation Administration ............................ 3 

Gerald L. Dillingham, Ph.D., Director, Physical Infrastructure Issues, Government Accountability Office .................................................................................. 3 

Jeffrey B. Guzzetti, Assistant Inspector General for Aviation Audits, U.S. 

Department of Transportation ............................................................................ 3 

PANEL 2 

Peter J. Bunce, President and CEO, General Aviation Manufacturers Association ........................................................................................................................ 19

Thomas L. Hendricks, President and CEO, National Air Transportation Association .................................................................................................................... 19 

Michael Perrone, President, Professional Aviation Safety Specialists, AFL– 

CIO ........................................................................................................................ 19 

Ali Bahrami, Vice President-Civil Aviation, Aerospace Industries Association 

of America ............................................................................................................. 19 

PREPARED STATEMENTS SUBMITTED BY WITNESSES 

Dorenda Baker and John S. Duncan, joint statement .......................................... 36 

Gerald L. Dillingham, Ph.D. ................................................................................... 46 

Jeffrey B. Guzzetti ................................................................................................... 63 

Peter J. Bunce .......................................................................................................... 72 

Thomas L. Hendricks .............................................................................................. 80 

Michael Perrone ....................................................................................................... 85 

Ali Bahrami .............................................................................................................. 95 

SUBMISSION FOR THE RECORD 

Thomas L. Hendricks, President and CEO, National Air Transportation Association, response to request for information from Hon. Mark Meadows, 

a Representative in Congress from the State of North Carolina ..................... 34 

ADDITION TO THE RECORD 

Eric Byer, Vice President of Communications, Policy, and Planning, Aeronautical Repair Station Association, written statement ................................... 103 

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(1) 

REVIEW OF FAA’S CERTIFICATION PROCESS: 

ENSURING AN EFFICIENT, EFFECTIVE, 

AND SAFE PROCESS 

WEDNESDAY, OCTOBER 30, 2013 

HOUSE OF REPRESENTATIVES, 

SUBCOMMITTEE ON AVIATION, 

COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE, 

Washington, DC. 

The subcommittee met pursuant to notice at 10:00 a.m. in Room 

2167, Rayburn House Office Building, the Hon. Frank A. LoBiondo 

(Chairman of the subcommittee) presiding. 

Mr. LOBIONDO. Good morning. The subcommittee will come to 

order. Thank you for being here today. 

Today the subcommittee will hear from the FAA and other expert witnesses on the agency certification process. It is the shared 

goal of everyone in this room to find the right balance between 

maintaining the highest level of aviation safety while achieving 

greater efficiencies in the FAA certification process. As the aviation 

industry develops new products and other innovations, the FAA 

must likewise evolve. Examples of this creative spirit can be found 

throughout the industry. Many companies I have worked with with 

the FAA Tech Center in my district to develop and test new products that improve safety and efficiency of the U.S. aviation system. 

To ensure that the hard work at the Technical Center and elsewhere in the industry, it is not needlessly delayed or wasted altogether, it is critical that the FAA certification processes keep pace. 

The Aviation Subcommittee often hears concerns from companies, 

operators and other certificate holders related to the FAA’s certification processes, and particularly long wait times, inconsistent regulatory interpretations, and redundant or outdated processes have 

all been brought to the subcommittee’s attention. 

In response, Congress included two important provisions in the 

FAA Modernization and Reform Act of 2012 to improve the FAA 

certification process. These provisions require the agency to develop 

plans to streamline their certification processes and address regional regulatory inconsistencies, all while maintaining the highest 

level of safety. In response, the FAA submitted reports to the committee that outlined recommendations to improve and streamline 

certification and address inconsistent regulatory interpretations. 

Today we look forward to hearing what progress the FAA has 

made carrying out these provisions and what recommendations 

they will implement to further ensure certification processes are efVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00011 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
2 

fective and efficient. I look forward to hearing from our witnesses 

and thank them for their participation. 

I ask unanimous consent that all Members have 5 legislative 

days to revise and extend their remarks and include extraneous 

material for the record of this hearing. Without further objection it 

is so ordered. I would like now to yield to Mr. Larsen. 

Mr. LARSEN. Thank you, Chairman LoBiondo, for calling today’s 

hearing to review the FAA certification process. 

Mr. Chairman, the ability of U.S. manufacturers to improve our 

aviation system and compete successfully in the global marketplace 

is tied directly to the FAA’s timely review of new products. The 

public relies on a skilled and dedicated FAA workforce to work 

with industry and ensure that new products and services are safe. 

I certainly see firsthand how important FAA’s certification services are in my State of Washington where aviation manufacturing 

is a significant economic driver. My State is home to over 1,000 

firms in the airspace cluster employing more than 131,000 people; 

in the export industry in my State, aviation accounts for $27 billion 

of a total $64.6 billion in exports. So to ensure that aviation manufacturing continues to play a critical role in our economy, Congress 

must provide adequate resources for FAA certification services. 

Additionally, Congress should encourage FAA to improve the 

streamlining process while maintaining the highest level of safety. 

Therefore, I am pleased that the most recent reauthorization directed the FAA to assess its certification process and address concerns about regulatory interpretation. More specifically, section 312 

of the Act requires FAA conduct an assessment of the aircraft certification and approval process. 

One of the key recommendations that came out of the report contained in the FAA certification report is that the agency would 

more effectively use its existing delegation authority. This authority is not new, because FAA simply does not have the personnel to 

oversee every aspect of aviation certification, though the law allows 

FAA to delegate certain functions to qualified individuals and companies. And today the FAA appoints both individual designees and 

grants approval of organizational designation authorizations or 

ODAs. And, through ODAs, FAA delegates responsibility for selecting individuals to perform routine certification work to aircraft 

manufacturers and other organizations. 

Further, the report notes that if FAA fully utilizes the authority 

to carry out these certifications, the personnel will be free to focus 

on critical areas that present more risk. So in theory this makes 

sense, and I support the idea of streamlining the certification process as long as it can be done safely. 

But safety can’t take a back seat to efficiency. And the GAO reports that upwards of 90 percent of FAA’s certification activities 

were performed by designees. Therefore, FAA personnel must have 

tools and the training to properly assess risk so that they are involved when needed to be and are prepared to step up their involvement and certification activity when warranted. And when 

certain certification activities present greater risk or involve new 

technologies, the FAA must possess the technical expertise or readily obtain outside expertise so it can work with industry to address 

safety issues. 

3 

And in 2011 the DOT inspector general reported the FAA needed 

to strengthen its risk assessment analysis capability with respect 

to ODA, so the FAA personnel could better identify safety-critical 

certification issues. And so I look forward to hearing from the IG 

about what steps, if any of the FAA, has taken to strengthen—the 

opinion that the FAA has taken to strengthen its risk-based targeting program since the 2011 report. 

And, likewise, earlier this year the GAO raised concerns that 

FAA staff have not been able to keep pace with industry changes 

and thus may struggle to understand the aircraft or equipment 

they are tasked to certificate. So I would like to hear from Dr. 

Dillingham whether he believes this is a major concern and what 

steps the FAA can take or is taking to address this concern. 

Now, Mr. Chairman, in 2010 the GAO reported the FAA is inconsistent in interpretation of its own certification and approval regulations, has resulted in delays and higher costs for industry, and 

this could lead to jurisdiction shopping or unfair standards for different manufacturers, depending on where they are located. For 

this reason, section 313 of the FAA authorization directed the FAA 

to be in an advisory panel to determine the root causes of inconsistent, regulatory interpretation by FAA personnel. This July, the 

panel issued its report to Congress, but the FAA has not yet drafted a plan to implement the panel’s recommendations. 

Many of the recommendations make sense, centering on improving training for FAA personnel and improving communication between FAA and industry. For example, the panel recommended 

that the FAA develop a consolidated master database for regulatory policy and guidance for commercial aviation. So I look forward to hearing the FAA’s reaction to this and to other panel recommendations. 

With that, Mr. Chairman, thank you for holding a hearing. I look 

forward to hearing from our witnesses. 

Mr. LOBIONDO. Thank you very much, Mr. Larsen. 

I would now like to recognize our first witness of the day, FAA 

Director of the Aircraft Certification Service, Ms. Dorenda Baker, 

who is accompanied by Mr. John Duncan, the Director of the Flight 

Standards Service. You are now recognized. 

Thank you. 

TESTIMONY OF DORENDA BAKER, DIRECTOR OF THE AIRCRAFT CERTIFICATION SERVICE, FEDERAL AVIATION ADMINISTRATION, ACCOMPANIED BY JOHN S. DUNCAN, DIRECTOR OF THE FLIGHT STANDARDS SERVICE, FEDERAL AVIATION ADMINISTRATION; GERALD L. DILLINGHAM, PH.D., DIRECTOR, PHYSICAL INFRASTRUCTURE ISSUES, GOVERNMENT ACCOUNTABILITY OFFICE; AND JEFFREY B. 

GUZZETTI, ASSISTANT INSPECTOR GENERAL FOR AVIATION 

AUDITS, U.S. DEPARTMENT OF TRANSPORTATION 

Ms. BAKER. Thank you. 

Chairman LoBiondo, Congressman Larsen, members of the subcommittee, thank you for inviting us to appear before you today on 

behalf of the Federal Aviation Administration. 

I am Dorenda Baker, director of the Aircraft Certification Service. With me is John Duncan, the director of the Flight Standards 

4 

Service. Today is the first time John and I are appearing before the 

subcommittee and we hope that the information we provide will assist you in your oversight responsibilities. 

Between the Aircraft Certification Service and the Flight Standards Service, we oversee the life cycle of an aircraft, from design 

and production of new aircraft, to maintenance, modification and 

repair of aircraft as they age. We also oversee the pilots, flight attendants, mechanics, airlines and flight schools who fly and maintain them. Throughout the life cycle, our priority is to ensure the 

continued operational safety of the civil aviation fleet. 

As the aviation industry grows in response to the global demand, 

each new aircraft and operator increases the FAA’s oversight responsibility. While we have been successful at using the tools that 

Congress has given us, such as delegation to leverage our resources, it is incumbent upon us to further improve our processes 

to make them as efficient and effective as possible and maintain 

the high standards of safety that the public expects. 

Last year Congress passed the FAA Modernization Reform Act of 

2012. Sections 312 and 313 of the Act require the FAA to work 

with industry representatives to review and improve the FAA aircraft certification process, and standardize FAA’s regulatory interpretations. In response to section 312, the FAA collaborated with 

industry representatives on six recommendations to streamline and 

reengineer the certification processes. The FAA concurred with the 

intent of all of the recommendations and developed an implementation plan that mapped the recommendations to 14 agency initiatives. Since the original release of the implementation plan in January of 2013, the FAA has made progress on all of the initiatives. 

To keep ourselves accountable and promote transparency, we periodically post the updates on the FAA Web site. Our most recent 

update was posted in July and we plan to post the next update this 

coming January. Some examples of our progress include the approval of the Part 23 Rulemaking Project, issuance of the revised 

order on Organization Designation Authorization, or ODA, initiation of a 2-year pilot program for delegation of noise findings, the 

kick-off of the Part 21 Aviation Rulemaking Committee, and a revision to the Aircraft Certification Sequencing process. 

In response to section 313, the FAA reviewed and accepted an 

Aviation Rulemaking Committee’s six recommendations to improve 

upon consistency and regulatory interpretation by offices within 

AIR and AFS, as well as between our two organizations. It is clear 

that long-term planning and cultural change is essential to make 

the improvements sought by industry. In order to address the recommendations as soon as practical, the FAA’s plan for section 313 

identifies near, mid and long-term priorities related to each recommendation. 

