We all want government to be efficient and use money effectively and for the public good, but when efficiency is prioritized over effectiveness there can be harm done to the very people who should benefit from that spending.
The FAA has been quietly working on a plan to streamline certification processes and that’s generally a good thing. Certification backlogs are legendary, and folks we’ve talked to about getting stuff approved have said the agency is functionally paralyzed by an ill-advised reorganization three years ago that dispersed certification decision makers so widely that they can’t get together to do the work they’re supposed to do.
Something that does work is the Designated Engineering Representative program, in which thoroughly qualified experts, many of them former FAA employees, are given the FAA administrator’s blessing to work with innovators and inventors to bring new products to market safely and expeditiously.
DERs are essentially gig workers. They’re hired guns brought in by aviation companies and even some individuals to get their bright ideas through the maze of government that stands between them and the free market. DERs take their jobs very seriously because lives may depend on their decisions, but they also understand how to get a good idea into the system for everyone’s benefit.
DERs have been taking this investigation, oversight and hand-holding burden off FAA employees for almost 100 years, and I can’t ever remember hearing a complaint about the system or its functionality. It’s true that there lots of them at the moment so there’s no imminent crisis. But many of them are retired FAA or private-sector professionals, and their shelf life is limited. I’ve also heard, but not confirmed, that the FAA is not taking new applications for DERs, which means the thousands we have now could be gone sooner than later.
But the watchword in government these days is efficiency and from that point of view the changes planned by the FAA are rock solid. By phasing out the thousands of DERs in favor of turning that kind of work over to Organization Delegate of Authorities (ODAs), the workload for the FAA oversight of certification of new stuff for airplanes will drop dramatically. Instead of keeping an eye on thousands of freelance DERs or the one or two that might be on staff at small businesses at airports all over the country, they’ll only have to deal with a fraction of that number representing ODAs.
The problem with that scenario is that while most of the innovation in aviation comes from those small shops scattered all from coast to coast, ODAs are set up to centralize those services and come with a major administrative burden. The dreamers and schemers who come up with the next big thing in aviation can’t possibly afford to set up their own ODAs and their ideas are doomed before they start.
The FAA needs to look at this issue through a different lens. If the goal is simply efficiency, then let’s get rid of GA altogether and save billions. But if the goal is to foster innovation and to create new and better ways to do things, well, you have to have people to actually do that work. There are relatively few aviation companies that are trying to invent and innovate and who can afford to set up ODAs. ODAs are mostly in the land of large manufacturers to take their own certification efforts in house and are not necessarily thrilled with a bunch of smaller companies coming up with better ideas than them.
So while efficiency should always be a goal, the actual business of the FAA still has to get done, and DERs are a fundamental part of keeping the industry nimble and leading edge in terms of technological development. As any of those small operators will tell you, you have to spend money to make money, and for almost a century DERs have been a prudent investment for the American taxpayer.
In federal gov’t (and maybe elsewhere…) either-or solutions generally exhibit a lack of imagination. In some instances, ODAs may provide measurable organizational benefit to FAA administrative oversight of private industry. I cannot know. But throwing out DERs is neither wise or necessary. Case-in-point: The Continental W670-M on my airplane is not on the type certificate for the airframe. It didn’t exist when the TC was published. But the engine overhaul shop brought in a DER to evaluate its suitability and he deemed it acceptable. The higher compression pistons in the -M give the engine 240 hp instead of the stock W670’s 220. The Continental W670, designed if I’m not mistaken in 1931, and used in Stearman and WACO WWII trainers by the thousands, does not need an ODA to evaluate minor modifications of near century-old engineering. DERs are just fine.
So, who then will be approving all these experimental kits and the new MOSAIC aircraft kits for flight if there are no DERs?
Fortunately, Experimental kits/aircraft don’t come under the requirements for DER approval becasue…they are Experimental!
Joe: You are thinking of DARs – Designated Airworthiness Reps. Different critter than DERs – Designated Engineering Representatives, of which there are not nearly ’nuff presently.
In a time of rapidly increasing worldwide innovation in aviation, especially in China, this is the wrong time to be shutting down new product development in the USA. The Chinese government is bending over backwards to help their aviation innovators and the response of this administration is to shut the door on new products? The USA is where aviation was born, why are we voluntarily giving up our worldwide lead in this industry?
I guess I need help realizing what the draft document changes with regard to DERs. After reviewing this new CHG 1, the original 8900.95D, and comparing that to the historical 8900.95C, I’m just not seeing the drastic changes to the DER landscape. I’m very curious to what the drama is really about and if it is truly legitimate and how it may also trickle down to DARs and DMEs.
You are not wrong. I am currently going through the DER appointment process, and have read the proposed language, as well as contacted two seperate FAA field offices (as of this writing) to get clarification.
Both told me the exact same thing- independent and FAA-employed DERs are not going to be phased out by any stretch of the imagination. There will always need to be the requirement to have them, especially in the post-MOSAIC landscape. The language is heavily geared towards the requirements for OEMs to plus-up on ODAs.
DER and ODA involvement in FAA certification is beneficial to an FAA system where progress is measured glacially as a result of faltering Congressional budget approvals and inherent Governmental inefficiencies. Its real value is found when established manufacturing companies bring new products to Certification using known and established technologies.
New and novel projects are a bit more convoluted, and involve so many DER, DAR, and ODA sub-category disciplines that finding appropriately-rated and approved engineering assistance is near impossible without hiring a platoon of designees. Something most small, innovative companies can ill afford.
Nevertheless, progress is grinding forward in spite of the FAA’s grudging acceptance of global collaboration with those seeking similar or parallel Certification strategies.
ODA recommendations to the FAA are limited to its company certification efforts and FAA approval of its certification model is likewise limited. DER/DAR personnel will review an ODA’s data, if not proprietary, during consensus standards review, but sharing information is limited. In other words, all of these very smart people work independently and in the dark.