Balance Point—Safety Vs. Cost

October 16, 2013 by Bruce Landsberg

iStock_000001618028XSmallBetween the sequester and the government shutdown, the endless summer of taxpayer and user funding has dried up. By the time you read this, the debt-limit crisis will be deferred or exacerbated. Mark Baker, AOPA’s new president, noted on several occasions during last week’s Summit that the FAA has some tough choices to make.

The FAA has many essential roles in the functioning of the national airspace system, aircraft certification, and safety efforts. But there are others that merely add to paperwork and payroll.

Here are a few items that I’d like to see the leadership address in collaboration with the users:

  1. AOPA and EAA’s petition for the third-class medical exemption should be approved. The number of annual pilot-incapacitation accidents is down in the “noise level.” That’s a technical statistical term meaning we can hardly measure it! Several friends, who also happen to be aviation docs, have openly admitted their inability to prognosticate when a pilot will physically dope off in flight. More than a few mentally drop off line in the judgment department—and we can’t predict that either!

    During the last nine years, the light sport aircraft (LSA) “experiment” in medical self-certification has been a success by any measure. Lighter-than-air and glider pilots have always had this privilege and guess what? No carnage. The medical certification process costs the FAA millions and the pilot community many more millions, and it provides little safety benefit. Time for a change?

  2. Part 23 rewrite—lower the cost of GA aircraft both for initial construction and for retrofit. Mods to old aircraft today must meet current specs even though the proposed modification might be a huge improvement over original equipment. But if the new product does not quite measure up to the current rule—the perfect being the enemy of the good—no dice. The current GA business model for light aircraft does not work. The Cessna 172 should be renamed the C-374K, which is about what a new one costs these days. Cessna is not alone and there are many reasons why the costs are high, ranging from product liability to excessive overhead. But we can start with some common sense on design and retrofit. Time for a change?
  3. Stop the re-issuance of flight instructor certificates. I’ve been confused for decades as to why the FAA felt it necessary to reissue flight instructor certificates every two years. There is no quibble with the requirement for a biennial CFI refresher but we don’t need a new certificate. It should be handled like pilot currency. You may not act as a CFI if you haven’t attended a flight instructor refresher course (FIRC) or otherwise renewed your certificate, but we don’t need a new piece of plastic to verify that someone is current. A decade ago we estimated that thousands of hours of FAA time went in to this with no measurable benefit to safety. Time for a change?
  4. Right size the number of towered airports. Let’s drop the charade that all or no towered airports are expendable. There are legitimate criteria that go beyond several air carrier flights per day, or that a location is GA only, or that it’s a contract or federally staffed tower. Activity, traffic mix, and complex airspace are starting points for a reasonable discussion. And some of the big airports probably don’t need staffing around the clock. Most places except the freight hubs could close up at midnight and reopen at five a.m. Time for a change?
  5. Your turn to add or subtract from the list. It’s a guarantee that services will be cut—seems like we should be at the table to say what’s needed and what we can do without. Where can the industry or pilot community pick up where the FAA leaves off?


Bruce Landsberg
Senior Safety Advisor, Air Safety Institute

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  • M. Ross Shulmister

    Either minimize medical deferments, or designate local private physicians who can rule on deferments from FAA medicals (a “senior” or reviewer physician). An examining physician is in a far better position to evaluate medical conditions than a bureaucrat with an MD license sitting at a desk thousands of miles away. If two different local FAA physicians concur that a pilot is medically safe to fly, why run the process through this bureaucratic nightmare (which is often automatic, based on criteria which is basically “one-size-fits-all”)?

    The current process is cumbersome, and can take 3-6 months, and can result in grounding a pilot for that time while the paperwork moves slowly through the system.

    The FAA is convinced I have diabetes, even though a specialist tested me and submitted lab results which show I do NOT.
    _ _ _

    I concur with your other proposals, BUT where a municipality (or government entity) owns a revenue-producing airport, let the locality support tower functions from airport revenues. No need to close towers that are not funded by the FAA, “to save money” (or to generate pain during a government shutdown). The FAA can still determine whether a tower is mandatory.

  • Mike Mahoney

    If the 3rd class medical is going to be waived for, last I heard, flying a/c under 180 hp, fixed gear, 2 px, then why can’t we go back to the 3 year 3rd class for over 40 years of age pilots for the other a/c in the fleet?

  • John Miller

    This is a letter sent to my district representative in Spokane WA

    I heard today that the Department of Transportation is in the process of closing down 149 air traffic control towers and today I was made aware of a huge waste of money also in the Department of Transportation. I learned today that each Federal Standards District Office (FSDO) is required to send its local flight inspectors to Dallas for currency training. This involves some 800 pilots being sent from their home territory to Dallas at least once a year and sometimes more often, at taxpayer’s expense.

    Heretofore this currency requirement was being handled in each inspectors home environment using local aircraft and local pilots with the effect of being able to work with local business, view the quality and airworthiness of local aircraft and in general support the local community.

    In my view sending inspectors to Dallas makes no sense. It is hard to imagine any thinking person coming up with the Dallas plan. Pilots are gone from their home territory for I estimate three to five days where they are provided room and board and if the weather is such that they can’t get the training they must return to try again. If someone with the figures would put pencil to paper my conservative guess is that they would come up with multiple millions.

    I talked with Zach in your Spokane office and advise I would be sending this letter and hope that you would ask Zach to do some investigation into what I perceive to be a very costly and unnecessary program.

  • Michele

    If the entire system of Ramp Checks were ended, no one would care, or even notice.

