Reverse Incentives

The way the existing certification system for aircraft and engines and components works is backwards. Consider just this one small (true) tale.

A manufacturer of aircraft components decides to upgrade the product. After some research and development, the product's designers make it longer lasting, more reliable, and more useful, all for the same price. Sounds like a good idea, right?

The manufacturer goes to its FAA engineering office to get the FAA's blessing in order to offer the product to customers. This shouldn't be a big problem. Many of the changes are cosmetic, although the guts have been substantially improved. The new product is really the result of small incremental changes, not the application of way-out-there new technology.

Here's where this manufacturer made a mistake. In consulting with the FAA, the manufacturer admitted that it planned to change the product's model number. Just slightly, to reflect the improvements, so the customer would know that they were getting something new and better. Component 10A instead of 10. Not a big deal, right?

Oh no. Big hairy deal. Really giant earth-shattering deal.

The FAA engineers got into high dudgeon-mode and filled the air with regulations and stipulations and requirements. Thou shalt do this and don't you dare think of doing that. A blizzard of paperwork. Consultations with more engineers. The FAA at its finest.

The result? A one-year re-certification process for a product that had been in service for decades and was undergoing a modest upgrade to make it better, for the benefit of the customer.

This effort cost the manufacturer a huge amount of money. Did it protect the flying public? Was the aviation world made safer?

No and no. All this effort did was occupy the valuable time of FAA engineers who are needed for more important certification projects. (Manufacturers are already complaining that lack of FAA manpower is causing many certification delays.) And it tied up valuable resources at the manufacturer, driving up the price of its products. No wonder aviation is so unbelievably expensive!

This unfortunate manufacturer learned a huge lesson from this case: never, ever change the model number on a product when improvements are incorporated. How did it learn this lesson?

Because shortly after the above occurred, the manufacturer did the exact same improvement program to another similar product, but this time the old model number was retained. Forget adding the "A" to the designation. And guess what? The FAA engineers blessed it without a fuss. What kind of whacky system is this?

The way aviation currently works is what I call a "reverse incentive" system. The FAA has a mandate to protect the public from dangerous flying machines. And flying certainly has its risks, there's no getting around that when you are operating a product that flies in the air. So in its mission to keep the public safe, the FAA is sometimes overzealous in applying the regulations. (This might also be a characteristic of a large government bureaucracy, but that's another story.)

In its zeal to promote safety, the FAA often sends a clear signal to the aviation community, that the time and effort and money required to modify and upgrade an aviation product is just not worth the huge effort. If your product does the job adequately, why spend the money and waste blood, sweat, and tears when the FAA is just going to go out of its way to make the job difficult? This is the reverse incentive; just leave the airplane, engine, or component alone and we'll all be happier.

That is completely backwards. The incentive for anyone in aviation should be a big reward for being willing to figure out a better way. Rather than a disincentive to improve the product, which is what we now have, there should be a disincentive for not making the product better. If a manufacturer keeps on building a product year after year without at least trying to incorporate improvements, then that manufacturer should be penalized. Don't ask me what form the penalty should take, I'm just saying that one shouldn't be penalized for trying to improve the product.

Sure, the marketplace operates naturally to provide incentives for product improvements, and that's the way most businesses operate. But aviation is weird. We're stuck in the same-old, same-old because it's just easier. It keeps the FAA off our backs and it's cheaper, too.

How about it, FAA? Can you encourage the industry to strive for improvement instead of erecting roadblocks?