RAA director of technical affairs Dave Lotterer knows perhaps as well as anyone that good intentions at the FAA don’t necessarily translate into sound action. So when the agency pledged to pursue more vigorously a “performance-based” approach to safety oversight, Lotterer met the promise of a simpler, more straightforward code of regulations with a healthy dose of skepticism. Manifest in a program called the Air Transport Oversight System, the effort will require a huge commitment by operators to overhaul their safety processes. Theoretically, however, it would pay dividends in the long run with a more flexible and proactive form of oversight.
Not surprisingly, Lotterer’s mis- givings proved well founded when the FAA introduced a new set of rule appendices that could make the regulations governing pilot and flight attendant training look concise by comparison. Although the new concept, known as quality performance standards (QPS), will at first apply to Part 60 flight simulator qualification rules, Lotterer warns that, unless industry intervenes, it will sweep through the FARs like a plague, adding thousands upon thousands of pages of rules and recommendations to an already arcane and complex regulatory code.
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