Quick Question – Remote Connectivity
Beginning in 2018, ARSA and its industry allies jointly engaged the FAA on “guidance for using remote connectivity technology and tools.” Despite quick agreement from the agency, promises to follow up with guidance went unfilled until the White House issued an early-pandemic memorandum directing government agencies to realign operations to slow the spread of the virus. Agency leaders were instructed to “utilize the full extent of their legal authority and discretion to execute this realignment” and to “maximize telework…while maintaining mission-critical workforce needs.”
ARSA seized on that direction to remind the industry and agency about the work both had done on remote connectivity. On March 31, the FAA’s Aircraft Certification Service issued its policy (as promised, albeit a year late) and Flight Standards followed on April 22 with a memorandum to its employees about “Video and Communication Technology.” The policies collectively acknowledge there is no regulatory prohibition against the use of such communications tools and provide basic instruction for inspectors to critically assess their implementation.
Help ARSA gather information on your company’s use of remote connectivity (or outstanding issues related to it) in this month’s “quick question” (and review the updates below for more information).
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/remote-connectivity.
Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.
Click here to see what questions have been asked and answered…and keep a lookout for more.
For more information about this or any other question, contact Brett Levanto (firstname.lastname@example.org).
Previously on remote connectivity...
April 23, 2020
On March 31, the FAA’s Aircraft Certification Service issued its policy on use of remote technology (as promised, albeit a year late). Although the policy claims it does not add burdens, its general consideration adds the elements of “complexity, novelty, and safety criticality of the product, article or system.” Therefore, it will be up to “applicants” to ensure requests to use the technology cover the ultimate requirement to …”enabl[e]…proper performance of duties” in spite or despite the general elements that are supposed to be considered.
On April 22, the Flight Standards Service issued its own guidance – in the form of a memorandum to AFS employees – regarding remote connectivity applications. Under the subject “Use of Video and Communication Technology (VCT),” the memo made clear that use of such tools is allowed under the aviation safety rules:
“Current FS Orders and [FAA] regulations do not prohibit FS or industry use of VCT in fulfilling the requirements, and no specific guidance is necessary to enable its use. When evaluating an applicant, certificate holder’s or designee’s procedures to use VCT, or when evaluating your own use of VCT, aviation safety inspectors (ASIs) should apply critical thinking and interdependence to foster consistent decisions for proper use of VCT.”
The AFX memo is not prescriptive regarding “proper use,” but instead provides a series of questions and considerations for both government and industry to consider when applying remote connectivity resources for both live and recorded/asynchronous uses. Though presented differently, these guidelines reflect the baseline standards proposed by ARSA and its industry partners in 2018, focusing on task accomplishment in situations where necessary “coverage and content” is sufficient to complete the relevant activity using remote tools.
To read the AFX memo, click here.
To read the AIR policy statement, click here.
The bottom line is that the agency can allow the use of any technology that achieves the purpose of the regulation and will be part of an application or showing of compliance. The AFS and AIR policies are steps on the path the industry should be pursuing (and where it needs the government to go).
March 20, 2020
On March 15, the White House issued a memorandum directing government agencies to realign operations to slow the spread of the current virus. The memo instructed agency leaders to “utilize the full extent of their legal authority and discretion to execute this realignment” and to “maximize telework … while maintaining mission-critical workforce needs.”
For ARSA members, that means offering remote connectivity options to the agency’s personnel so routine approvals and audits can be conducted. The executive directive allows the FAA to expand telework capabilities using ubiquitous devices and readily available audio and visual software. This capacity should apply to any and all FAA personnel otherwise unable to provide oversight in person on premises during the government’s response to the spread of the virus.
Certificate holders should refer to the association’s 2018 engagement with the FAA regarding “remote connectivity technology and tools.” ARSA confirmed with both the Aircraft Certification and Flight Standards Services that there are no regulatory prohibitions against the use of such resources, then provided an industry-supported draft advisory circular outlining standards for oversight, inspections and testing performed using systems as readily available as a personal mobile device.
To facilitate the use of the best available technology, the draft AC established general requirements for set up and use of tools and equipment. The elements outlined in the document assist users in ensuring “the same level of acumen and capability [through remote connection] as if the oversight, inspection, test or training task or activity was conducted on-premises.”
ARSA encourages its members to utilize this guidance and readily available technical capabilities to request routine approvals and surveillance activities from the FAA during periods when inspectors are unable to interact face to face. While doing so, be sure to document all communications with agency personnel regarding remote oversight. Should an inspector reject or defer progress, contact ARSA.
To see ARSA’s previous work on remote connectivity, review the content below.
To read the industry’s draft remote connectivity AC, click here.
To read the White House memorandum to the heads of executive branch agencies, click here.
August 7, 2018
On Aug. 7, the FAA confirmed it would finalize and publish the industry-produced draft advisory circular providing “guidance for using remote connectivity technology and tools.”
“The Aircraft Certification Service (AIR) and Flight Standards (AFS) are working together to finalize the draft of the AC and begin the publication process,” the letter from AIR and AFS executive directors Dorenda Baker and Rick Domingo said. “We anticipate final publication in October 2019.”
To bridge the expected 13-month gap before the expected publication date, the letter explained that AIR would publish a policy statement aligned with the AC’s guidance. Since “AFS policy and guidance does not prohibit the use of remote connectivity,” Flight Standards will continue to “support industry requests until the AC is released.”
On May 7, the association and 15 of its aviation industry allies had jointly submitted the draft AC. The new guidance would provide a baseline for the FAA, its applicants and certificate holders to comply with 14 CFR while taking advantage of advances in connectivity technology and related video, live-stream and other visual and audio tools. The process began after the FAA opened a “Remote Witnessing Using Video” draft policy for comment in early 2018.
To read the complete industry submission and draft AC, click here.
To read the agency’s response, click here.
May 8, 2018
On May 7, ARSA and 15 of its aviation industry allies jointly submitted a draft advisory circular to the FAA providing “guidance for using remote connectivity technology and tools.”
The guidance document was developed after consultation with agency personnel regarding the existing draft policy “Remote Witnessing Using Video,” which was open for comment in early 2018. The AC would provide a baseline for the agency, its applicants and certificate holders to comply with 14 CFR while taking advantage of advances in connectivity technology and related video, live-stream and other visual and audio tools.
To facilitate the use of the best available technology, the draft AC establishes general requirements for set up and use of tools and equipment. The elements outlined in the document assist users in ensuring “the same level of acumen and capability [through remote connection] as if the oversight, inspection, test or training task or activity was conducted on-premises.”
The draft AC was delivered to Dorenda Baker, executive director of the Aircraft Certification Service and John Duncan, executive director of the Flight Standards Service. In addition to ARSA, its submission was supported by:
Aerospace Industries Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
The Boeing Company
Gulfstream Aerospace Corporation
MOOG Aircraft Group
To view the complete submission, click here.