The primary focus area identified by industry was a standardized 

methodology, whereby all FAA guidance documents, including legal 

interpretations affecting compliance with the regulations are linked 

to the respective regulation. The FAA is currently reviewing existing data systems to determine how best to achieve this goal. As one 

of the near-term strategies, we are identifying existing guidance 

documents used by FAA personnel that are not catalogued in one 

of our electronic databases. 

5 

We expect to identify all such documents and establish a protocol 

to determine if such documents are still applicable, in which case 

they will be integrated into one of our existing electronic systems 

by the end of 2014. As the reports we have submitted in our testimony indicate, the FAA is making progress in addressing the concerns identified in the Act. We understand the importance of the 

recommendations, and are committed to following through with 

their implementation. Our efforts are transparent and are being 

done with the support of industry. The implementation of these improvements provides a path forward for the FAA to meet the ongoing and future demand of a dynamic industry that is crucial to the 

economic interests of all Americans. We look forward to working 

with this industry and the subcommittee to achieve these goals. 

Mr. Chairman, this concludes my statement. Mr. Duncan and I 

will be happy to answer any questions you have at this time. 

Mr. LOBIONDO. Thank you very much, Ms. Baker. 

Our next guest witness is Dr. Gerald Dillingham, director of 

Physical Infrastructure Issues at the Government Accountability 

Office. 

Dr. Dillingham, we thank you for being here. You have been at 

this a number of years. I am trying to remember just how many, 

but I know it is a bunch. 

Dr. DILLINGHAM. Sir, I don’t remember exactly how many times 

myself. 

Mr. LOBIONDO. OK. OK. But we thank you for your expertise 

and welcome your remarks. 

Dr. DILLINGHAM. Good morning, Mr. Chairman, Ranking Member Larsen, members of the subcommittee. 

Thank you for inviting me here today to discuss FAA certification 

processes and inconsistencies in regulatory interpretation. In 2010 

at the request of this committee we conducted a study of these 

issues. Overall, we found that the aviation industry views the certification and approval processes as generally working well and 

making positive contributions to the safety of the National Airspace 

System. 

I happen to know circumstances where there are inefficiencies. It 

can result in costly delays, particularly for smaller operators. We 

made two recommendations to address these inefficiencies. Section 

312 and section 313 of the FAA Reauthorization Act require the 

agency to work with industry to assess the certification processes 

and concerns that have been raised about the inconsistency of regulatory interpretation. My statement today discusses FAA’s response 

to those recommendations that we made in 2010 and the recommendations of two FAA-industry advisory committees regarding 

the certification and approval processes. 

FAA has taken sufficient action on the GAO recommendations 

that allowed us to close them as implemented. The Certification 

Process Committee that was established in accordance with section 

312 developed six recommendations to improve process, efficiency 

and reduce cost. In response, FAA issued a detailed implementation plan earlier this year. The plan identified many initiatives and 

programs that FAA has planned and underway that it believes will 

address the committee’s recommendations. However, FAA’s plan 

lacks performance goals and measures to track the outcomes of 

6 

most of the initiatives. Without these performance goals and measures, FAA will not be able to gather the appropriate data to evaluate current and future initiatives. 

Additionally, FAA’s response does not include an integrated plan 

for achieving the desired future end-state for the certification process. Without this plan, FAA will not have an overall blueprint or 

guide for how or if the individual initiatives fit together to achieve 

the desired outcome of improving the entire certification system. 

Regarding consistency of regulatory interpretation, the Regulatory 

Interpretation Committee that was established in response to section 313 identified several root causes of inconsistent interpretation 

of regulations and made six recommendations to address them. 

The root causes identified by the committee were similar to those 

that we also identified in our 2010 study. According to FAA, an action plan to address the recommendations and metrics to measure 

implementation is a work in progress. The estimated date for completion of the plan is December of this year. We would note again 

that measuring implementation may provide useful information, 

but FAA should also develop outcome measures which can help determine whether the actions undertaken are having their intended 

effect. 

Mr. Chairman, Ranking Member Larsen and members of the 

subcommittee, as I stated earlier, problems in the certification and 

approval processes can cause delays in getting innovations and 

safety improvements into the National Airspace System and have 

significant cost impacts on the industry. With FAA certification 

and approval workload expected to grow in the next 10 years because of the introduction of new aircraft, including unmanned aerial systems, the increasing use of composite materials and aircraft 

and the expected progress of the NextGen initiative, continued 

progress in implementing the committee’s recommendation is even 

more critical. 

To its credit, FAA has taken steps toward improving the efficiency and consistency of the certification and approval processes. 

It will be essential for FAA to follow through with its plans for implementing the committee’s recommendations and to develop measures of effectiveness to evaluate the impact of those initiatives before closing the recommendations. We look forward to supporting 

this committee in its continued oversight to ensure the full implementation of sections 312 and 313 and the achievement of the intended efficiencies and streamlining of the certification and approval processes. 

Thank you, Mr. Chairman. 

Mr. LOBIONDO. Thank you, Doctor. 

We will now turn to Mr. Jeff Guzzetti. 

Mr. Guzzetti, you are recognized for your statement and Mr. 

Guzzetti is the Department of Transportation assistant inspector 

general for aviation audits. 

Mr. GUZZETTI. Mr. Chairman, members of the subcommittee, 

thank you for inviting me to testify on FAA’s certification processes. 

As you know, certification plays an important role in FAA’s efforts to ensure the safety of the National Airspace System. However, our work as well as joint FAA industry reports have identiVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00016 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
7 

fied opportunities for improving the efficiency and effectiveness of 

FAA’s certification process. My statement today will focus on 

vulnerabilities in three areas of FAA certification: Organization 

Designation Authorization, or ODA; new air operators and repair 

stations; and NextGen capabilities, including the integration of unmanned aircraft systems. 

First, ODA: Through ODA, FAA’s Aircraft Certification Service 

delegates certification tasks to aircraft and component manufacturers and other outside companies, making it an important resource 

for managing the industry’s growing certification needs. However, 

our previous work identified vulnerabilities in the ODA program, 

including inconsistencies in how FAA offices interpreted FAA’s role 

in how manufacturers selected the personnel to perform certification tasks. 

In response to our 2011 report and a mandate in the FAA Modernization and Reform Act of 2012, FAA has taken steps to improve 

its oversight of the ODA program. For example, in May of this year 

FAA issued new and more stringent guidance for prescreening staff 

prior to assigning them to an ODA. They established procedures for 

tracking and removing poor performing ODA staff and they improved training for FAA engineers on how to enforce ODA policies. 

As the ODA program continues to grow, effective oversight will remain critical to ensure that all aircraft certification organizations 

are following FAA’s policies and procedures. 

Now, while improvements to ODA oversight are in process, we 

identified shortcomings in another area of FAA’s certification, and 

that is certification of new air operators and repair stations by 

FAA’s Flight Standards Service. Currently, more than a thousand 

aircraft operators and repair stations around the country are 

awaiting certification, 138 of which have been delayed for more 

than 3 years. Several factors contribute to this backlog, including 

the lack of an effective method to prioritize new applicants, the 

lack of a standardized process to initiate new certifications, and 

poor communications regarding FAA’s certification policy. According to FAA officials, budget uncertainties have also contributed to 

these backlogs. Since March 2011, FAA halted certain certification 

activities several times in an effort to maintain oversight of existing operators. 

Finally, it is important to note that a growing demand for certifying NextGen technologies and procedures, as well as unmanned 

aircraft systems, will only add to FAA certification workload and 

further tax its certification staff. For example, FAA has mandated 

that airspace users equip with ADS–B Out avionics by 2020 to provide more accurate satellite-based surveillance data for reduced 

separation between aircraft. 

However, FAA has not certified all of the needed avionics that 

must be installed or developed and certified the procedures for controlling air traffic with ADS–B. Developing and installing these 

avionics may take years, and any certification delays translate into 

further delays with both user equipage and NextGen benefits. 

Another certification challenge along these lines facing FAA is its 

effort to safely integrate unmanned aircraft systems into U.S. airspace, something that could further exacerbate FAA’s certification 

workload. While FAA successfully certified two unmanned aircraft 

8 

for civil use, the agency relied on an older rule addressing military 

aircraft and only authorized flights over water in the Arctic. 

FAA has not yet developed certification standards for novel and 

new civil unmanned aircraft operating over populated areas. A 

wide range of safety related issues regarding unmanned systems 

also remain unresolved, including standards for certifying new systems, crewmembers and ground control stations. Until FAA establishes a regulatory framework and certification standards, unmanned aircraft will continue to operate with significant limitations in the Nation’s airspace. 

Clearly, there is greater industry activity than FAA can support 

through its current certification processes. While continually adapting to meet industry needs is no simple task, strategies for enhancing the management and oversight of FAA’s certification process 

must be developed and implemented, and our office remains committed to oversight that will identify areas needing attention. 

Mr. Chairman, this concludes my prepared statement. I will be 

happy to answer any questions you or other members of the subcommittee may have. 

Mr. LOBIONDO. Thank you very much. 

The FAA’s plans to streamline and ensure consistency of certification processes I think are a good first step. As we move forward, 

what can be done by the FAA industry and Congress to further improve certification and approval processes? For anyone on the panel 

or everyone on the panel. 

Dr. DILLINGHAM. Well, Mr. Chairman, I think if FAA continues 

to implement the recommendations that came from 312 and 313, 

that’s a first step, because part of that means better utilizing some 

of the initiatives and some of the tools that they currently have. 

I think that partnership that was established by the industry FAA 

committee when they did the committee to respond to 312 and 313 

is something that needs to be continued. 

In our work we found that whenever the stakeholders are not included early and continuously, the problem doesn’t go away easily 

and I think congressional oversight, as you are having this hearing 

today, to get to actual implementation, oftentimes there are plans; 

but, sometimes, that implementation falls short. So I think continued oversight is also going to be critical. 

Mr. LOBIONDO. Anyone else? 

Mr. GUZZETTI. Well, I’d like to add that in regards to the flight 

standards service side of the equation, that is, the FSDOs, the inspectors that review applicants for repair stations, and for aircraft 

operators, such as crop dusters, there’s quite a big backlog, over a 

thousand as I indicated in my testimony. About a quarter of those 

applications, about 251 of those thousand, are older than 2 years 

old. It’s a big workload and FAA only has a certain number of resources. But, perhaps they can move away from their philosophy of 

first come, first served, when these applicants come in. There could 

be a better way to triage these applications to look at complex operations versus simple operations and get more of the applications 

rolling. A different philosophy on how they utilize their workforce 

to process these applications would stem the tide of the backlog. 

Ms. BAKER. I would echo Dr. Dillingham’s comment in regard to 

section 312. It provides a number of initiatives that will help us 

9 

streamline the process. One in particular is echoed in the Small 

Airplane Revitalization Act. We are taking a relook at Part 23 and 

reorganizing it so that it is more fitted for the complexity and performance of the aircraft. That should make it much easier for applicants to get their aircraft certified. 

Also, Part 21 is another part of the initiatives in 312. We are 

going to be looking at a systems safety approach. So it will make 

a difference in how the applicant can apply the rules and we can 

apply our resources from a safety approach. 

Mr. LOBIONDO. Do you believe the use of designees is safe? 

Ms. BAKER. Yes, I do. 

Mr. LOBIONDO. Dr. Dillingham? 

