20th Annual JAA/FAA International Conference JAA/FAA Update on Rulemaking Prioritization Mike Kaszycki, FAA Thaddée Sulocki, JAA

20th Annual JAA/FAA International Conference

JAA/FAAJAA/FAA

Update on Rulemaking Prioritization

Mike Kaszycki, FAA

Thaddée Sulocki, JAA

20th Annual JAA/FAA International Conference 2

JAA/FAAJAA/FAATopics of Discussion

• Review of Discussion at 19th Annual FAA/JAA International Conference

• Harmonization Management Team (HMT) Prioritization Team Activities

• Joint FAA/JAA/TCCA Rulemaking List• Next Steps for Rulemaking Prioritization

Activity• Summary


JAA/FAAJAA/FAAReview of Discussion at the 19th Annual

FAA/JAA International Conference

• The Rulemaking Prioritization Presentation Addressed the Following: – History of Harmonization– Existing Harmonization Workload– New Prioritization Process– Overall Rulemaking Process


JAA/FAAJAA/FAAHistory of Harmonization

• Harmonization Activity going on for over a decade• Focused mainly on Airworthiness Codes (parts 23,

25, 27, 29, and 33/JAR E) and Operations, Maintenance and Licensing

• Harmonization of Airworthiness Codes is very close to being technically complete

• Harmonization of Operations, Maintenance, and Licensing focused on areas of significant benefit to Industry

• Harmonization efforts to date are considered a success


JAA/FAAJAA/FAAExisting Harmonization Workload

• The backlog of new rulemaking initiatives is over 130 projects

• The FAA has published an average of 6 part 25 Harmonization Working Group (HWG) final rules per year since 1995

• JAA rulemaking process is streamlined• Some HWG recommendations have gone

unpublished for years• New rulemaking process is needed to effectively

focus industry and authority resources


JAA/FAAJAA/FAANew Prioritization Process

• HMT tasked an ad-hoc group to develop a new rulemaking prioritization process (March 2002)

• Prioritization of rulemaking projects recognizes:– Prioritized safety initiatives– Limited authority and industry resources– Realistic limitations on rulemaking capability

• Initiatives considered in prioritization activity include:– Unfinished existing HWG initiatives– Backlog of TORs not yet formally tasked– JSSI, CAST, CPS initiatives


JAA/FAAJAA/FAAOverall Rulemaking Process

UnilateralAction

Simple HarmonizationTasks

Prioritized RulemakingTasks

FAA JAA

Try To InvolveOther Authority & Industry

SRDs

- Fast Track (Enveloping)- Completed HWG Tasks - No APO Resources Needed

- No Additional IndustryResources Needed

FAA/Industry Write& Review NPRMs

Harmonized Regulations

(1) Limited to Maximum of 20+/- projects

(2) New Tasks/TORs/SRDs &Incomplete Existing Tasks

(3) Commitment From FAA/JAA/TCCA and Industry toSupport

(4) High Safety or EfficiencyBenefit

HarmonizedRegulations

(FAA adopting JAR requirements Only)

TCCA


JAA/FAAJAA/FAAHMT Prioritization Team Activities

• In November 2002, the HMT refocused the ad hoc team prioritization activity– Reduced scope from airworthiness, maintenance, and operations

rulemaking to airworthiness rulemaking only– Identified existing mechanisms for obtaining industry comments on

rulemaking prioritization

• The objectives defined for the ad hoc team included:– Finalize prioritization process– Identify lower priority, unfinished ARAC taskings to be placed under a

moratorium until prioritization is complete– Use draft FAA AVR Rulemaking Priority List to develop a joint

FAA/JAA/TCCA rulemaking list– Finalize joint rulemaking list for 20th Annual JAA/FAA International

Conference



• FAA committed to a moratorium on low priority ARAC HWG activities until prioritization is completed and implemented– FAA/JAA/TCCA agreed on the projects proposed for the moratorium– The projects identified included the active taskings for the

Powerplant Installations HWG and General Structures HWG– The moratorium (and affected projects) was coordinated with the

ARAC Transport Airplane and Engines Issues Group

• Industry input on rulemaking prioritization was obtained during March 2003 HMT meeting– Input received from GAMA and AIA– Identified specific projects of priority to industry– Requested that the authorities continue to work unfinished HWP

projects with completed recommendations



• The Draft Joint Rulemaking List was developed March 5, 2003– FAA input was based on the draft FAA AVR Rulemaking

Priority List– JAA input was based on the HWP and JSSI

recommendations– Considered industry input obtained during March 2003

HMT meeting– The Draft Joint Rulemaking List was coordinated with

FAA/JAA/TCCA management


JAA/FAAJAA/FAAJoint FAA/JAA/TCCA Rulemaking List

• The Final FAA/JAA/TCCA Rulemaking List contains 26 projects:– 23 on-going projects

• 19 Harmonization Work Program (HWP) projects– 6 projects still in HWGs– 13 recommendations received from HWG

• 4 harmonization projects not in HWP– All 4 recommendations received from HWG

• 12 projects were identified by industry as priorities

– 3 new initiatives• Not yet tasked to ARAC


JAA/FAAJAA/FAANext Steps for Rulemaking Prioritization

Activity

• Industry/Authorities will commit to supporting the Joint FAA/JAA/TCCA Rulemaking List

• Discontinue ARAC activities for certain low-priority tasks– As determined from the final AVR Rulemaking Priority List and the

Joint FAA/JAA/TCCA Rulemaking List

• HMT Prioritization Team will determine an appropriate cycle for updating the Joint FAA/JAA/TCCA Rulemaking List– To maintain a current list of joint rulemaking projects– To account for “pop-up” rulemaking activities


JAA/FAAJAA/FAASummary

• Continue to preserve the benefits of harmonization

• Maintain harmonization as an objective for future rulemaking projects

• Prioritization of rulemaking projects is necessary to efficiently achieve our safety goals

• FAA and JAA agreed on a limited list for future rulemaking activities


JAA/FAAJAA/FAASummary

• Commitment is needed from industry to actively support the joint FAA/JAA/TCCA rulemaking plan

• It remains of paramount importance that the FAA and, in the future, EASA continue to co-operate and establish a common ambitious, but prioritized, rulemaking program

Documents

20th Annual JAA/FAA International Conference JAA/FAA Update on Rulemaking Prioritization Mike Kaszycki, FAA Thaddée Sulocki, JAA