how to be a administration federal aviation regulator...faa act as amended • faa order 1100.161,...

Presented to: KOCA

By: Anthony Ferrante

Date: April 30, 2014

Federal Aviation Administration How to be a

Regulator: Guidance and Tools

Federal Aviation Administration

Why do we Regulate ATM?

• Convention on International Civil Aviation, also known as the “Chicago Convention”

• FAA Act as amended

• FAA Order 1100.161, Air Traffic Safety Oversight Service

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What does it mean to regulate?

Regulators do so much more than administer laws. They also deliver services, build partnerships, solve problems, and provide guidance. M. Sparrow

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What are our areas of oversight? • Air traffic control services • Safety personnel including ATCS and Technicians • Flight procedures and flight inspection • Communication, Navigation, and Surveillance

services • Aeronautical Telecommunication services • Meteorological services • Aeronautical Information Services and Aeronautical

Information Management • Cartographic services

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Some Regulatory Models*

Model 1-Prescriptive approach • Rule based • One size fits all PRO- Easy to enforce CON- Doesn’t address insufficient requirements

Model 3- Safety management system approach • Includes Regulator approvals, periodic

audits, and detection and verification • Dependent on service provider having a

safety culture PRO- Maximum flexibility for service provider CON- The Regulator only knows what the service provider tells them

Model 2 – Performance based • What, not how to accomplish something PRO- Allows for innovation CON- Enforcement is a challenge

Model 4- Industry self regulation • Facilitated by industry associations PRO- Maximum incentive for industry leaders CON- Favors large companies and most energy is focused on keeping out the competition

* Based on models from Malcom Sparrow

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AOV’s Regulatory Continuum

Yesterday • Quality Control

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Today Tomorrow

• Agile oversight assessments

• Increasing collaboration to set standards

Raising the safety bar

• Compliance against a standard


Stages (adapted from Malcolm Sparrow)

How AOV does it 1. Nominate potential problem for

attention Audit topic initiation

2. Define the problem precisely Audit plan

3. Determine how to measure impact Audit checklist

4. Develop solutions/interventions Audit report

5. Implement the plan/periodic monitoring/review/adjustment

Compliance and Follow-up Audits

6. Project closure and long term monitoring/maintenance

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Approach Regulating as Problem Solving


How does AOV regulate?

• Monitor • Conduct audits and assessments • Resolve safety concerns (Compliance

process) • Set safety standards • Approve, accept or concur with changes to

NAS

ATO is informed of every non-compliance identified. We never turn a blind eye

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During audits…

• We allow the facility manager to become aware of non-compliance in a non-confrontational, informal manner

• We assume positive intent

• We allow the ATO to address the non-compliance

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Identifying Safety Issues

Be task focused • Approach regulating as problem solving

– Reduce risk – Eliminate patterns of non-compliance

• Root cause problem solving • Breaking the cycle

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Determining Urgency

• What is the real issue? • What risk does it pose?

– Is there a time-sensitive element to the problem or its resolution?

• What about the regulated party? – First time or repeat offender?

• What potential actions will maximize the likelihood of the problem not recurring?

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Professionalism

• Within AOV – Because there will always be the need to exercise

judgment, there needs to be a sense of collegiality among co-workers and team members, while valuing a range of skills and opinions

• With ATO

– Safety professionals should be able to take a contrary position without adopting an adversarial style

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What would you do scenario #1

• On an audit, you are observing operations in the tower. While observing the Local Control position, a new controller comes in and a position relief briefing is conducted. As you move closer to observe the briefing, you notice a very strong smell of alcohol. As a regulator, what do you do?

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What would you do scenario #2

• On an audit you are reviewing local quality control procedures at a facility. During the interview with the manager, she explains how the process is completed. The process as explained is in compliance with the requirements. When you ask for objective evidence to verify what you were told, she is not able to produce any documentation. As a regulator, what do you do?

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• Use standardized methodologies and tools to guide you

• Make improvements to your

processes and tool on a regular, recurrent basis

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AOV Monitoring Activities • In headquarters, the NAS Operations

Branch uses trending information for events that are national in scope.

• The area offices maintain an in-depth

knowledge of local procedures and operations and develop professional relationships with counterparts at the Service Area and Field levels. Their monitoring efforts are more detailed.