    I had the dubious opportunity to be the object of one last year.

    My first impression was of a man slouched down in a parked car that looked suspicious enough that I was about to call 911 and report him.

    But as I opened the hangar, he approached. And luckily for him, he identified himself as FAA before getting to close.

    He wanted to see several items.

    1 – Pilots license. Well that sounds fair enough. BUT, that plastic card was issued sometime in my lifetime and proved nothing of my currency that day. It well could be that I haven’t flown in a decade.

    2 – Medical certificate. Obviously that should make the flight more safe, right? That piece of paper means I peed in a cup and read an eye chart some time within the past two years. Possession of the paper card doesn’t guarantee that I didn’t have a heart attack last week.

    3 – Airworthiness Certificate for the plane. That should give everyone a warm fuzzy. BUT, this one is the most ironic. The airworthiness certificate is granted on the day of MANUFACTURE. It doesn’t mean the plane has even had an oil change since 1968.

    So in review, the nice FAA man check some boxes on his form and went skulking around for the next pilot. I, on the other hand, was now 15 minutes late, and slightly peeved as I climbed in my Skyhawk and prepared to take to the skies.

    How did this “safety program” make the flight more “safe”?

  • Ron Adams

    Rescind mandatory aircraft reregistration.

    This requirement has no practical purpose. The FAA already has an aircraft database that is beyond their ability to manage. Giving them more ‘data’ to manage every three years can only exacerbate the problem.

    Among other positive benefits, this action will:
    Shrink bureaucracy
    Save money
    Prevent issues arising from:
    owner forgetfulness/procrastination (which isn’t a crime)
    bureaucratic delays (which should be)

  • john

    1. The 3rd class physical should be eliminated completely for private pilots not just limited categories.
    2. The FAA needs to get out of the certification of accessories inside the cockpit. Provide a performance spec that the manufactures need to meet.
    3. The FAA need to get out of the small aircraft certification business again have a performance spec and let the manufactures innovate without the astronomical cost of certifications.
    4. Small currently certified aircraft used for personal flying should fall under the same rules as experimental aircraft for maintenance and upgrades.
    5.Close some towers shorten hours at others a very good point.

  • Ron Rapp

    Great list, Bruce. Even slight headway in making flying easier or less expensive would be a huge boost for morale in the pilot community. Oh to see the tide turn even a little…

    Keep up the good fight.

  • John

    Bruce, as usual you have presented some interesting alternatives to address a current (and continuing) problem. I agree with each of your five points as a starting point to fit the FAA’s available budget to the work at hand. Most of these are, however, chickenfeed. You need to move beyond pilot centric issues that rally the AOPA membership and initiate a discussion of some big ticket issues. Here are some examples: What about airport design factors that require very expensive studies to initiate, more expensive engineering to design, and fabulously expensive construction contracts to implement? I submit that the FAA would save more money should Congress revisit the “Prevailing Wage” concept, streamline the processes for airport plans and design work required for reconstruction and new construction, eliminate the “Essential Air Service” (EAS) subsidy, and take other measures which would reduce the burden of cost for compliance FROM the users as well as the bureauacracy. Other Congressional actions could be to allow the FAA to have a much stronger role in local airport environment land use planning. Billion$ have been, and continue to be spent to mitigate easily forseeable impacts to subdivisions, schools, day care centers, and other incompatible devlelopments located in “noise sensitive areas” or “crash zones” adjacent to airports. How about the redundant VORS, and the remaining NDBs? Then, there’s the elephant in the room called ADS/B… We could go on, and on. Until AOPA and our other alphabet soup aviaiton organizations move beyond their parocial interests the FAA’s inability to rationally reduce its budget, become more efficient, and even be more ‘user friendly’ won’t get off the ground.

  • Duane

    A lot of promising suggestions in Bruce’s post and the subsequent comments.

    As a matter of process, few to none of these actions are likely to ever see the light of day without specific Congressional direction to the FAA as enacted into law.

    The FAA exists in order to exist. It is like any other government agency – it gets created then spends the rest of its lifetime perpetuating itself, making sure it stays in business and grows. The more regulatory burden it creates, the more justification for increased agency funding.

    This would be a great time to approach the Congressional Aviation Caucus, as AOPA (and allied with other aviation interest groups) and develop a specific package of comprehensive FAA reform legislation. It is far past time for a complete rewrite of all GA affecting rules.

    The data are already in existence to prove that most GA accidents, especially fatal accidents, do not result from failures of aircraft or from in-air medical emergencies, but rather come from strings of pilot error that virtually none of the existing private pilot airman certification, medical certification, and aircraft certification programs can affect in any meaningful way. All these programs do is add great cost to both commercial products and to the pilots and aircraft owners.

    Call your Congressman and Senator and demand regulatory reform at FAA. Absent a law directing such reform (such as already is in force directing the current Part 23 aircraft certification review), none will be forthcoming.

  • Bruce Landsberg

    Good and thoughtful comments. Will pass them along to the gov’t affairs team. Please send in your thoughts. Now is the time that we may really be able to make a difference.

    Re airport design, in the early 1960s Ohio embarked on puttin an airport in very state using their highway dept to build a “mile of road” that was the runway. Worked great for light aircraft. Runway lights? They used traffic light bulbs. We need some fresh thinking.

  • Brandon Savage

    I believe that we should eliminate the 3rd class medical entirely. Reducing the cost and oversight required for the creation of GA aircraft components should also be included. There’s no reason I should spend $50k for a new O-540, when if this engine was in a car I could probably buy the same parts for $10K installed.