Dr. DILLINGHAM. Yes, I do, Mr. Chairman. And I think the reality is there is no way that FAA can carry out all of its responsibilities without the use of designees. I think the critical dimension is proper oversight and accountability, and this is something 

that they’ve been doing for decades. It’s just a matter that it still 

needs monitoring, and it frees up FAA to actually work on those, 

to spend more time and attention on the real safety-critical aspects 

of certification. 

Mr. GUZZETTI. Sir, I think generally, yes, although I do think it’s 

an open question. I absolutely agree with Dr. Dillingham that oversight is key. ODA is yet one layer removed of FAA direct oversight 

of certifying products, and FAA needs to have the companies who 

know the product best help them with taking care of all these technical aspects. But delegation, which has been used in this Nation 

for decades, has always needed strong oversight by the FAA. So as 

long as that’s maintained, then it will remain a safe process. 

Mr. LOBIONDO. For the FAA, when will the 313 implementation 

plan be completed? And is it being developed with input from the 

ARC members, and what role is labor taking in the process? 

Mr. DUNCAN. Yes, first of all, we are working with the ARC 

members in developing the 313 plan. The 313 plan has short-range, 

mid-range and long-range goals. We are working the short-range 

goals right now to include the required fix to the rulemaking process. It would make sure that the guidance in rules that we produce, 

in the preambles, that they clearly state the purpose of the rule 

and the technical requirements of the rule, as well as the intent 

of the rule. Also we are evaluating the training that’s required for 

those folks who write the rules and later interpret the rules and 

what kind of guidance should be involved. We are also evaluating 

the existing IT systems that we have for the master database that 

you described earlier. 

Those are short-term goals, and we look to have those completed 

shortly. Some are completed already. The longer range goals are 

more of a challenge for us and we will continue to work toward 

those goals. 

Mr. LOBIONDO. So no timeframe for implementation of 313? 

Mr. DUNCAN. The timeframe for implementation of the shortterm goals and the continued evaluation for long-term goals is this 

year. 

Mr. LOBIONDO. This year? 

Mr. DUNCAN. Yes. 

10 

Mr. LOBIONDO. For Mr. Guzzetti, in your testimony you mentioned the weaknesses that the IT found in the 2011 report on organizational designation authority, in particular the oversight by 

FAA. Since your 2011 report, what actions have the FAA taken to 

address these concerns, and do you think they are adequate? 

Mr. GUZZETTI. Thank you for the question. 

We made five recommendations from that report, and FAA has 

taken action on every one of them. They have concurred with a 

plan to revise their policy to require a full, 2-year transition before 

an ODA unit can begin to self-appoint their own designees. They 

developed explicit guidance on the process to remove an ODA unit 

member in a timely fashion. They are tracking unit member appointments better. 

They have concurred and are developing new training and guidance for its certification engineers that never used to be in the 

habit of being an enforcer, of taking enforcement action. But with 

ODA they have to now, and we found in our audit that the engineers weren’t familiar with the enforcement process. So FAA has 

instituted training and guidance in that regard, and they also concurred with our recommendation to improve the oversight structure 

for large ODA organizations by again developing training and assessing the effectiveness of the new oversight structure. So they 

have moved out and completed just about every one of our recommendations in this regard. 

Mr. LOBIONDO. My last question, Dr. Dillingham. What can be 

done by the FAA now in recognizing the current situation and new 

regulations or additional resources to improve its certification and 

approval process. 

Dr. DILLINGHAM. Thank you, Mr. Chairman. I think the first 

thing is something that FAA is currently doing, that is making the 

best and highest use of the tools that they have. It is also, I think, 

to implement those recommendations, fully implement those recommendations that came from 312 and 313, and establish some accountability up and down the line from the very top to the very bottom of actually implementing the recommendations. Of course, it is 

going to be tough in terms of the whole fiscal situation for the 

country, but getting more from what you already have is a first 

step. 

Mr. LOBIONDO. Thank you. 

Mr. Larsen? 

Mr. LARSEN. Thank you, Mr. Chairman. 

First, for Mr. Guzzetti, you talked about ODA a little bit here 

and guidance for the engineers. Have you assessed whether or not 

FAA Aircraft Certification Engineers have enough direction regarding which activities should be delegated and which should not? 

Mr. GUZZETTI. Congressman Larsen, I think that area could use 

some improvements. We addressed an aspect of that in our 2011 

report, specifically in regard to a tool that FAA developed called 

the risk-based resource targeting, or RBRT tool, for engineers to 

use. And at the time the RBRT tool wasn’t a part of the ODA program, but we were requested to look at it, I think now it can be 

a candidate for ODA. 

We found some problems with that tool. RBRT is the tool that 

was designed to assist FAA engineers in prioritizing how complex 

11 

a project was to give them a better feel for whether it should be 

delegated or whether FAA should address it directly. And we found 

a lot of problems with that tool. There were software glitches, but 

also we felt that there wasn’t enough objective data feeding into 

the tool for its use; and there wasn’t enough training for folks to 

use that tool. Additionally, even after the tool would provide guidance to the engineer, the engineer had the option to not use the 

prioritization if the engineer was biased. 

We made a recommendation in that regard; and FAA responded 

and they are attempting to resolve the software glitches. Right 

now, I believe it’s just a voluntary tool to be used, but it would 

greatly enhance FAA’s ability to have another objective input to decide whether or not they should delegate an aspect of certification 

or keep it close hold. 

Mr. LARSEN. The term ‘‘software glitch’’ up here has a whole new 

meaning in the last 4 weeks. So I am trying to stay away from— 

just trying to find what that is. 

Can you, though, Ms. Baker, respond to Mr. Guzzetti’s comments 

regarding what should be and what should not be delegated, 

whether there is enough guidance for engineers? 

Ms. BAKER. Yes, Mr. Guzzetti characterized our problems very, 

very accurately. The tool was supposed to provide a standardized 

methodology for all of our engineers to use, so that it wasn’t just 

a personal bias just from the start. But it does allow the engineer 

to use engineering judgment. The idea is to try to understand the 

complexity of the design, understand the experience of the company 

that you are working with, understand the clarity of the regulation. 

All of these will eventually be put into the tool along with additional data, as Jeff said. We were trying to get other sources so 

that the engineer is aware of failures within the system. So when 

we get that complete, we will implement it wholly across all of our 

service and offices, and they’ll start using it at that time. They’ll 

also start using it for the ODAs. At this time they are not using 

it for ODAs. 

Mr. LARSEN. And on that last point, is that one of the issues that 

is a limiting factor for the FAA on using or delegating the full panoply of ODA authorities? Right now, some folks aren’t able to use 

all that is allowed through the delegation authority. Are there limiting factors to allow that to happen? 

Ms. BAKER. Yes. I wouldn’t say that this tool is the limiting factor. That tool is supposed to identify what areas within the actual, 

tight certification would be delegated and not delegated. When the 

companies are talking about full authority, we believe that they are 

really saying that whatever is authorized under our orders should 

be granted to them, which actually goes beyond certification. So 

there would be quite a few things associated with that. Issuance 

of certificates, for example, if they have a production certificate 

under their ODA, they would have a lot of autonomy. We are trying to get metrics that will measure how much autonomy they 

should actually have. 

Mr. LARSEN. Dr. Dillingham, I’ll finish here so the other side is 

ready. You mention on page 10 of your report a couple of issues 

with regard to the consistency of regulatory interpretation, ARC 

and the issue of fear of retribution, perhaps by industry players, 

12 

if they are complaining. There was a gentleman in my district office, a few weeks back I met with on, getting the name or company, 

a small company in the district. 

And he talked about this issue of fear of retribution from the regulator, from the certificator, if they even knew that he was in my 

office, much less if he complained to them directly about it. It sort 

of reminds me of one of the many classic lines from the movie 

‘‘Blazing Saddles,’’ where old lady Johnson delivers a pie to Sheriff 

Bart and she says, ‘‘Of course, we have the good common sense not 

to mention to anybody I was here.’’ And that’s kind of what I felt 

like this guy was so concerned about retribution from the regulator 

for even bringing these issues up to me that he didn’t want to be 

known. 

Can you assess that that’s prevalent? I will give you an opportunity to respond to this, Ms. Baker. Is that prevalent? Is that a 

one-off? Have you looked at that? Can you address that? 

Dr. DILLINGHAM. Thank you, Mr. Larsen. 

We did hear that from the stakeholders that we interviewed 

when we were doing the work for this committee a few years back. 

And the way it worked was that an applicant would be concerned 

about raising a dispute with their specific inspector, raising it up 

to the FSDO level or raising it up to the FAA headquarters level, 

because even if they won, they were concerned that that same inspector would be back to inspect something else later on, and there 

might be a problem with that. 

So FAA, to its credit, has a system in place that allows you to 

appeal all the way to the top, but that fear of retribution meant 

that the system wasn’t being used as much as FAA thought it 

might be used. How widespread that problem is, we weren’t able 

to assess. I wouldn’t say it is one-off, and that is one of the most 

difficult things to do. It is the cultural change that will be necessary, that inspectors are willing to do something different than 

the way they have in the past. And, in another way, the tool that 

one of the committees recommended was to have this comprehensive database with all of the regulations, the various interpretations that have been made of it, so that the inspector had a ready 

source to go and look and see there is another way to do this. 

There have been other alternatives, so, hopefully, we are just 

sort of moving towards a cultural change, putting this comprehensive database in place that we will have or hear fewer experiences 

like that. It certainly is a problem. How widespread, we couldn’t 

say. 

Mr. LARSEN. Yeah. Thanks. 

Ms. Baker, do you want to respond to that? Or Mr. Duncan? 

Yeah. 

Mr. DUNCAN. If I may, thank you, sir. 

Mr. LARSEN. Sure. 

Mr. DUNCAN. The relationship between our inspectors and the 

stakeholders is a one-to-one relationship in many cases through 

flight standards. It depends on a professional relationship between 

the two parties. That, in some cases, is challenging for us. We understand the perception in some cases of potential retribution, and 

we are concerned about that. 

13 

Number one, we obviously do not condone any kind of retribution. We also understand that there is a cultural challenge in dealing with certain cases. I think this is the case with both parties, 

on the part of the FAA and the part of the stakeholders as well. 

We are working to try to address this concern through several different mechanisms, including the recommendations of 313. To have 

clearer and more concise guidance is important to address these 

concerns. We need to promote within our organization the attitude 

that we are always looking for a consistent answer to the question. 

That is part of what we are trying to do. 

Mr. LARSEN. Yeah. Thank you, Mr. Chairman. 

Mr. LOBIONDO. Mr. Bucshon? 

Dr. BUCSHON. Thank you, Mr. Chairman, Ms. Baker. Hi. Over 

here! 

There was described there is a backlog of—you know—as much 

as 3 years in the approval process. What is the rate limiting step 

when you have that type of what I would prolonged approval process? Is there a specific area within the process that generally 

causes that kind of delay? 

Ms. BAKER. Yes. There are actually two, different sequencing 

processes. I will let John handle the actual certification of the airlines, and then I will cover the other. 

Dr. BUCSHON. Right. There are two. I understand. 

Ms. BAKER. Yes. 

Dr. BUCSHON. In your particular instance, what would be the—— 

Ms. BAKER. Yes. In 2005 we implemented a sequencing process, 

because we needed to ensure that we meted in the certification 

work so that we could reserve resources to work on our main priority, which is safety, and the continued operational safety of the 

aircraft that are in the fleet. The limiting factor is just the capacity 

of our engineers to do the work. We recognize that the process that 

we had in place was fraught with problems. The biggest complaint 

was that there was no predictability. There was a situation where 

the applicant would put in their application, and they would be in 

the queue for an indefinite period of time. 

