“Safety” and the FAA

On November 10, 2009, Secretary of Transportation Ray LaHood posted a blog on the Department of Transportation website entitled “The FAA, an Active and Vigilant Partner in Aviation Safety.” In his post, Secretary LaHood made the point that the Federal Aviation Adminsitration is seeking to be proactive with respect to safety and “move aggressively to put new safety measures in place.” And, in so doing, move forward by working with “key stakeholders to solve aviation problems.”

The basic point–that safety is this DOT’s number one priority–cannot be said too many times. However, I think it’s important to make one other point very clearly:

The Obama Administration’s Federal Aviation Administration is an active and vigilant partner, and we are moving aggressively to put new safety measures in place.

Now, there are two parts to this claim.

One–the new FAA is active and vigilant.

For that look no further than the recent incident where two Northwest Airlines pilots overflew their destination on the way to Minneapolis. The FAA took action immediately, revoking the pilots’ licenses within a matter of days.

Two–the new FAA is a partner, working with key stakeholders to solve aviation problems.

In June, for example, we issued a call to action encouraging all players in the aviation industry-–labor, management, and the FAA–to come together to scrutinize operations, share best practices, and implement actions we know can improve safety.

To his post, I made this comment.

While I do not for a moment doubt the sincerity of the FAA’s statement that safety is its number one priority, since as a former FAA employee, I know firsthand the commitment the agency and its staff have to safety. The issue I have is when the FAA hides its actions behind the mantra of “safety.”

Take, for example, the institution of a RNAV procedure at an airport. To say that the purpose and need for the RNAV procedure is to enhance safety is not entirely accurate. The need for an RNAV procedure is to allow, among other things, shorter separation between planes and more accurate flight tracks. Do those goals create a safer environment for those on the plane or on the ground? Perhaps, but safety is really a secondary goal – a by-product, if you will, of the primary goals.

While whether a RNAV procedure is a safety concern or a congestion concern may be a minor thing, the stakes get raised when the legal consequences are considered. The FAA has long recognized that if denominates the purpose of a project as being “safety,” it will get less resistance from the public, and from the courts, if litigation results. That would not be the case if the purpose were “convenience,” “ease of congestion” or even “efficiency.” Thus, when the FAA drafts an Environmental Impact Report pursuant to the National Environmental Protection Act, it knows that, whatever the project, the purpose and need has to be “safety.”

If everything is about safety, then nothing is about safety. Denominating safety as the purpose for every project, diminishes the impact that projects that ARE about safety will have. I applaud the FAA safety efforts, particularly with respect to pilots and air traffic controllers, and hope that it is successful instituting the needed changes in its infrastructure to enhance safety even more. But when a project is clearly not about safety or, at best, a minor part of the purpose of the project, the FAA has tell the public the truth.

The point is: too often the FAA hides behind “safety” to protect itself from criticism about its projects.  Too often valid debate about the need for FAA projects, e.g., runway extensions, RNAV procedures, control towers, etc., is muted because the FAA wraps them up in the mantle of safety.  If the true purposes for the projects are announced, then the debate about whether the project’s pros can be balanced by the cons can be effectively debated. And that, is the whole point of requiring federal agencies to make their projects known to the public.

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