Here are some key findings gathered from interviews with 14 CFR Part 121,135, and 145 Certificate Holders regarding SAS. Through these discussions, insights were gathered from 13 Certificate Holders on SAS’s potential impact on the aviation industry as well as how and what they want to hear about SAS as implementation gets closer. Here is what the Certificate Holders interviewed had to say:
SAS's Perceived Impact - How might SAS impact 14 CFR Parts 121, 135, and 145 Certificate Holders?
They believe SAS could create a more tailored inspection that targets each Certificate Holder’s greatest areas of risk, thereby streamlining the auditing/inspection process and reducing the number of man-hours needed to prepare for an audit
The smaller 14 CFR Part 135 and 145 Certificate Holders expressed concern over SAS’s potential to create more reporting when they cannot afford to increase their staffing level or budget to account for it
Many Certificate Holders believe SAS should create a better platform for information-sharing between the Flight Standards District Office (FSDO)/Certificate Management Office (CMO) and Certificate Holder, and SAS could help the Certificate Holder and the FAA measure and interpret information through the same lens
SAS's Perceived Impact - How might SAS's automation improve the oversight process?
Many Certificate Holders said that they have migrated away from paper-based manuals and replaced them with the iPad; the digitizing of their manuals allows them to push manual updates electronically and could complement SAS’s data automation features
These Certificate Holders stressed the importance of information visibility; they believe that SAS’s automation features could create a more efficient inspection system that allows information to be more freely exchanged ahead of inspections
They believe SAS’s automation could lead to a more efficient manual inspection process that will allow them to answer manual-related questions in advance of their inspection as well as more easily and precisely search for FAA regulations and policies
These Certificate Holders, particularly the smaller operators, underscored the need for SAS to scope to the size of each Certificate Holder due to their already tight budgets and workforce demands
They would also like SAS to integrate with the safety and quality management tools that they currently use
SAS Communications - What do Certificate Holders need to know?
Most Certificate Holders said that SAS communications must address why SAS is being implemented, its anticipated impact on Certificate Holders and on the oversight process, and its potential benefits
Many Certificate Holders – particularly smaller ones – want to know what resources will be required of them when SAS is implemented
Some Certificate Holders would appreciate knowing how SAS compares with current oversight processes
SAS Communications - How and when should SAS messages be delivered?
Most Certificate Holders strongly prefer to get information about the SAS from their FSDO/CMO and Principal Inspector, rather than from FAA Headquarters; however, many Certificate Holders indicated that Web sites, electronic newsletters, all-hands meetings, emails, and aviation association communications are effective for reaching a broader Certificate Holder employee base
Many Certificate Holders suggested using joint forums and training sessions with FSDO/CMO and Certificate Holder representatives present, as this would allow both sides to learn about and understand the SAS together and address potential hurdles jointly
Certificate Holders we interviewed expressed a wide range of preferences on when they felt communications should begin: Most said 6-12 months prior; some said 12-18 months prior; and many said that communications with Certificate Holders should start now or as soon as possiblle.