We took those comments on our original process, rewrote our 

process completely, put that process back out for comment. When 

we finished dispositioning all the comments from industry, we put 

a revised process for sequencing out. It will still sequence. It’s basically going to be prioritization of specific resources, but it won’t 

hold up the initiation of the projects. 

So from here out, after we implement this in 2014, when you put 

in an application, you’ll immediately be able to initiate your 

project; and then the limiting factor might be a particular specialty 

in engineering to issue a special condition where there’s a novel 

item in the design of the aircraft. If there isn’t, it would just flow 

through the system and there wouldn’t be any holdup anymore. 

Dr. BUCSHON. OK. Mr. Duncan? 

Mr. DUNCAN. Yes, sir. Our primary responsibility and highest 

priority is to maintain the safety of the existing system, the operators that are currently out there. So in order to protect our ability 

to do that, we created the certification services oversight program. 

When an applicant files an application, or when a stakeholder files 

an application for some kind of certificate, we first evaluate whethVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00023 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
14 

er the resources are available in that jurisdiction to support the 

initial certification of the operator and the ongoing oversight of 

that operator. 

If they don’t exist in that office, we look more broadly to see if 

it can be done by someone else or somewhere else. If that can’t 

happen, then the application is placed on the wait list. For all practical purposes, the certification oversight process is where we keep 

applicants informed, on a 90-day basis, of where they are in the 

process. The limitation in that process is our resources, the resources to perform the required work that needs to be done and to 

provide the ongoing oversight of the new operator that’s created. 

Dr. BUCSHON. Thank you very much. 

I yield back, Mr. Chairman. 

Mr. LOBIONDO. Ms. Johnson? 

Ms. JOHNSON. Thank you very much, Mr. Chairman, and let me 

thank all the witnesses for being here. 

Your last statement about the resources, I do have a question 

about the recent Government shutdown and the budget cuts, hiring 

freezes, and some say they were sequestered. It has had the affect 

on FAA’s ability to attract and retain qualified staff for aircraft for 

Flight Standard Certifications. And I wonder also about the kind 

of risk that’s based on improving the aviation safety and wonder 

if you had those impacts to deal with and how it’s affected it. 

Mr. DUNCAN. Well, I’ll start from a flight standards standpoint 

and say that the challenges that you described, the impact on us 

is that we evaluate the resources that we have available to make 

sure that we cover the continuing operational safety requirements 

that we have. Because of the resource constraint, we expect that 

we will have slower response times in terms of what we just described, the certification processes and so forth. It’ll be slower and 

our ability to use overtime and travel expenses may also impact 

those things. 

New operators will likely be delayed, as we talked about a 

minute ago, and that may have an impact on small businesses. 

There may be significant delays associated with those operators. 

Additionally, operators that require changes, such as new aircraft 

on their certificates or training program approvals and so forth, 

may be delayed beyond the time that they would plan to implement 

those things, because of the resource constraints. 

Ms. JOHNSON. One further question. Just earlier this year, just 

before the shutdown came, there was an air control tower open, 

and—with the promise that staff would be furnished for the control 

tower. And after much discussion, that promise was kept, but also 

we are very aware that there is some threat to that. Now, how 

much of that is being experienced throughout the country, and for 

air traffic controllers? 

Ms. BAKER. Thank you for the question, but that’s something 

handled by Air Traffic Control. So we could take an action to get 

back to you on that. 

Ms. JOHNSON. OK. Thank you very much. 

Mr. LOBIONDO. Mr. Davis? 

Mr. DAVIS. Thank you, Mr. Chairman. 

I just want to note that both panels today have testimony that 

references the Small Airplane Revitalization Act. I am proud to coVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00024 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
15 

sponsor this bipartisan bill that would improve general aviation 

safety and spark innovation in the private sector by streamlining 

regulations. It appears this bill is getting very close to being presented to the President. 

You take a look at bills like that and ODA, and this committee 

has some good momentum and I hope we are able to keep it going. 

My question is going to be directed to Director Baker. Thanks for 

your role in ensuring the safety of our system. GAO made two recommendations in 2010. FAA has addressed one, but still has a little work to go on the other. 

GAO indicates that performance measures are necessary for FAA 

to be able to evaluate current programs. Can you talk about what 

you are doing to institute these performance measures? 

Ms. BAKER. Yes, Gerald was correct. We found that setting performance measures is very difficult. You have got to be sure that 

you don’t create unintended consequences. The approach that we 

chose to take was to develop a vision and pull together all of the 

initiatives in the section 312 response, and then to start working 

with industry to develop those metrics. 

We have milestones and goals to meet each of the initiatives. The 

actual effectiveness and efficiency metrics will be built as we work 

through the projects. It will have to be done very, very carefully, 

again, so that we don’t cause things to happen that we hadn’t intended to have happen. 

Mr. DAVIS. I yield back, Mr. Chairman. 

Mr. LOBIONDO. Mr. DeFazio? 

Mr. DEFAZIO. Thank you, Mr. Chairman. 

I have pretty much a very simple question or observation. It 

seems to me I’ve been on this committee an awful long time, and 

I remember when Libby Dole cut back on the inspector work for 

us big time. 

I don’t think we’ve ever recovered from that, and I guess my 

question is—we have testimony in the next panel from Michael 

Perrone from PASS, and he says, ‘‘The balance of FAA oversight 

is insufficient. The high number of designees’’—and he talks about 

that basically people are just chained to their desks reviewing paperwork or answering questions, but they really can’t get out any 

more because of the impossible workload they’re being given. 

Do we have—and I guess the FAA has actually studied this issue 

and they’ve come up with varying numbers. Do we have enough 

people? We can talk about all the systems, changes we want to 

make, and all the other things we want to do and all the computer 

applications, and all this streamlining and all that stuff; but if you 

don’t have enough people to provide the critical oversight of the 

designees program—which I think is a good program when properly overseen—it’s not going to work. Do we have enough people? 

Dr. Dillingham? Anybody? Do we need more? 

Dr. DILLINGHAM. Well, Mr. DeFazio, you know, of course, FAA 

can always use more people. I mean its responsibilities are everexpanding, and we support that, but we also—there’s a reality of 

the fiscal condition that we all are in. So that means that you have 

to make the best of the resources that you have. 

Mr. DEFAZIO. Well, I get that, but OK. So let’s not be fiscally 

constrained. We could look at novel ways to—you know. I mean if 

16 

the people who are developing the new systems and new aircraft, 

the new avionics, all the other things are feeling like they’re being 

held back so much in terms of their productivity. They might be 

happy to contribute some money to the FAA to hire more people 

so that they could get more timely reviews more quickly. 

Dr. DILLINGHAM. I think you hit the nail on the head when you 

started off, Mr. DeFazio, by saying a properly overseen designee 

program is probably the quickest, most efficient way to expand the 

resources available to carry out the work. That oversight has to be 

top-notch. Otherwise, you do start to risk issues of safety and other 

related matters. 

Mr. DEFAZIO. I think we have seen with some other agencies 

over at the—overseeing pharmaceuticals, the FDA or the Corps of 

Engineers, sometimes, on major projects where they essentially 

allow people who have an interest to contribute resources; but the 

resources are not employees of or responsible to those who contributed the additional resources. They are responsible to the agency 

doing the reviews. And so you are still having the amount of oversight you need, but you are providing more people. 

Isn’t the number of people ultimately going to be a choke point, 

no matter what we do here and no matter how efficient we make 

this? No matter what reforms we adopt, they’re still shuffling stuff 

around. 

Dr. DILLINGHAM. Absolutely. 

Mr. DEFAZIO. Anybody else got a different opinion or want to 

augment that opinion? 

Ms. BAKER. No. I don’t think that there is a different opinion. 

There is, obviously, a point where you’ve got a diminishing return. 

You can only have as many designees as you can have enough employees to oversee those designees appropriately. What we’re trying 

to do is to develop processes and procedures and tools so that they 

can do a better job at oversight by making sure that FAA inspectors are doing their jobs strategically, instead of using the personal 

preference of an individual. If you can determine which areas you, 

as an inspector, should target, then the idea is that you would use 

a system safety approach and it would direct you to the areas 

where you should concentrate. 

That way, you’d use fewer people. But there is, obviously, a point 

where you cannot delegate any more. You have to have more people. 

Mr. DEFAZIO. Hm-hmm. OK. 

Mr. GUZZETTI. Congressman DeFazio, I just wanted to piggyback 

off that statement. Because of the fiscal constraints, because of the 

inability to hire new inspectors, it’s up to FAA to make sure that 

they have the best process to target what limited resources they 

have to risk, and we just issued a report this past March regarding 

a staffing model that FAA has, that they’ve been having some difficulties with. 

But it would be helpful if there was a model to at least identify 

how many inspectors FAA needs, given the demand out there, and 

we made some recommendations along those lines. And that model 

was also meant to not only include flight standards inspectors, but 

also aircraft certification engineers and inspectors. It’s not there 

17 

yet, but perhaps that could be very helpful to FAA to get that 

model up and running. 

Mr. DEFAZIO. Right. But, you know, if we target the people to the 

risk areas—I fly a lot and am happy with that—but that leads to 

the statistics we heard earlier in all these routine things that become a bigger and bigger backlog. Isn’t that correct? 

Mr. GUZZETTI. It’s definitely a balancing act. You heard Mr. Duncan indicate that continuing operational safety should be the priority and that has impacted his ability to process new applications. 

It’s a big challenge, but it’s one that has to be tackled. And to not 

allow any new applicants to begin at the exclusion of continuing 

operational safety, I don’t know if there’s a proper balance right 

now. 

Mr. DEFAZIO. All right. 

Thank you, Mr. Chairman. 

Mr. LOBIONDO. Mr. Williams. 

Mr. WILLIAMS. Thank you, Mr. Chairman. I want to thank all of 

you for being here today. Appreciate it. I’m from Texas. We have 

got a lot of aviation in Texas, and especially in my district. And, 

also, I just want to add one thing. I am a small business owner, 

and I hear what you are saying about balancing and this and that, 

and remind you in all due respect that small businesses are balancing right now. That’s the nature of our economy to get the most; 

sometimes the least, but I appreciate what you all are doing. 

My question would be to Mr. Guzzetti. Of course, safety is, I 

know, everybody’s top priority and we appreciate the record that 

you have. But I guess I would ask at least in here with all that 

in mind to find a balance between streamlining your processes, 

your certification processes, and make sure it doesn’t compromise. 

Are you able to do that, make sure it doesn’t compromise with 

what we call the gold standard of safety that you all have? 

Mr. GUZZETTI. I think there’s probably ways to do it. I don’t know 

what they are. I think FAA needs to explore those additional processes or a different process for efficiencies. Right now, the general 

philosophy at these flight standards offices is to process these new 

applicants that come in, whether it be a small airline or a repair 

station that wants to start up, on a first-come-first-served basis. 

But, when you look at the guidance, it can allow some flexibility 

for the FAA to bypass that process, marshal their resources, and 

not let a complex project clog the pipeline of simpler projects behind it. So FAA could explore those flexibilities to add a little more 

balance. 

Mr. WILLIAMS. Compromising safety is not anything we want, so. 

Mr. GUZZETTI. No, absolutely not. Safety should always remain 

FAA’s number one priority; but, by the same token, they also are 

the regulator and the organization to give the green light to small 

business. Safety should be number one, but they have this other 

component they need to perhaps make more efficient. 

Mr. WILLIAMS. Thank you, Mr. Chairman. I yield back. 

Mr. LOBIONDO. OK. Thank you, Mr. Williams. 

Mr. Larsen, do you have any thing else? 

