FAA MUST NOT OUTSOURCE APPROACH PROCEDURES

The Professional Aviation Safety Specialists, AFL-CIO (PASS) represents approximately 11,000 Federal Aviation Administration (FAA) employees in five separate bargaining units throughout the United States and in several foreign locations. ). The Professional Aviation Safety Specialists, AFL-CIO (PASS) represents approximately 11,000 FAA and Department of Defense employees in seven separate bargaining units throughout the United States and in several foreign countries, including flight inspection pilots, mission specialists and flight procedures development specialists in Aviation System Standards (AVN); examiners in the FAA’s Civil Aviation Registry; and support staff.

Flight procedures and flight inspection employees in AVN are charged with developing, evaluating, certifying by flight inspection and maintaining the more than 18,000 instrument flight landing and takeoff procedures for every major and municipal instrument-capable airport across the country. The development, implementation, flight inspection and maintenance of flight procedures supporting this growth requires the proper interpretation of a complex series of computations, measurements and modeling standards, strict compliance with diverse criteria, extensive coordination with multiple stakeholders, and the frequent adaptation of procedures in an ever-changing aviation environment. Current administration regulations and directives provide for third-party development of special-use operational and approach procedures, which are not fully integrated into the NAS. As opposed to special-use procedures, which do not have to be fully integrated into the NAS, public-use procedures are completely integrated into the system and protected by controlled airspace. However, over the last few years, the FAA has been pressured to contract out the development of public-use procedures. AVN employees represented by PASS have expressed concern with the FAA’s ability to fully and safely integrate third-party developed procedures into the system since a single procedure cannot just be added into the system without considering the affect such an addition will have on the NAS as a whole.

PASS believes this safety-critical work to be inherently governmental and should not be outsourced to private vendors and is concerned that the FAA has not established sufficient mechanisms and staffing to provide safety oversight of any third party involved in developing any public-use procedure.

Congressional Action Requested

PASS fully supports language contained in Section 208 of the FAA Reauthorization Act of 2009 (H.R. 915), which requires the Department of Transportation Inspector General (IG) to review third-party approach procedures development. Unfortunately, the FAA Air Transportation Modernization and Safety Improvement Act (S. 1451) contains conflicting provisions regarding the acceleration of RNAV and RNP. Section 510 of the legislation promotes the contracting out the development of flight procedures and flight inspection programs and outlines an arbitrary number of procedures (200) to justify contracting out this work. This language conflicts with Section 314, which includes procedures and processes for accelerating and achieving RNAV and RNP and incorporates a cost-benefit analysis for third-party usage. PASS fully supports the language in Section 314 and finds it to be mutually beneficial to all stakeholders involved in NextGen and requests that Section 510 or any language that calls for third-party development of public procedures be removed from the legislation.