Update on Rulemaking Prioritization

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Presentation transcript:

Update on Rulemaking Prioritization Mike Kaszycki, FAA Thaddée Sulocki, JAA Update on Rulemaking Prioritization

Topics 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 Update on Rulemaking Prioritization

Review 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 Update on Rulemaking Prioritization

History 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 Update on Rulemaking Prioritization

Existing 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Group (HWG) final rules per year since 1995 JAA rulemaking process is streamlined Some HWG recommendations have gone unpublished for years New rulemaking process is needed to effectively focus industry and authority resources Update on Rulemaking Prioritization

New 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 Update on Rulemaking Prioritization

Overall Rulemaking Process Unilateral Action Simple Harmonization Tasks Prioritized Rulemaking FAA JAA Try To Involve Other Authority & Industry SRDs - Fast Track (Enveloping) - Completed HWG Tasks - No APO Resources Needed - No Additional Industry Resources 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 to Support (4) High Safety or Efficiency Benefit Harmonized Regulations (FAA adopting JAR requirements Only) TCCA Update on Rulemaking Prioritization

HMT 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 Update on Rulemaking Prioritization

HMT Prioritization Team Activities 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 Update on Rulemaking Prioritization

HMT Prioritization Team Activities 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 Update on Rulemaking Prioritization

Joint 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 Update on Rulemaking Prioritization

Next 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 Update on Rulemaking Prioritization

Summary 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 Update on Rulemaking Prioritization

Summary 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 Update on Rulemaking Prioritization