Mr. LARSEN. One more question. 

Mr. LOBIONDO. OK. 

18 

Mr. LARSEN. Dr. Dillingham, in April you testified before the 

Senate that ‘‘When faced with the certification of new aircraft or 

equipment, FAA staff have not been able to keep pace with industry changes, and thus may struggle to understand the aircraft or 

equipment they are tasked with certificating.’’ 

Do you think that is a major problem? If so, what steps can the 

FAA take or is it taking to address that concern? 

Dr. DILLINGHAM. Thank you for the question, Mr. Larsen. 

We heard that opinion from some of the stakeholders that we 

interviewed about FAA’s capabilities. I don’t think that that’s a 

major problem at this point in time. It could take on more, become 

more of an issue as their workload expands and different technologies come in. But our experience in looking at FAA, for example, when we did the work looking at the composite components of 

the Boeing Aircraft, we found that FAA had taken numerous steps 

to train its workers, establish centers of excellence, work with the 

industry to understand what’s going on. 

So our experience, at least in that example, shows that when 

FAA sees an issue that requires that kind of technological expertise 

that it reaches out to industry, hires people when it can, but also 

makes sure that its current workforce is up to speed on things. So 

now we don’t see it as a major problem; and, again, the future is 

to be determined. 

Mr. LARSEN. Yeah. 

Ms. Baker and Mr. Duncan? 

Ms. BAKER. I agree. No entity is going to have the expertise in 

every, single, new technology. Especially when industry is consistently pushing the boundaries of technology. Our people gain experience through the certification of the new technology, but they also 

work with committees, like RTCA and SAE. Our people are in 

amongst the world-renowned experts and absorb the information 

from them, and rely upon them in many cases. We can go to contractors, like Volpe, if we need expertise in a particular area. So 

all of these are at our disposal. 

In addition, we have chief scientists within our organization, 

whose sole role is to go out and to learn more about new technology 

and bring information back to our engineers. When we do see that 

we are, maybe deficient in a particular area, or not multistranded 

in a particular area, then we’ll provide the training for those individuals who need it so that they can be up to speed with the technology that’s presented to them. 

Mr. LARSEN. Thanks. Thanks. 

OK. Thank you. 

Mr. LOBIONDO. Thank you, Mr. Larsen. 

To our first panel, thank you very much. We will take a very, 

very short break, allow the second panel to get set up and then 

proceed again. 

[Recess.] 

Mr. LOBIONDO. Thank you. We will pick up with our second 

panel. We welcome Mr. Peter Bunce, president and CEO of the 

General Aviation Manufacturers Association; Mr. Tom Hendricks, 

president and CEO of the National Air Transport Association; Mr. 

Michael Perrone, president of Professional Aviation Safety SpecialVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00028 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
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ists; and Mr. Ali Bahrami, vice president of civil aviation, Aerospace Industries Association of America. 

Peter, you are recognized. 

TESTIMONY OF PETER J. BUNCE, PRESIDENT AND CEO, GENERAL AVIATION MANUFACTURERS ASSOCIATION; THOMAS 

L. HENDRICKS, PRESIDENT AND CEO, NATIONAL AIR TRANSPORTATION ASSOCIATION; MICHAEL PERRONE, PRESIDENT, 

PROFESSIONAL AVIATION SAFETY SPECIALISTS, AFL–CIO; 

AND ALI BAHRAMI, VICE PRESIDENT-CIVIL AVIATION, AEROSPACE INDUSTRIES ASSOCIATION OF AMERICA 

Mr. BUNCE. Thank you, Mr. Chairman. 

Chairman LoBiondo and Ranking Member Larsen, it is a pleasure to be here today and be able to discuss certification. Certification is a very complex topic, and it was very evident by the first 

panel and the discussion that went back and forth that everyone 

is very familiar with some of the impediments to this process and 

also the opportunities that we have as we move forward with being 

able to streamline certification. 

General aviation manufacturing in this country is extremely im- portant. We are talking 1.2 million jobs, and $150 billion in economic contributions to this Nation’s economy. But, what’s really 

important is in recent years 50 percent of the product that is produced in this country is going overseas. That is a great export engine for this Nation, and that’s why being able to get product to 

market is so important. 

We are one of the most heavily regulated industries that there 

are, and getting product through the system and through the FAA 

certification process has a tremendous impact on jobs. This committee has been extremely supportive of this journey that we are 

on with our Government regulators in both section 312 and 313. 

The last Congress and the FAA Reauthorization Act really put a 

focus on this. And then, during this Congress, and particularly this 

subcommittee and the full committee, the support for the Small 

Aircraft Revitalization Act is absolutely instrumental. 

That is just the start. We want to be able to extend that to Part 

27 and Part 29 for rotorcraft, and eventually to Part 25 for transport category aircraft, because this is a new way of doing business, 

and it is very important to keep aerospace leadership here where 

it belongs. But reform is extremely important, and let me put the 

challenge that we have in front of us in terms of different companies that we have out there. 

If we take a small company that is trying to develop a new technology—and Mr. Massie was here earlier, and one company he’s 

very familiar with actually looked at being able to put safety-enhancing, a great safety-enhancing technology in their new iteration 

of a product going out the door—and looked at the length of time 

it was going to take to be able to get that certified, and just said 

‘‘we cannot afford to be able to wait that length of time to introduce 

this new product. We will miss a market opportunity in our timing 

when other companies are introducing similar technologies,’’ and 

they had to forgo some great safety enhancement, just because of 

the amount of time it took. 

20 

You take another company, such as one that’s located in Mr. 

Nolan’s district. It is their first foray into a jet. They have only produced piston aircraft heretofore. They need resources to be able to 

be devoted to them to get this new technology and be able to get 

the help from the FAA to get that product to market because they 

haven’t done that before. 

Now, compare that to some mature companies that are in both 

of your States or in Mr. Bucshon’s State looking at engine technology, these companies are very mature. They set up these ODAs 

to be able to go and have a safety system in place that recognizes 

that when they are doing something that they have done time and 

time again, they have competencies built up. So, Mr. Larsen, when 

you ask that question about what you delegate and what you don’t, 

the system recognizes that they have competencies. But when they 

are doing something new and novel, then resources can be devoted 

there. 

So leveraging resources becomes so very, very important, and the 

burn rates for some of these companies are very huge. When you 

look at a larger company, a burn rate in a development program 

is up to $10 million a month; and, when it is extended out for a 

year, you are talking real dollars. When you are talking a smaller 

company and you look at investment dollars and the requirement 

of investment capital to get a return on investment, but you have 

to go back and tell them, ‘‘Well, the certification process is uncertain. It could take 3 years or it could take 5 years,’’ that investment 

just doesn’t happen, because of that uncertainty. 

The return on investment is too far out there, because of the certification process. So, if we allow delegation to work through an 

ODA, we free up resources to be able to go to those newer companies. And unfortunately, I can give you a list as long as my arm 

of companies that just couldn’t make it because they ran out of 

money in the certification process. So leveraging these resources 

becomes absolutely critical. 

Implementation is the key. As Dr. Dillingham brought out, we’ve 

started a journey, but it is just not enough for the FAA leadership, 

which I believe really is behind this effort and is in concert with 

us to try to make this process more efficient. But you can’t just put 

out edicts from headquarters without putting in the implementation criteria, actually having metrics that we can measure and be 

able to come back to this committee, and you all asking important 

questions, ‘‘Are we making progress?’’ It’s got to be measurable. 

We need to be changing job descriptions; we need to be changing 

that culture, and you heard that in the first panel. Cultural change 

is the real driver to be able to make this work. And, finally, what 

I want to emphasize is this gold standard. The erosion of the gold 

standard is something we are very concerned about. FAA should be 

the standard for certification across this entire planet, so we have 

got to make sure that we keep talking to international authorities 

about the robustness of our programs and how we produce the 

safest products on the planet. 

Thank you. 

Mr. LOBIONDO. Thank you. 

Mr. Hendricks? 

21 

Mr. HENDRICKS. Thank you and good morning, Chairman 

LoBiondo, Ranking Member Larsen and other members of the subcommittee. 

We appreciate the opportunity to speak to the subcommittee 

today, and thank you for your foresight in conducting this hearing. 

It is good to testify before the subcommittee, again, in my new role 

as the president of the National Air Transportation Association. 

Our members represent—are characterized by small businesses at 

the Nation’s airports. We have over 2,000 members. 

As stated earlier, we operate in a very highly regulated environment. Our members include fixed-base operators, charter companies, maintenance repair stations, flight schools and airline service 

companies. The 2012 FAA Modernization Reform Act played a 

large role in how our companies are regulated, and I am pleased 

to provide comment today. 

Specifically, regarding section 313, the consistency of regulatory 

interpretation, as you are aware, NATA cochaired the Aviation 

Rulemaking Committee. We were honored to do that. The FAA has 

a challenging environment. They have eight regions, 10 aircraft 

certification offices, and 80 flight standards district offices. And so 

we need to strike a proper balance between the different operating 

environments that these companies find themselves in. 

I’ll give you an example of one of our members. A member, a 

charter company, actually moved an aircraft to a different region 

of the FAA. To get that aircraft placed on their operating certificate 

in that region required 5 weeks. During this time, this small company spent $25,000 trying to comply with the new requirements in 

this new district, and they had to forgo over $200,000 in revenue. 

Again, these are small businesses. Thirty percent of our members 

have 20 employees or less. These are make-or-break decisions, so 

we support reform in this regard. 

The Aviation Safety Information System that the FAA is developing is a step in the right direction, and we support this system 

that provides the ability to coordinate, not only within the Flight 

Standards Service and the Aircraft Certification Service, but between those two organizations. We view it as a positive development. 

Specifically, regarding section 312 of the Act, we strongly support 

the modernization of the certification processes, and I agree with 

Mr. Bunce’s comments on this issue. We are concerned about the 

rapid pace of technology evolution in the aircraft environment, in 

the FAA’s ability to keep up with that pace. Right now, there are 

safety enhancing and economic enhancing technologies that are 

just slow to the market, because of the FAA’s struggles with certifying this new equipment. 

And we are concerned that as technology rapidly evolves over the 

coming years that there will be a larger bow wave of requirements, 

and we are going to fall further and further behind. The FAA has 

acknowledged this. We are working with them, trying to be very solution-oriented, and we agree that expanding the ODA, the Organizational Delegation Authorization, is a correct path and will yield 

results. And we couldn’t do that without the great work force we 

have already with the inspectors. So it is a community-industryVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00031 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
22 

Government effort to try to expand this program and leverage the 

talent that we already have. 

So, in conclusion, I would like to say that we all have helped create the safest, most complex aviation system on the planet. We 

can’t lose sight of that. It has taken strong collaboration with our 

regulator, with industry, and the oversight of the Congress. We are 

very thankful for that, and what we would like to see in the future 

is an FAA that provides more agility to respond to these ever-evolving, safety-enhancing technologies that can improve our businesses 

and grow jobs. With that, I’ll be happy to take any questions you 

might have. 

Thank you. 

Mr. LOBIONDO. Thank you. 

Mr. Perrone? 

Mr. PERRONE. Chairman LoBiondo, Ranking Member Lawson 

and members of the committee, thank you for inviting PASS to testify today. 

PASS represents approximately 11,000 FAA employees, including 

over 3,000 aviation safety inspectors in the flight standards and 

manufacturing bargaining units. We appreciate the opportunity to 

present our views on the FAA certification process and ways to improve it for the safety and efficiency of the aviation system. 

