PLANE TALK Here are some tips on
communications, both written and oral. Be correct and concise in your communication. Keep to one subject in your message; adding in additional subjects takes away from your single point. It also may cause delays in response if your communication covers several departments. For example, if it’s a maintenance issue do not add in an air traffic issue. Stay away from emotional language or namecalling. It will not help your case nor will it intimidate the regulators. Avoid threats as most nations protect their inspectors by law from such matters. I have read and answered thousands
of letters and have seen regulations change on one well-written letter from one technician or AME. Individuals in positions like directors of maintenance are particularly well regarded and influential in such matters. I have also been on receiving end of the threats that do not work at all.
HOW THE REGULATOR REACTS
AND WHY So you now find you need to confront your regulator. You have sent them a well-written communication. If you started at the inspector level, your letter will be analyzed and a response prepared. If your point needs some clarification, they will contact you for further information and once they have that they will continue. At times the inspector will need to consult with other inspectors, study the standards and policies and perhaps consult with their supervisors. If policy is unclear they might refer your issue to a national HQ and their specialists. All this takes time and can be frustrating to industry; however, the inspector works for the government and they must be right as they are, in fact, committing the government to the reply. Now you have received the reply
and you believe their position is wrong. The next step is to move up
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the management chain. Thank them for the reply and readdress your point to the next level, making sure you copy your principal inspector. It’s always important to keep everyone in the loop. You can continue this until you reach the regulatory HQ and even onto the minister or administrator. If you are pursuing it that high, make sure you attach all previous correspondence, copy the individuals you dealt with and await the minister’s or administrator’s reply.
STARTING AT THE TOP Why not start at the top? The following is the effect once you leave the technical chain and enter the political area. No public servant wants to make a mistake and have the minister or administrator sign a letter that is in error. It happens but not often. Your issue will travel down the chain to your inspector and back up. Everyone has to sign off on it and usually it goes to a communications group for format, grammar, etc., and then onto being signed. You can only imagine how many such letters get written in the U.S. or Canada every day. In the regulatory department it’s an important thing, well tracked and has firm timelines for responses. Guess who gets to draft the first response. It’s usually your inspector, so it causes a lot of technical work delays because ministerial correspondence takes top priority and there are no surplus inspectors waiting for work. It basically locks the system down. Technical managers can overrule their subordinates but once it has gone political it is difficult to get a ruling changed. Should you go to that level on a technical matter? I say normally not. If you have good case it should get resolved in the technical part of the department. If it is more political (for example sales taxes on aviation parts), then yes, but operational issues, not so quickly. Of course as a citizen
you can do as you wish. I am only indicating how the system works. Last but not least, tell the inspectors
that you will turn the matter over to your lawyers, thereby intimidating the inspectors. This method does not work as the department and the government have massive legal departments and access to many contract law firms. Of course, if you find yourself in an enforcement action, accident or incident with potential legal implications, call on your lawyers. When in doubt, chat with them before you act, as there are many good aviation lawyers who can help you decide how to proceed.
CONCLUSION
Thousands of technical issues have been solved over the years by com- municating clearly and professionally to the regulators. You can leverage the department’s own standards to help make your case. Standards like profes- sionalism, service levels and good management mean they want to resolve issues. Your part is to provide them with the information needed to move them to your position. The inspectors are also knowledgeable aviation people who want a safe and successful industry just as you do. Do not be afraid to discuss and debate things with them. The idea that they will get back at you is a false no- tion. Regulators are far too busy and have too many oversight agencies (in- cluding the courts, the media and their political masters) to engage in that sort of activity. I can deal with that subject more thoroughly in another issue. Lastly, use the resources of your associations as well as your own. There is strength in numbers if the issue affects more than just your operation. Clearly state your case and be polite, firm and open to solutions and your relationship with regulators will be smoother and more rewarding than confrontational. Remember to use the 3 C’s along the way.
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