Red Tape

My father was a big man, straight from the old sod. He was a lot smarter than I and a card-carrying survivor of the depression years.


My father was a big man, straight from the old sod. He was a lot smarter than I and a card-carrying survivor of the depression years. One bit of advice he gave me one day, 35 pounds ago, went like this: "Son, if you want job security, attach yourself to an unsolvable problem, work diligently every day trying to solve that problem, then retire." So, following my father's lead, it is no great secret that today I earn my living as a bureaucrat in Washington. So here I sit alone, in a small, unventilated room in front of an old GSA computer that has a desk footprint the size of a Volkswagen bug and a memory almost as bad as mine. Every working day I grind out pages and pages of FAA policy, which of course you know it by its nom de plume: red tape.

Now the intent of the policy that I write is to describe methods or procedures on how the FAA field offices will encourage compliance with a particular Federal Aviation Regulation. New policy is needed because new regulations are written with a broad brush in order to address every possible aviation situation. At the same time the broad brush approach conveniently allows an FAA lawyer some wiggle room if they have to go to court to defend the rule.

But sometimes this broad brush approach to a rule is totally unworkable in the field where the industry demands a narrow, focused standard to follow. Therefore, a narrow, focused FAA policy must be written to address this industry's need. Sometimes, amazingly enough, a new FAA policy must be written for an old rule. This is because technicians in general are such an enterprising and inventive group of people that are always coming up with new ways to get around older FAA policy for older rules. So with new policy needs identified, I once again get to turn the old computer on, watch the lights in the ten-story headquarters building dim a bit, and begin pounding on the key board with blunt, fleshy fingers.

So, did I find job security? Did I find the unsolvable problem my dad told me to attach myself to? Well, I figure that as long as airplanes fly we have a continual need for new FAA policy, and it stands to reason that a continued need for writers of new FAA policy also exists. So what we have here is a continued need with no permanent solution. If we have no permanent solution, then that constitutes an unsolvable problem, ergo, bureaucratic job security! Dad would have been proud!

My latest attempt to achieve bureaucratic immortality is Flight Standards Information Bulletin for Airworthiness: # 98-03 titled "Instructions for continued Airworthiness for Major Alterations Approved under the Field Approval Process." It is a product of last year's long and painful discussions in the bowels of this building, deliberating the Part 135 single engine Instrument Flight Rules (IFR) passenger carrying rule. During the mandatory name calling and cussing phase of developing the rule we found that no FAA policy or instructions existed to ensure that major alterations, such as a stand-by electrical system or vacuum system required by the new rule and installed under a field approval, were going to be maintained to a published standard.

In other words, under existing policy, a FAA inspector could sign the field approval block 3 of FAA Form 337 for one of three kinds of field approvals. The most common field approval granted is approving the data only. The second kind of field approval is approving the installation by physical inspection or testing. The third kind is approving the data for multiple installations by the same modifier. However, a technician or IA performing an inspection a year later has nothing to refer to when performing an inspection or maintenance on the new equipment that was installed under a field approval.

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