The FAA certification process is intended to ensure aircraft and 

equipment meet FAA’s airworthiness requirements. Section 312 

and 313 of the FAA Reform Act included requirements for the FAA 

to streamline the certification process and address inconsistencies. 

In response, the FAA created two Aviation Rulemaking Committees to analyze the certification process and make recommendations. 

Regarding the ARC recommendations, we agree that the certification process is in need of some streamlining; however, we don’t 

believe that creating additional steps or layers of paperwork is the 

most efficient way to achieve this goal. In fact, paperwork requirements included in the FAA’s CPI guide and other guidance contribute to inefficiencies rather than address it. 

PASS recommends conducting a review of agency regulations, 

policies and procedures in the certification process to eliminate 

those that are inefficient, redundant and conflicting. PASS also 

supports the development of a database to monitor and track certification process improvements. The ARC also recommends that 

the FAA enhance its use of the designee program. PASS has serious concerns with this recommendation. The FAA cannot keep delegating out work without an adequate number of inspectors to 

oversee the designees. In our view, this is an aviation safety issue. 

Oversight is especially difficult to ensure in the ODA program 

where an entire corporation performs work on behalf of the FAA. 

Since inspectors are only able to examine a small portion of a large 

company, it is literally impossible to ensure sufficient oversight. 

When the ODA program was first introduced, it was intended to 

allow companies with the highest expertise and capabilities to 

serve as an extension of the FAA. Now there are 76 ODAs, and the 

FAA intends to expand this program. 

The level of work and the oversight needed to ensure proper surveillance of designees and ODAs must be addressed. This comVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00032 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
23 

mittee asked what can be done in the near term to improve the certification process. The number one way to improve the process is 

through additional inspector staffing. There are currently 139 manufacturing inspectors. Unbelievably, that number has not changed 

for over a decade, despite the steadily increasing level and diversity 

of work and responsibility including oversight of the designee program. 

Certification activity is on the rise due to industry changes and 

advances in technology. At the same time, budget cuts resulting 

from sequestration are preventing the hiring of additional inspectors due to the hiring freeze; and, while staffing is dropping in 

many locations due to retirements and other factors, the work is 

steadily increasing for the remaining inspectors. Without a doubt, 

in order to ensure a safe and efficient certification process, there 

must be an adequate number of FAA inspectors in place to oversee 

these important functions. 

In closing, PASS wishes to express our serious concerns regarding the impact of the Government shutdown. For 16 days in October, oversight of important certification work was put on hold. During the shutdown, among other things, no new safety design approvals were addressed, quality system audits and supplier control 

audits were delayed. Investigations were altered and safety data 

was not evaluated. When a limited number of inspectors were 

called back during the shutdown, they were directed to focus only 

on continued operational safety and stop all certification work. 

Aircraft manufacturers and the aviation industry as a whole depend on FAA employees being on the job to review and certify new 

equipment on a timely basis. These critical employees must be 

given the tools and resources to continue performing their important work. 

Thank you for your attention to this important matter. I would 

be happy to answer any questions you have. 

Mr. LOBIONDO. Thank you. 

Mr. Bahrami? 

Mr. BAHRAMI. Chairman LoBiondo, Ranking Member Larsen, 

distinguished members of the subcommittee, thank you for allowing AIA to submit testimony at this important hearing. 

I am Ali Bahrami, vice president for civil aviation at the Aerospace Industries Association. AIA represents the interests of over 

380 U.S. aerospace and defense manufacturers. Our members have 

a keen interest in efficiency of the FAA certification activities, because those activities govern our ability to bring new and innovative products to the market. 

Before joining AIA earlier this year, I worked 24 years in the 

FAA’s aircraft certification service. In 2012 I also served as the cochair of the agency’s Aviation Rulemaking Committee, formed in 

response to section 312 of the FAA Modernization and Reform Act. 

I think it is appropriate to first recognize the dedication and technical expertise of the FAA certification work force. 

Our aviation system is the safest in the world. This is partly due 

to effective partnership between aircraft manufacturers and FAA 

certification staff. While industry has continued to grow, certification offices have been facing budget cuts, hiring freezes, and furloughs due to sequester and the Government shutdown. Expecting 

24 

the FAA to keep pace with industry while conducting business as 

usual is not realistic. 

If the streamlining is not implemented properly, FAA will not be 

able to keep up and will begin to fall behind our global competitors. 

FAA’s response to the 312 ARC recommendation has been very encouraging. The FAA has developed detailed implementation plans 

for all six recommendations, and work has already begun on several of them. We are also pleased that the FAA’s plan includes establishment of a joint FAA-industry group to review the implementation progress. 

The AIA welcomes the recommendations made by the so-called 

313 ARC, the committee charged with addressing the inconsistencies in regulatory interpretation. We are waiting for the release 

of the implementation plan for these recommendations. Since many 

certification standards are performance-based and not prescriptive, 

it would be unrealistic to assume that these recommendations will 

eliminate all inconsistencies. 

AIA believes development of an effective process to quickly resolve disagreements between applicants and the FAA staff is essential. Given the magnitude of the process changes, it is important 

that the FAA institute a robust change management process that 

ensures acceptance of the change by the workforce and successful 

transition. The members of the 312 ARC believe this issue was important enough to be included as one of the recommendations. 

While we are moving forward with these activities, let’s not forget that today we have an effective tool that can reduce certification delays. It’s called delegation. We have over half a century of 

successful history with delegation. This successful history supports 

expansion of delegation based on data. The AIA members can tell 

you obtaining an organizational designation authorization is not 

easy. It requires a lot of resources, care and oversight on part of 

an applicant. We urge the FAA to allow greater use of delegation, 

not only to take full advantage of industry expertise, but to increase the collaboration that improves aviation safety. 

Mr. Chairman, we applaud the committee for holding this hearing. It demonstrates to the agency that certification is a priority for 

this subcommittee; but, equally important is ensuring that the FAA 

has the resources it needs to maintain momentum. Like any other 

initiative, process re-engineering will take resources to implement. 

In some cases, this will divert staff from paying attention to the 

certification work and other safety matters, at least in the short 

term. 

The FAA’s 312 implementation plan does not estimate the resources needed to follow through on the recommendations. We believe these resources should be clearly identified, reviewed by the 

subcommittee, and protected as much as possible in the appropriations process. 

Mr. Chairman, that concludes my statement, and I look forward 

to answering any questions you may have. 

Mr. LOBIONDO. Thank you very much. 

For the whole panel, the question I asked of the first panel, we 

have heard a lot about the use of designees. Are the use of designees in those programs safe in your eyes, in your estimation? 

25 

Mr. HENDRICKS. Yes, Mr. Chairman. It’s a very safe, highly regulated environment as Mr. Bahrami alluded to, to be admitted in 

the program. With the volume of projects and the evolution of technology, we feel like this is a very safe, sound process at the FAA, 

and we’d like to see it expanded. 

Mr. BUNCE. Mr. Chairman, designees are nothing new. Since the 

FAA was created in 1958, we’ve been using designees all along. I 

mean every pilot out there that flies in the system uses a designee 

just to be able to get their pilot’s license. Using them in the certification process actually makes the system safer, because we are 

able to go ahead and leverage that FAA expertise and the great 

men and women that we have their work on, the engineering workforce, to go into the new and novel technology. So as long as we 

leverage this correctly, we are actually making the system safer. 

Mr. BAHRAMI. Mr. Chairman, as I mentioned during my remarks, 

we have a lot of data over the past 50 years that indicates that the 

system is working and it is safe. 

Mr. PERRONE. Mr. Chairman, as I said, because we only have a 

limited number of staff, the expansion is probably a concern; but, 

overall, it’s safe. But how much oversight, how much checks and 

balances can we have if we don’t have enough inspectors to oversee 

the designees? So, right now, are we pushing the envelope, or are 

we at a safe place? It’s hard to tell what. In our view, more inspectors will help make it a safer and continue to make it a safer system. 

Mr. LOBIONDO. Also, for the whole panel, how has the FAA consulted with industry on gauging implementation plans and 

progress? And what role do you think should labor have and are 

they being utilized? 

Mr. PERRONE. From PASS’s perspective, we should be involved in 

any decisions that the agency and industry work with to have more 

eyes and ears, to be involved in would help and I think be as successful, because we have a particular need to make it the safest 

system in the world. So labor should be at the table with this. 

Mr. LOBIONDO. Are they consulting with you? 

Mr. PERRONE. From the PASS perspective, limited to none. 

Mr. BUNCE. Mr. Chairman, I would say that we have a very close 

relationship with the engineers out in the aircraft certification offices throughout the country. And so there’s constant feedback between industry and the regulator, itself, at that local level; one, to 

get consistency across the board, but also to be able to implement 

the guidance that’s coming down from headquarters. 

Sometimes that information flows differently to industry than it 

does to Government. And that’s why as we implement ODA, and 

we also just streamline the whole certification process, being able 

to have metrics in place that everyone understands, that we can 

measure and have everybody on a common sheet of music is extremely important. And then the education and training for the 

FAA workforce, we want nothing more than to be able to have very 

educated engineers, especially when we are working with new and 

novel technology. 

So that’s why industry is very eager, and when we’re doing something new to have them partner with us so they can learn along 

with us when we have this new technology. But when we are doing 

26 

something that we have done routine time and time again, we don’t 

need the FAA engineers down there with the sharp pencil down in 

the details. Let’s focus them on areas where we really need them, 

and I think that’s where the communication has to be. 

Mr. LOBIONDO. I understand. But are they consulting with you 

or are they dialoguing with you? Or is there a back and forth here 

on some of these critical things? 

Mr. BUNCE. Absolutely; there is a back and forth. Just when you 

go and you develop a plan to be able to certify a program, whether 

you are using an ODA or whether you are in the normal sequencing process, there is a back and forth that goes on. Industry will 

submit the plan. It’s brought back to us with either acceptance or 

recommendations. So there is a process back and forth. 

Now, one thing that we are asking for is if a company actually 

does have an ODA that they have invested a lot of money to be 

able to set this up on the promise that the FAA will allow them 

to go ahead and administer and have these programs delegated unless it’s new and novel. Right now, the process works that a lot of 

times the FAA can go ahead and say, ‘‘I’m going to retain this, this, 

this. You can do this, this and this.’’ 

What we’d like to do is see a process because the way the ODA 

was originally envisioned that says, ‘‘OK. FAA, if you are going to 

retain it, give us rationale on why you want to retain it. Is it to 

train your workforce? Is it because it is new and novel technology?’’ 

And then if there is a discussion about that, we can go ahead and 

elevate it to a higher level, but that would be a much more efficient 

way of administering the ODA and leveraging those precious resources. 

Mr. HENDRICKS. Mr. Chairman, I would just like to offer you 

may be shocked to know that in the aviation world our members 

are not shy about sharing their opinions, about what they are seeing out there in the field. And they see challenges at the local level. 

We can’t allow everything in the FAA to be run at headquarters. 

It wouldn’t be a good way to operate. But our members share those 

with us. All of us have expertise on our staffs, and the FAA has 

been very collaborative as we bring them evidence of the cases I 

cited in my testimony about a challenge you are seeing in the field. 

So I would say the FAA is working very well with us. We are looking for solutions, collectively, and trying to be constructive in those 

suggestions we offer. 

Mr. BAHRAMI. Mr. Chairman, a key word is collaboration, and I 

believe so far on these two initiatives FAA has been doing a great 

job of communicating and working with industry. With respect to 

questions on working with labor, as I mentioned, acceptance of 

these changes by the workforce is really important. If you don’t 

have that, we are going to continue to struggle. So, whatever the 

form is for that collaboration, through whatever means, I think 

that’s appropriate and necessary. 

