As part of the FAA's System Approach for Safety Oversight (SASO), the Aviation Flight Standards (AFS) office under AFS-30 is developing the FAA's new oversight system called Safety Assurance System or SAS. It is targeted for implementation beginning in 2013 for 14 Code of Federal Regulations (CFR) Parts 121 (scheduled air carriers), 135 (charter/on demand air carriers), and 145 (repair stations) and eventually for all other applicable operators.

SAS is intended to:

• Enable the FAA to focus on areas of highest risk in the aviation system and equip the FAA with new tools to assess the health of the certificate holder's systems and to ensure that they effectively manage risk.
• Provide the ability to share data, collaborate and integrate voluntary programs such as internal evaluation programs (IEP) and aviation safety action programs (ASAP).
• Provide resources to address areas that pose the highest degree of risk.
• Assist the FAA with adapting oversight activities to fit the type of operations of an individual operator.
• Keep the best of the surveillance system that works today and enhance areas that need improvement.
• Replace the Air Transportation Oversight System (ATOS), which is currently used to assess the safety of air carrier operating systems for Part 121 certificate holders and will also become the oversight system for all CFR Parts. Once SAS is implemented there will be no further versions of ATOS. The FAA does not expect that ATOS and SAS will run in parallel although there may be a brief overlap during the initial deployment period.
• Use the concepts of Design Assessment (DA) and Performance Assessment (PA) and target areas that present the highest degree of risk. Today ATOS uses Safety Attributes Inspections (SAIs) and Element Performance Inspections (EPIs) as the data collection tools for design and performance assessments. It is anticipated that new data collection tools (new inspection questions) will be developed for SAS.
• Be designed to identify the correct oversight activities based on the differences between the certificate holders (size, complexity and risk) including very small operators like single pilot certificate holders. SAS will help inspectors prioritize work activities by removing questions that do not apply to certificate holders operation.
• Use several types of oversight questions (data collection tools) such as yes/no, rating scales, and drop-down menus. Open text fields will be used to evaluate the adequacy of the certificate holders design and effectiveness of their performance, and eliminate the high degree of interpretation that is currently required.

Weighing in on the Proposed Passenger Rights Rule

There is a way for everyone to weigh in on the proposed new passenger rights rules. Regulation Room at www.regulationroom.org enables air travelers the opportunity to submit comments on the proposed passenger rights rule that covers everything from tarmac delays to peanuts. If the passenger rights rule is enacted, it will impact the way we travel by scheduled air carriers more than any single regulation since the airline industry was deregulated in 1978.

Typically, when a proposed rule is published in the Federal Register (a daily Federal government publication for Rules, Proposed Rules, and Notices), it required insider knowledge of the government rulemaking process. Interested groups such as trade associations representing segments of the industry are intimately familiar with the process and the potential impact a proposed rule may have on the industry. Using the collective inputs from their members they often submit comments pro or con pertaining to the proposed regulation.

Many individuals and groups with a substantial interest in the proposed passenger rights rule and other proposed rules are not aware of how to submit comments. The Regulation Room, which is funded by the National Science Foundation and Google eliminates the hurdles for those that want to participate in the rule making process. The Regulation Room "service" is free and it includes a plainly worded summary of the proposed rule as well as an opportunity to submit your comments.

The proposed passenger rights rule covers a lot of areas including:

1. Requiring airlines to include all mandatory fees in the ticket price.
2. Airlines adopting contingency plans for lengthy delays.
3. Reporting more information about delays and promptly informing customers of flight delays.
4. Providing minimum airline customer service standards.
5. Increasing compensation for passengers denied boarding/seat when ticket was purchased (over booked flight).
6. Preventing air carriers from raising fares after ticket purchase was made.
7. Making it "easier" for passengers to file legal action against an airline.

The Regulation Room provides the best opportunity for travelers to voice their opinion. You have until August 9, 2010 to submit your comments.

JDA Regulatory Affairs Training: September 14-15, 2010

1. FAA Flight Standards organization and function of different departments in relation to Regulatory Affairs personnel.
2. FAA CMO organization, duties and responsibilities, positions, i.e. Principal Inspectors, Partial Program Managers, Assistant Managers, etc. Also explain the functions of these positions.
3. Inspection programs and inspector criteria; i.e. surveillance, investigation, complaints, incidents, etc.
4. Understanding the variety of inspector methods and how to address them.
5. Inspector authority and limits.
6. Steps for establishing new relationship with FAA CMOs:
• Procedures for checking in and out at your facilities
• Inspector in briefing and out briefing
• Inspector access to facilities, equipment, records and personnel
• Inspector badges
7. Actions and timeframe for implementing new operating procedures:
• Data to collect
• Standardized reports
• Other line stations and facilities
8. Introduction of new procedures to FAA CMOs and anticipating the FAA's reaction.
9. Understanding how the FAA conducts investigations and what kind of response they expect from Company.
10. How to research FAA regulations, handbooks, policy letters, etc.
11. How to conduct an internal investigation (what to look for) as a result of an FAA Letter of Investigation (LOI), and how to respond to an FAA LOI using actual ongoing cases.
12. When and how to tell the FAA that you disagree with allegations and how to respond accordingly.
13. Procedure (when and how) for elevating an issue to higher authority.

"It concerns us to hear of the difficulties some of our clients are having with their FAA interactions," said Joe Del Balzo, President of JDA. "This course will provide in-depth understanding of the FAA processes and inspector responsibilities and authority as well as the resources available to assist operators improve their working relationship with their FAA counterparts."

The course was originally presented to a large Part 121 operator in 2009, receiving rave reviews, and made a second appearance in Ft. Worth, TX as a two-day event that was available to all operators in May, 2010.

One participant described it as "one of the best training courses I ever attended. I learned more in two days about the FAA and the oversight process than I have during my seven years on the job. The course is jam packed with valuable information."

JDA has enhanced the regulatory affairs course by adding a former FAA Chief Counsel, who will offer legal insight; establishing the September course as the most comprehensive yet.

A discount of $100 is being offered to all participants that register before August 1st so sign up soon!

For detailed course and registration information, go to our website or contact Michael Kushner at 301-941-1460 ext.130 or via email.