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Area Office Continuous Monitoring Activities • safety oversight at the field-facility level • work with local FSDOS for a 360 degree

view of events • routine surveillance of field facilities • monitor field level SOP's, MOA's and LOA's • Identify facility specific risks • monitor field level equipment and

maintenance procedures

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Area Office Continuous Monitoring Activities (cont.) • develop and monitor certificate application

process for new systems and procedures • liaison with ATO, service area and field level • collect and analyze safety data • monitor field level trends and indicators • monitor safety risk management

development and functions at the field level

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Monitoring – Oversight Tools

• AOV is developing tools to assist inspectors in executing their responsibilities

1. Service Delivery Point Assessments (SDPA) 2. Facility Risk Assessment Tool 3. Facility Specific Safety Standards 4. AOV Oversight Portal

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Service Delivery Point Assessments

(SDPA)

• Inspectors (POIs and PMIs) need a program

and process to use in the assessment of their assigned facilities and have the ability to produce reports on their findings

• Reports need to be consolidated and dissected by a peer group to identify systemic issues found in their service area

• Identified systemic issues need routing from the field to upper AOV Management

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SDPA (continued) • AOV uses the collected data to establish a

baseline

• The data is used to get a better understanding of the facility and how it performs

• In understanding how the SDP performs, we can compare it to other like facilities, collaborate with our fellow inspectors and get a good picture of any systemic issues

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What is an SDPA? • SDPA is the practice of gathering key

information pertaining to systems performance from an air traffic facility or a technical operations System Service Center and putting it on one report

• The SDPA establishes a baseline of information that allows inspectors to compare data. It also uses the expertise of each individual inspector to analyze and determine if a SDP is compliant with requirements

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SDPA Main Page

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General Facility Information

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Facility Traffic Count

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Facility Runway Information

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Key Components of a SDPA Inspectors • Increased knowledge • Relationship with the service delivery point

Collaboration • Service delivery point assessments are tied

together • Systemic issues discovered

Communications

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Benefits of a SDPA

• Snapshot inside of a service delivery point • Audit Topics • Compliance Issues • Narrowed Focus • Increased Inspector Knowledge • Pinpoints Systemic Issues • Open Dialogue

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Within AOV: The Branch Council

Council comprised of 3 POI’s and 1 PMI from the branch office. All members are

management appointed and are on a rotating basis

Consolidate assessments Decide branch derived systemic issues Complete Branch Council report Forward Branch Council report to Division Council

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Work Flow

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CENTRAL BRANCH COUNCIL

WESTERN BRANCH COUNCIL

EASTERN BRANCH COUNCIL

200 DIVISION COUNCIL


Program Deliverables In-depth reports Identified systemic issues Well rounded facility knowledge Cross talk with peers Avenue for open communication

between the POI and AOV Management, POI and Facility, POI and ATO Safety

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Purpose To support independent safety oversight of air traffic services by assessing, ranking, and tracking air traffic facility safety risk and allowing AOV to target its oversight resources towards facilities posing the highest risk to air traffic safety.

Facility Risk Assessment Tool (FRAT)

Goals Provide a common platform for AOV to access facility safety risk

information and performance trends Provide facility risk scores and supporting data as a basis for AOV

prioritization and allocation of limited safety oversight resources Support proactive facility safety risk assessment through leading

risk indicators and risk trending capabilities Support AOV’s strategic and tactical safety oversight activities,

ranging from annual audit topic planning to daily facility risk monitoring

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FRAT Concept

• Facility Risk Ratings • Risk Factor Ratings • Comparative Risk

Assessment • Trending • Graphs • Reports

A mixture of leading and trailing NAS safety and performance data available to and accessible by AOV

Quantitative Framework to calculate risk ratings for Air Traffic Control facilities

Output Input

Facility Risk Assessment Tool (FRAT)

Model

Web Interface

AOV User Community

FRAT Graphical User Interface

FRAT Reports and Graphs

Mission – To support independent safety oversight of air traffic services, AOV requires a Facility Risk Assessment Tool (FRAT) that will assess, rank, and track air traffic facility safety risk and allow AOV to target its oversight resources towards facilities posing the highest risk to air traffic safety.

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Facility Safety Risk

Facility Factors Operational Factors Organizational Factors

Physical Environment

Technological Environment

Operations & Procedures

Safety Performance

Organizational Environment

Resource Management

Potentially Hazardous Operations

Waivers Air Traffic Operations

Technical Operations

Risk Factor Categories • Criteria for risk factor selection e.g., safety impact, viable data source, etc.