Mr. LOBIONDO. I have some additional questions but I am going 

to hold back and let some of the other Members go. 

Mr. Larsen? 

Mr. LARSEN. Thank you, Mr. Chairman. Mr. Perrone, considering 

the future and the next decade or so, trying to get NextGen technologies out, new models and new airplanes being designed and 

27 

built in the country, application of new technologies to existing 

general aviation platforms, have your folks done any sort of independent or in-house analysis of the number of inspectors that you 

need to (1) perhaps catch up to where we should be today, and (2) 

looking out in the future, the numbers that we would need to maintain an efficient certification and approval program? 

Mr. PERRONE. We had the Academy of Sciences do a study a few 

years back, the flight standards folks, and they came up with a recommendation for a model that the FAA has used. They plugged in 

a number, somewhere between 300 and 900 short of inspectors. 

On the manufacturing side, however, there has not been any 

study. That is why I am saying the 139 manufacturing inspectors, 

it has been that way for a decade. 

From PASS’s perspective, we just continue to see and hear the 

workload is increasing and increasing to oversee the designees and 

expand—the ODAs. 

We believe we are short staffed. The more the industry needs to 

move along with NextGen, and we see that as an important aspect—NextGen is going to be here. There are going to be a lot of 

new products. The FAA needs to have more of that oversight to 

make sure everything is done safely and efficiently. 

Mr. LARSEN. Does your thinking include the need for FAA to 

have some folks come in, outside experts come in just for a brief 

period of time and leave again? You are not including that group 

of folks, are you? 

Mr. PERRONE. No. 

Mr. LARSEN. You still expect that to happen: outside folks to 

come in for a technology-specific thing and then go, but once we are 

in implementation and application, incorporating it in the platforms, that is where we are going to need additional folks? 

Mr. PERRONE. Correct. 

Mr. LARSEN. Mr. Bunce, you talked about the gold standard. Is 

the FAA in danger of losing its gold standard status for certification? 

Mr. BUNCE. Yes, sir. Actually, we see an erosion of it that is happening all across the board. If you look internationally right now, 

EASA, the rough FAA equivalent over in Europe, it is very aggressive with teams out, being able to explain their certification processes. 

When they go and do that to other countries that are out there 

starting to stand up more robust aviation regulating authorities, 

we want to make sure that they have confidence that if something 

has an FAA Stamp of Certification on it, they say OK, we do not 

need to spend the time to have to come over to the U.S. or have 

manufacturers come over to their country to once again prove that 

this aircraft was built safely. 

We want them to be able to accept the FAA as the gold standard. 

Any of the authorities that we have a bilateral relationship with, 

that is really not a problem if we are dealing with Transport Canada, ANAC in Brazil, or EASA. 

When we have so many countries out there that are now increasingly getting into aviation, it becomes all the more important that 

we do not waste time having to re-prove that we built this aircraft 

safely, and they accept that FAA gold standard. 

28 

What does that require? That requires the FAA certification offices along with the international offices to be aggressive, to be out 

there and discuss with these countries and the other regulators, as 

they stand up their structure, to say ‘‘hey, you need to accept what 

we did because this is the best in the world.’’ 

Mr. LARSEN. Mr. Hendricks outlined the problem that even here 

in the United States, you cannot get one region to accept the standard another region has set. 

Mr. HENDRICKS. I think it goes to the point, Congressman 

Larsen, about striking the proper balance. We do have different operating environments. It is different flying in the southeast U.S. 

compared to the Rocky Mountain region, and the oversight of those 

operators in those regions need to reflect that reality. 

We do not believe one size does fit all for the regulatory regime, 

for operating aircraft safely in the U.S., that we need to have 

thoughtful discussions, and that is the reason we mentioned the 

balance between headquarters’ view of regulation and what the inspectors out there in the field who know their operating environment very well, how they view their operation. 

We just would like to see an increase in that dialogue so we are 

striking the proper balance. 

Mr. LARSEN. Mr. Bahrami, I want to ask you to explain yourself, 

being from the northwest region. I have a different question for 

you. If you want to address that, that’d be great, given your experience in one of the regions. 

This issue of other certification processes. The FAA’s August 

2012 Aircraft Certification Review states that Europe and Canada 

have more mature systems approaches for regulatory oversight of 

design organizations and certification processes. 

Has AIA looked at how Europe’s oversight of the certification 

process differs from those of the U.S., and can you grade it? Can 

you say it is more mature? Can you say it is better or worse? 

Mr. BAHRAMI. I would not be in a position to grade it better or 

worse, but I would tell you that from experience I have had in certification, 24 years, and 10 years of it in large transport, some of 

the ideas that we are thinking to start, things like certificated design, organization or approved organization, have been used in 

other countries. 

When it comes to the safety level, if you define measure of success as safety, we are competing with those and we are doing quite 

well. 

But if you talk about the transition, the pace of change and 

things of that nature, I think we are a bit slower, and therefore as 

Mr. Bunce mentioned, there is a risk of not being able to lead globally if we cannot find ways to do things more effectively. 

Mr. LARSEN. Thanks. Thank you, Mr. Chairman. 

Mr. LOBIONDO. Mr. Bucshon? 

Dr. BUCSHON. Thank you, Mr. Chairman. A general comment 

and a couple of questions. I have heard a lot today at this hearing, 

which I do at a lot of other hearings in different committees about 

funding and how funding has an effect on Federal agencies. 

As it specifically relates to the FAA, in regards to where Congress is on funding, when you have the FAA is $4 billion over 

budget on NextGen, for example, and other issues like that, I think 

29 

it is important—we have heard some of that today—not to convince 

but to show Members of Congress on both sides of the aisle where 

the taxpayers’ money is being used efficiently or not. I think that 

is one of the rate-limiting steps on funding. 

The other comment I have on funding is we have a crisis in debt, 

but we are only addressing about 40 percent of the overall Federal 

spending budget. Congress will need to address the 60 percent of 

our mandatory spending programs or else we are going to continue 

to see a pinch on the discretionary side. 

With that said, Mr. Bunce, can you detail some of the effect on 

industry and your members from the current system in terms of 

delay and costs to your members? Do you have just a general comment on that and how that is affecting your members? 

Mr. BUNCE. Absolutely, sir. In your State, two very mature engine manufacturers that operate in Indiana—if you look at some of 

the new technology that we have going forward, in fact, they were 

very instrumental in success with ICAO in Montreal in developing 

new CO2 standards, which all jet engines will be measured against 

as long as we will all be around. 

That new technology is complex. There are new materials being 

used, new metallurgy, new ceramics in those engines. 

If you try to get through that process and you are doing something new and novel, if we can go and dedicate those resources, we 

keep the burn rate down of being able to introduce that new product. Because if you look at the air frame manufacturers, they need 

to keep constantly putting a new air frame out. They have to have 

new engines. 

If one of those companies misses that development cycle because 

their program is drawn out because they cannot get the resources 

devoted to this new technology, they will miss being on that platform. That translates directly into money and directly into jobs and 

really into safety. These new engines will be safer, and the environment, because they will be more efficient. 

It is all intertwined in the efficiency of the system to get that 

product out the door. 

Dr. BUCSHON. Do you think the inspection process and the approval process is causing some difficulty with keeping American 

competitiveness in place worldwide? 

You talked about the expansion of other countries, getting involved in the aviation industry and the regulatory climate in their 

area of the world, maybe the EU or other places. 

Do you think we are at the point where it might be inhibiting 

America’s competitiveness worldwide in your industry? 

Mr. BUNCE. Yes, sir. I do think it impacts us. When you have 

some of our manufacturers in the U.S. looking to actually do their 

certification program in another country, because they can actually 

have it being done faster or more efficiently, that concerns me, because those jobs will go there. 

At the same time, when you are looking at this program and the 

competitiveness itself, we are a global industry, and because 50 

percent of the market is here in the U.S., we want people to be able 

to relocate. 

I am very proud of the fact that a lot of international manufacturers are building facilities here in the U.S. right now, whether 

30 

you are talking North Carolina, Florida, or others, because they 

look at this market and say ‘‘we want to be close to the market,’’ 

and we want to encourage that by making it very efficient for them 

to be able to get through the process. 

Dr. BUCSHON. Mr. Bahrami, do you have any comments about 

that with your members, on both the costs and the delays, perceived delays, and also the competitiveness aspect of it? 

Mr. BAHRAMI. Sir, any time you have a delay in a program, it 

is going to be costly, whether the source of that delay is the FAA 

or some technical challenges in the program. 

From our perspective, what we are trying to do is trying to have 

these collaborative relationships, real dialogue, communication, between the manufacturers and the regulators, to be able to plan 

things. 

Absolutely, if you have delays, it will cost quite a bit of money 

because you cannot stop everything and let people go and bring 

them back. Those are things that you just cannot do when you run 

a program that runs anywhere from 3 to 8 years. 

Dr. BUCSHON. Thank you. I yield back, Mr. Chairman. 

Mr. LOBIONDO. Mr. Davis? 

Mr. DAVIS. Thank you, Chairman LoBiondo. Thank you all for 

being here today. I should not use all my time. I just have a quick 

question and a comment for Director Baker. Thanks for your role, 

too. 

For President Bunce, I am sorry. Thank you for being here today 

and reminding us in your testimony how vital general aviation is 

to our economy. 

I was actually making notes while this hearing was going on. 1.2 

million jobs generated by the general aviation industry. It is important that we do not forget that. 

There seems to be a commitment from the stakeholders, and as 

your testimony indicates, these changes can have their challenges. 

I want to note in your testimony, too, and highlight the fact that 

you have several cases of smaller aviation businesses faced with a 

loss of financing and possibly going out of business because of the 

inability of the FAA to act. 

I know we have gone over the FAA process, the certification process. I want you to speak to the importance of congressional oversight in this process as part of this team to achieve our safety 

goals. 

Mr. BUNCE. Thank you, Congressman Davis. I want to put it into 

something mentioned on the first panel, the Small Airplane Revitalization Act. This really was to make certification something that 

works in the 21st century. 

We developed a bunch of rules back in the 1990s. We promulgated about 800 rules in a very short period of time and basically 

certified very simple aircraft to the highest common denominator 

of very complex jets. 

What did that do? That stifled innovation. That hurt a lot of companies out there, but it also made regulations become stale. 

So what you all have done is help the FAA push the process forward, because left to their own devices, I think the FAA supported 

everything we were doing, but when it got into the FAA legal chanVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00040 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
31 

nels and their decisionmaking, they all said no, this is too hard to 

do. 

What you have done with this legislation is to say no, you have 

to do this, and this is the right way. You get international regulators together to have a common set of standards, you have them 

meet periodically to keep the rules fresh and keep pace with modern technology, and what do you do? You stimulate innovation to 

that process, and you are saying, by the way, get it done by the 

end of 2015. 

I cannot thank this committee enough for the support you have 

given us there. We can do more, and the oversight that this committee and your colleagues in the other body also have, to be able 

to hold the FAA’s feet to the fire and say let’s make progress. This 

is important to us. It is important to safety and important to jobs. 

I just cannot overemphasize the importance of it. 

Mr. DAVIS. Thank you, President Bunce, and thank you, all. I 

yield back. 

Mr. LOBIONDO. The gentleman from Tennessee, Mr. Duncan. 

Mr. DUNCAN OF TENNESSEE. Thank you very much, Mr. Chairman. I can tell you that I appreciate your holding this hearing and 

calling attention to this problem. Apparently, there is really a serious problem at the FAA in the certification process. 

