Aerospace Industries Association of America, Inc. 

1000 Wilson Boulevard, Suite 1700 Arlington, VA 22209-3901 (703) 358-1000 www.aia-aerospace.org

March 7, 2011

Aerospace Industries Association/Strategic Standardization Forum for Aerospace

RESPONSE TO FEDERAL REGISTER REQUEST FOR INFORMATION

“Effectiveness of Federal Agency Participation in Standardization in Select Technology 

Sectors for National Science and Technology Council’s Sub-Committee 

on Standardization”, Docket No. 0909100442-0563-02

The Aerospace Industries Association (AIA) appreciates the opportunity to respond to 

the National Science and Technology Council’s Sub-Committee on Standards regarding 

their request for input concerning the effectiveness of Federal agencies’ participation in 

the development and implementation of standards and conformity assessment activities 

and programs. The aerospace industry’s long partnership with government agencies 

(both civil and military) for the development of standards is one of the key reasons for 

the US’s dominance in aerospace. Ensuring strong, responsive standards systems is 

critical to the success of aerospace products and programs. This response was 

developed by our Strategic Standardization Forum for Aerospace (SSFA) and 

represents the collective input of the many companies and standards developing 

organizations that constitute this large and nationally important industry sector.

The SSFA welcomes the opportunity to discuss these issues and others with the NSTC 

Sub-Committee on Standards or any government entity seeking input on policies or 

processes related to standards.

Effectiveness of the methods Federal agencies have used to engage in 

standards-setting activities

Whenever possible, the aerospace industry encourages government agencies to work 

with industry to set applicable standards to ensure that impacts to design and 

manufacturing, and operations are considered along with safety and health. 

In instances where the government is the customer or where a government agency has 

regulatory responsibility for public health, safety, or the environment, the activities that

seem to have been most successful were when the end performance or the acceptable 

limits were specified and then industry was allowed to work with government 

representatives in industry standards setting venues to determine the best way to meet 

the specified needs. 
AIA response to Sub-Committee on Standards RFI

Docket No. 0909100442-0563-02

Page 2

Effectiveness of Federal agencies coordination with the private sector

AIA is looking to the NSTC Sub-Committee to help with more consistent interpretation 

and policy implementation across Federal agencies relative to government participation 

in standards development. Conflicting agency policies on membership, inconsistent

support of dues and travel costs, and the wide variability of guidelines related to the 

ability of federal employees to take on leadership roles with technical committees or 

even in the governance structure of standards organizations, leads to confusion and lost 

opportunity for the public sector to be an equal and effective partner in standards 

setting. 

AIA strongly encourages the NSTC Sub-Committee to clarify, on a government-wide 

basis, policies that would help agency stakeholders to understand the rules of 

engagement. Inconsistent application of the tenants of the National Technology 

Transfer and Advancement Act (NTTAA) and its implementing instructions delays the 

timely development of standards relevant to the needs of federal agencies. Without 

competent government employees participation not only at the technical committee 

level, but at the standards governance level within standards setting organizations, 

private industry is unable to effectively partner with the public sector on critical 

standardization initiatives nor ensure that the standards systems meet the collective 

needs of both government and industry.

Adequacy and availability of Federal resources

The US aerospace industry depends on the strong infrastructure of standards setting 

that government agencies bring to the public-private partnership. Certainly one of the 

cornerstones of the superiority of the US’s defense, space and civil programs is the 

existence of the Defense Standardization Program Office and the system of Military 

Specifications and Standards. AIA encourages the Department of Defense and other 

government agencies to continue to support the robust set of government technical 

standards that define our defense and space platforms and programs as these same 

technical standards are also the major source of data used for the private sector, e.g. 

civil aircraft, commercial space systems, etc. AIA also encourages the DoD and other 

government agencies to grow and expand their efforts to work together with industry in 

voluntary consensus standards setting venues whenever possible to develop the 

industry standards that define our defense and space platforms and programs.