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21. ATC Equipment Anomalies 22. NAVAID Anomalies 26. False Alerts 44. Late Certification 45. Restoral Events Waiting Flight Inspection 47. Outages Due to Tech Ops Personnel Errors 58. Adjusted Availability 59. Interrupt and Related Corrective Maintenance 60. Maintenance Effectiveness 61. ILS CAT II/III System Continuity of Service 63. Failures Following Repair 66. Mean Time to Restore 76. Number of Vehicle / Pedestrian Deviations

Involving Tech Ops 77. ATC Zero 78. ATC Alert 79. Facility Evacuations

Facility Safety Risk Factors

Environmental Factors

Operational Factors

Organizational Factors

Physical Environment

Technological Environment

Operations & Procedures

Safety Metrics and Performance

Measures

Organizational Environment

Resource Management

Air Traffic Operations

Technical Operations

1. Runway Configuration 5. Number of Taxiways 6. One Taxiway to Multiple Runways 10. Number of Intersecting Taxiways 13. Mountainous Terrain 14. Terminal Area Construction 15. Another airport located:


FSSS is a new tool for conducting oversight of air traffic services

– Addresses unique facility characteristics – Simplifies national safety standards – Streamlines AOV and the ATO’s approval process – Eliminates inconsistencies in interpretation – Can influence and enhance safety prior to the

implementation of a new procedure

Facility Specific Safety Standards (FSSS)

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The Flight Standards Model

Flight Standards uses Operations Specification (OpSpecs) for monitoring and oversight of service providers

– Identifies authorized carrier operations, locations, and responsibilities

– Bridges the gap between safety regulation and operator capabilities

FSSS is modeled after OpSpecs

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FSSS Facility Specific authorizations will be issued using templates that contain:

– National order reference – Procedure details – Requirements/Mitigations – Electronic signatures – Supporting (Safety Risk Management) documents – They are valid until canceled, but can be modified

Allows for better monitoring of unique procedures

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AOV Portal

The purpose of this tool is to monitor the safety of the NAS using indicators that are outside the control of the Air Traffic Organization (ATO) • ATOS-like Environment • Incorporates FRAT and FSSS • Will incorporate the SDPA and many other

data sources

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Benefits • Access multiple sources of information • Pooling data sources, e.g.,

– ATO facility risk factors from AOV inspectors’ Facility Risk Assessment Tool (FRAT)

– Flight operations statistics – NAS operations statistics – AOV archival documentation

• Standardized measures and comparisons • De-identified information can be shared

across stakeholders

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Federal Aviation Administration 42

AOV OVERSIGHTPORTAL

”PUBLIC”DATA/INFOSOURCES

Populate FRATrisk elements

Facility Risk Assessment Tool

(FRAT)

Populatedynamic summaries and

recategorizations.

POI’s Inputs - Judgments, Ratings, etc.

Functionality for DynamicSummarization and

Information Integration.

AOVSOURCES

AOV POI Facility

Assessments

AOV Archived Reports & Data

(Other)

AOV ApprovedWaivers (FSSS)

AOVAudit

Findings

AOV Unapproved

Waivers (FSSS)

Runway Safety Reports

As Available

ATO Corrective

Action Plans

AOVPMI Facility

Assessments

•ATO

•Reports


AOV Oversight Portal

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Example: Wrong Airport

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NAS Operations

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Airport Ops Overview

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How to be a Regulator: Guidance and ToolsWhy do we Regulate ATM?What does it mean to regulate?�What are our areas of oversight?Some Regulatory Models* AOV’s Regulatory ContinuumApproach Regulating as Problem Solving�How does AOV regulate?During audits…Identifying Safety IssuesDetermining UrgencyProfessionalismWhat would you do scenario #1What would you do scenario #2슬라이드 번호 15슬라이드 번호 16AOV Monitoring ActivitiesArea Office Continuous Monitoring ActivitiesArea Office Continuous Monitoring Activities (cont.)Monitoring – Oversight Tools ��Service Delivery Point Assessments (SDPA)�� SDPA (continued)What is an SDPA? SDPA Main PageGeneral Facility InformationFacility Traffic CountFacility Runway InformationKey Components of a SDPABenefits of a SDPAWithin AOV: The Branch CouncilWork Flow�Program Deliverables�슬라이드 번호 33FRAT Concept슬라이드 번호 35 Risk Factor Summary Findings:�The Flight Standards ModelFSSSAOV PortalBenefits슬라이드 번호 42AOV Oversight PortalExample: Wrong Airport슬라이드 번호 45슬라이드 번호 46슬라이드 번호 47NAS OperationsAirport Ops Overview슬라이드 번호 50

how to be a administration federal aviation regulator...faa act as amended • faa order 1100.161,...

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