I read in the inspector general’s report that there are now, across 

the country, 1,029 new certification applications pending, and it 

says of these awaiting certification, 138 applicants have been delayed for more than 3 years, with one applicant waiting since August of 2006. 

I am sorry, I was at another committee hearing and did not get 

to hear all of your testimony. I read in Mr. Bunce’s testimony for 

instance, that according to one aircraft manufacturer, a delay in a 

large certification project cost over $10 million a month, and it says 

this is just one project. You can imagine the compounding effect 

when carried across the whole industry over a number of months. 

Additionally, we have had several cases of smaller aviation businesses faced with the loss of financing and possibly going out of 

business because of the inability of the FAA to act. 

And then I read in Mr. Hendricks’ testimony about one commercial air charter operator who had to spend $25,000 to secure FAA 

approval to move an aircraft on his air carrier certificate from one 

FAA region to another. 

It seems to me there is a real problem there. In fact, I wish, Mr. 

Bunce and Mr. Hendricks, you would get together and give us some 

specific suggestions as to how we can speed this entire certification 

process up. 

I know there is some variations, depending on what types of 

things are being requested to be certified, but there are surely 

ways to do this. I can tell you, it is not a money problem. The FAA 

is getting plenty of money. They should be handling these certifications much, much faster. 

In fact, I think if they started giving out some bonuses to move 

some things faster, they probably would see a lot of this backlog 

wiped out pretty quickly. 

32 

It is just not a good report. When I read Mr. Hendricks said 89 

percent of NATA members responded that their businesses have 

suffered due to inconsistent interpretation of regulations. 

I know the two of you are in a difficult position because you have 

to work with FAA so you cannot be too critical, and because there 

might be repercussions, but do either of you have anything you 

would like to add to what is in your testimony? 

Mr. HENDRICKS. Thank you, Congressman Duncan. I would like 

to offer a couple of views, if you do not mind. 

Mr. DUNCAN OF TENNESSEE. Sure. 

Mr. HENDRICKS. You know very well with your experience, we 

are a highly regulated industry, unlike any other industry in the 

United States. 

Mr. DUNCAN OF TENNESSEE. Yes, sir; I know. 

Mr. HENDRICKS. When entrepreneurs make the decision to start 

a small business out there, one of the pieces of the framework that 

they use to develop their business model is how we are regulated. 

During the recent Government shutdown, we saw what happens 

when the regulator nearly disappears. We had commerce come to 

a grinding halt in many cases. Pilot qualifications expired, instructors that could help with those pilot qualifications, their qualifications expired. We had aircraft that were unable to be transferred 

between businesses because the FAA aircraft registry office was 

closed in the shutdown. 

I do not want to focus on the shutdown, but it shows you how 

dependent we are on our regulator, and why the oversight of the 

Congress and this subcommittee is so critically important to our 

members. 

One of the things we subscribe to very strongly, and Dr. 

Dillingham referred to this in his remarks as did Director Dorenda 

Baker, is that we must take a systems safety approach through 

safety management systems, very highly structured, risk-based approach, complete buy-in by the regulator, by labor, by management, 

and moving forward on how we evolve the system more efficiently 

than we have done. 

We have seen success with this in the industry and we would 

like to see this process and this culture change accelerated within 

the FAA as well. 

Mr. DUNCAN OF TENNESSEE. I did not want to get into this but 

I will say on our side, we voted four times to open the entire Government back up with just a simple delay of Obamacare for a year, 

but we do not need to get into all that. 

Mr. Bunce? 

Mr. BUNCE. Congressman, I would just add that the workforce 

that Mr. Perrone represents, they are great people, they are sharp 

people, they want to learn, they want to be with us on this journey, 

but I think they are trapped by the bureaucracy in a lot of ways. 

We are in a very risk-averse setting where they are very constrained by the guidance that is coming down to them. It is very 

important that they get clear guidance of what they are allowed to 

do and what they cannot do, but also that they can take confidence 

in what some of the other FAA inspectors already approve. 

Let me give you an example. Several years ago we went to this 

thing called RVSM, reverse vertical separation minimums, so it alVerDate Aug 31 2005 10:57 Jun 16, 2014 Jkt 000000 PO 00000 Frm 00042 Fmt 6633 Sfmt 6633 P:\HEARINGS\113\AV\2013\10-30-~1\85301.TXT JEAN
33 

lows us up at the high-altitude airspace to fly closer together 

vertically. 

When we give an aircraft and sell it to a customer, we have to 

show it can do this, that the avionics is very tight, the tolerances 

are very specific, to be able to fly there. But then we had a process 

where that was the certification side, but then we had to reprove 

the aircraft could do that on the flight standard side. 

That side was not trusting what the other side did. Then within 

the flight standards—we just had an incident a few months ago 

where on a telecon, they were discussing RVSM and the capability 

to certify aircraft to fly there, and all of a sudden, an FAA inspector chimed in over the phone and said ‘‘how can I trust what the 

FAA inspector did in another region, how can I trust that he did 

that right?’’ All of a sudden, there was silence in the room, and 

people got it then, right away, that we have inspectors, because of 

the guidance, are not able to trust what another FAA inspector has 

done. 

That is just debilitating for industry. What happened is FAA 

leadership listened to this, there was industry in the room, there 

was a lot of discussion, and now there is going to be some very 

clear guidance put out dealing with RVSM and what should be expected. 

That is what we are asking more of and that is why this oversight is so important, that we have metrics available and that we 

make sure the FAA is putting implementation guidance to leverage 

these resources properly and use delegation. 

Mr. DUNCAN OF TENNESSEE. My time has gone way over. Thank 

you very much, Mr. Chairman. 

Mr. LOBIONDO. Mr. Meadows? 

Mr. MEADOWS. Thank you, Mr. Chairman. Thank each of you for 

coming today. I want to focus a little bit on the bureaucracy and 

what was just touched on. I am troubled at times when I hear 

about the need for regulators on a daily basis. That is counterproductive to a vibrant economy. 

At the same time, we obviously need a safe environment, and the 

airline and general aviation industry has been extremely safe. It is 

highly publicized when there is an accident, but when you look at 

it compared to a number of other transportation modes, we have 

a great track record. 

The—administrator for the FAA, I have been very direct in some 

of my questioning, but yet at the same time I believe him to be a 

person who wants to do the very best for the industry. 

And so Mr. Hendricks, I would ask you, specifically what would 

be the top three things that we could do to get rid of some of the 

bureaucracy, to speed up the process, to make sure we have a competitive aviation business? Because if it is not us, it is going to be 

somebody. 

I come from North Carolina. We love aviation in North Carolina, 

but what would be the top three things that you would recommend? 

Mr. HENDRICKS. Thank you, Congressman Meadows. I actually 

would give you the top choice rather than the top three, and it 

would be let’s accelerate the movement towards safety management systems at the FAA and drive cultural change. 

34 

The industry is already rapidly moving in this direction, the airline industry is very mature in their safety management system 

processes. 

Former Director of Flight Standards, John Allen, spoke very frequently about the role of the regulator changing in the future because of the cultural change that is taking place at the regulated 

parties, and it needs to take place at the FAA. The FAA knows 

this. The Administrator will acknowledge this. It is a proven system. It is very thorough. It requires everyone to take ownership of 

the identified risks in an operation or a certification process, and 

we believe this is the way of the future for the FAA and will allow 

them to be much more agile in their oversight responsibilities. 

Mr. MEADOWS. All right. I would ask you for the record and not 

to respond right now, is to give us three areas that we can get rid 

of. Because what we do is we add layer upon layer upon layer. 

Most of us in this room have flown, and we still get—and this may 

be a poor example, but every time we get on a commercial airline, 

they are still showing us how to put our safety belts on. You want 

to go at what point is there a market saturation on that training. 

I would assume in this particular area, you can identify three 

areas that we just added layers, so I would ask you to respond to 

the committee on that, if you would. 

Mr. HENDRICKS. I would be happy to do that. Thank you. 

[The information follows:] 

Three actions the Federal Aviation Administration (FAA) 

can take to improve safety and help our industry compete 

in the marketplace by streamlining the FAA processes: 

1. SMS—The FAA should leverage the Safety Management Systems being implemented throughout the industry. The FAA could reduce direct involvement and 

could rely on an approved SMS regime to identify and 

mitigate risks so that overall safety levels are improved 

with more efficient FAA oversight activities. Reliance 

on SMS principles should permit expanded use of delegation authority without requiring additional FAA personnel for oversight. 

2. The FAA should develop and publish directions to the 

inspector workforce through handbook guidance that 

specifically requires approvals from one geographic region to be approved in every region. This procedure 

should require that any approval deemed not ‘‘transportable’’ be reviewed at a higher level to determine the 

root cause. Therefore, this procedure could dramatically 

improve standardization by automatically elevating differences in policy interpretation so that operators would 

not be reluctant to complain or fear retribution. 

3. The FAA should continue its effort to provide a single 

platform for all regulations, guidance materials and 

legal interpretations for both Aircraft Certification and 

Flight Standards. A critical aspect of this effort is that 

much of the guidance is outdated and should be modernized so that it will be clearer to both FAA inspectors 

35 

and to the operators and manufacturers. A consolidated 

library of standardized, modern and clear guidance will 

support more consistent regulatory interpretation and 

is key to streamlining FAA processes. This project will 

only be enabled if Congress protects necessary funding 

and provides adequate staffing. 

Mr. MEADOWS. Mr. Bunce, you mentioned in your testimony 

about the certification process using engineering experts, that they 

are the same with the traditional, I guess, certification, and that 

was problematic. 

Can you expand on that a little bit, the difference, why using 

those same engineers would be a problem? 

Mr. BUNCE. If you take an aircraft certification office, Congressman, that has been working traditionally in the old model, and all 

of a sudden you say convert to this new safety system management/safety oversight, there is resistance to change. That is just 

human nature. People do not want to change. 

What does an engineer want to do? God love them, they want to 

be down there designing, working on the intricacies. It is very 

tough to be able to say no, your job now is to manage the whole 

safety processes network and let this company that has had a very 

mature record of developing aircraft, or engines, avionics, whatever 

it is, go and do the day-to-day sharp pencil engineering, and you 

make sure their processes are safe. That is cultural. 

Mr. MEADOWS. So they have more of a broader brush overarching 

engineering responsibility where specifically you allow the stakeholders and so forth to do the processes that go into that? Is that 

what you are saying? 

Mr. BUNCE. Absolutely. Sometimes that may be appointing different people to go do that expertise. This may be the sharpest engineer in one specific area. You may want to move that engineer 

and say go work on this project for this company that it is brand 

new for, and put another person into that safety oversight. 

In your great State, Honda, this is their first foray into jets, this 

is a complex program. We want to make sure they have all the resources they need to be able to get that product to market quickly, 

because they are spending a lot of money. I am sure you have been 

to that facility. It is tremendous. 

They are going to employ a lot of people. The sooner they start 

delivering jets, the sooner they start ramping up that employment. 

We want them to have the resources, but a mature company that 

has been doing it for a long time, let their processes be overseen 

by a safety management system. 

Mr. MEADOWS. I appreciate the Chair’s indulgence and I yield 

back, Mr. Chairman. Thank you. 

Mr. LOBIONDO. Thank you, Mr. Meadows. I have some additional 

questions that I am going to submit for the record. Unfortunately, 

we are up against a little bit of a time constraint, but I want to 

thank the second panel, encourage you to keep thinking ideas to 

bring to us. Rick and I want to stay very much engaged with trying 

to see how we can further get this on a positive track. 

The committee stands adjourned. 

[Whereupon, at 12:01 p.m., the subcommittee was adjourned.] 

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