At the same time, AIA encourages the NSTC Sub-Committee to help government 

agencies to recognize that the development and use of industry standards is not free. 

Just as the internal development and distribution of government standards is not without 

cost, participation in the development of industry standards and then the subsequent

purchase of the standards requires resources. Federal agencies need to budget for the 

time and travel of government experts to participate in the setting of standards. They 

also need to budget to purchase the resulting standards. AIA would point out to the 
AIA response to Sub-Committee on Standards RFI

Docket No. 0909100442-0563-02

Page 3

NSTC Sub-Committee that managed correctly, participation with industry, pursuant to 

the NTTAA and OMB Circular A-119 directives, is a strategic investment in the 

standards which can ultimately control costs and improve quality and safety of 

government purchased products and services.

The aerospace industry would also encourage government support for more 

participation by technical experts from government in standards setting activities and 

earlier communication of standards needs. This would ensure that the public sector 

technical requirements are met in a timely manner and in close collaboration with the 

private sector. The aerospace industry would also like to encourage greater government 

support for the National Institute of Standards and Technology (NIST) in carrying out its 

assigned roles and responsibilities as expressed in the directives of the OMB Circular 

A-119. 

Other issues that arise and are considered during the standards setting process 

which impact the process, and the timeliness, adoption and use of the resulting 

standards.

Federal agencies that maintain a standards office/function staffed by full-time standards 

professionals whose careers are independent of any single administration, are those 

which are best able to develop, nurture and maintain positive public-private partnerships 

as well as forge strong interagency standardization networks. It is difficult for the private 

sector to work with a Federal agency that does not have a standards office/function 

staffed by individuals with a strong understanding of the value of standards, codes, 

conformity assessment process and the standards systems used by US industry.

AIA would encourage the NSTC Sub-committee to work with the Standardization 

Executives to ensure that each agency develops and maintains a strong core office of 

professionals dedicated to helping coordinate standardization activities between 

agencies and with the private sectors. These government standards professionals 

should be encouraged to engage with and participate in standards setting organizations 

at the governance and policy level to help foster a stronger partnership.

Additionally, AIA would like to emphasize the connection between innovation and the 

protection of intellectual property rights contained in standards. The US Government 

should consider ways to ensure that standards organizations have IPR policies which 

meet the requirements established by OMB Circular A119. However, AIA would urge 

the US Government to avoid regulations or preferences directed at a particular IPR 

policy, noting that no single policy would be appropriate across all standards types and 

in every standardization instance.
AIA response to Sub-Committee on Standards RFI

Docket No. 0909100442-0563-02

Page 4

Summary

Our nation’s economy and national security rest on the strength of the aerospace 

industry and its products, which in turn owes its strength to the robustness and flexibility 

of the standards systems it uses. The ability to collaborate with government agencies 

to identify and develop the standards necessary to support this vital industry is integral 

to the continued success of US aerospace superiority. AIA and its members welcome 

the opportunity to continue to search for ways to improve this proven public-private 

standards partnership and to communicate and share requirements in standards setting 

venues in order to work together to respond to civil and defense priorities. 

The aerospace industry not only welcomes, but requires, the participation of 

government experts in standards development activities and together we will continue to 

create standards that can be adopted and relied on by Federal agencies. AIA welcomes 

the opportunity to work with the NSTC Sub-Committee on Standards and with entities 

such as NIST and ANSI to continue to build upon the success of the NTTAA. We 

appreciate the opportunity to provide these comments and we look forward to being a 

part of the ongoing dialogue between members of the Sub-Committee and other key 

stakeholders from the standardization community.

For more information, please contact:

Christopher Carnahan

Director, Standardization

Aerospace Industries Association

1000 Wilson Blvd., Suite 1700

Arlington, Virginia 22209 USA

T: 703-358-1052 F: 703-358-1152

chris.carnahan@aia-aerospace.org