www.PSFmagazine.com | December 2018 - January 2019 | 37 36 | December 2018 - January 2019 | Powered Sport Flying The L-Word Over a decade ago I became one of the very first Designated Pilot Examiners (dpes) for sport pilot in the country. Before then, I was a Basic Flight Instructor operating under a training exemption to Part 103, the ultralight rules. Worse, I wasn’t a respectable green-card-carrying pilot of any sort. So I did something that is pretty unheard of before or since: I went from chump to champ in less than two weeks. I received my sport pilot check ride, certified flight instructor check ride and my dpe check ride all in a very short time. (I may have been a little bit of an anomaly because I was the only one in that first round of dpe applicants who was merely a powered parachute pilot. Most of the other seven guys were ahead of me, certificate-wise.) In any case, the faa wisely deemed it necessary to put all of us through charm school. They call it the “Initial Sport Pilot Examiner Standardization Seminar.” Most all dpes go through that course. It trains the pre-dpe’s on how to do their jobs once they complete their seminar, their check ride, and receive their designation. The guy running the program when I attended is long retired. But I still remember some of his welcome speech. Some of it was the standard “you’re here because you are the best of the best of the best” stuff. But the part that stuck in my mind was the prohibition on using the “L-Word” during the course. Our man got the expected rca dog looks from all of us, so he went on to explain that much of what the faa does may not make sense to us and that he wasn’t going to waste class time comparing faa regulations and procedures to something as esoteric as “Logic.” Things are the way they are and we were to just accept everything and perform according to standards, no matter how much they didn’t align with what we thought made sense. A couple of times during the course questions did come up. And if they were “Why?” questions that seemed to be getting too dangerously close to that initial prohibition, we would be reminded that the L-Word just wasn’t allowed. Pretty soon everyone got the point, we put our heads down, and we did our own version of cooperate and graduate. Obviously the part about the L-Word stuck with me. And unfortunately I have seen more than one example in the faa where logic is left at the curb because the bureaucracy demanded another path. And that in itself makes me wonder why. Some of it may well be that the way government works just makes it difficult to do the logical thing. Maybe since organizations are made of people and rules, and not everyone agrees as to what is logical, makes change based on a litmus test of logic difficult. But I have been around long enough to see that common sense change is difficult in the faa. And I have heard from many in the faa –from line workers to executives– bemoaning the fact that the bureaucracy can be difficult to work within. It seems to me that perhaps the culture is so accepted that it is rarely challenged. Or perhaps new hires try to affect change initially and get frustrated quickly. Then they either move on to another job or just “cooperate and assimilate.” But there are a couple of things that should be easier to do and which may help the situation. For example, it should be easier to get rid of a regulation than it is to establish it in the first place. Regulations are often based on assumptions. If those assumptions prove to be wrong, then why should a regulation built on those assumptions be allowed to stand in perpetuity? Right now, it takes a lot of effort to establish regulations. That is proper. But why make it just as difficult to eliminate a regulation if it turns out to be harmful rather than helpful? Or even if it is merely more harmful than it is helpful? New regulations have had (at least in the past) to go through an economic analysis to see what kinds of benefit or harm there might be to the industry being regulated. What if that economic analysis turned out to be as accurate as a summer ten-day weather forecast in the Midwest? Again, if the underlying justification for a rule proves to be inaccurate, shouldn’t the rule at least be reviewed? The faa has in recent years done a lot to improve some regulations; the Part 23 overhaul for aircraft certification and establishing Part 107 for unmanned aerial vehicle regulations both stand out in my mind. But there is still room for more logic within the world of the faa.
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