Disclaimer: The FAA employs over 35,000 individuals, a great many of whom are smart, capable, and dedicated to the advancement of aviation. The fact that I have never, personally, met such an FAA employee in no way confutes the existence thereof.
There are two types of amateur pilots: those who fly for the sport, and those who fly for the science. The sport flyers are content to yank and bank and spin themselves dizzy. They’d rather execute a forward slip than drop flaps, and consider getting an airplane down and stopped before the first taxiway a noble aspiration. Their counterparts, the scientific flyers, relish perfect holding-pattern entries, flawless DME arcs, and partial-panel ILS approaches to ATP standards. In time—usually around two-thousand hours—these proto-aviators evolve into professional pilots whose interests incline more toward accruing seniority and bidding prime routes than sport or science. Asked what they love about aviation, journeymen pilots will cite handsome suburban homes, German motorcars, and challenging par-5s. Asked what they hate, they’ll resoundingly respond, safety management systems.
According to the FAA, Safety Management System (SMS) means the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk. A high-time, heavy-iron PIC I interviewed for this article offered a more colorful definition. He described SMS as a red-tape noose with which the FAA seeks to hang pilots by their genitals.
This interpretive disparity confused me. Historically, safety has been a topic upon which the FAA and pilots generally agree. Knowing this heavy-iron PIC to be a squared-away chap, I asked him to elaborate. “What is it about your company’s SMS protocol that compels you to liken it to ritualized castration?” I inquired.
For a long moment, the heavy-iron PIC regarded me as a tenured professor regards the class dullard. “Okay,” he sighed wearily. “Let me break this down for you. SMS is window-dressing. It’s a blame allocation mechanism that functions on the fatuous premise that the risks inherent packing people into aluminum tubes and blasting them through the upper atmosphere on columns of burning jet fuel can be mitigated with paperwork. Plainly stated, SMS seeks to supplant pilot expertise and experience with flowcharts, worksheets, and simple math.”
“That’s nothing new,” I countered.
“Nothing new?!” the heavy-iron PIC blurted. “What are you on about? This SMS nonsense has only been around for a few years. If memory serves, it was mandated in 2015.”
“Never mind,” I said dismissively. “Just tell me more about SMS.”
“As you wish,” the heavy-iron PIC obliged. “Like I was saying, SMS is a knee-jerk idiocy cobbled together by politicians and bureaucrats more concerned with optics than results. Like all crackpot notions hatched in committee, it’s needlessly complex and self-indulgently bloated. The aspect of it with which pilots most often contend is a preflight worksheet that, ostensibly, quantifies the risks associated with the prospective flight.”
“A worksheet?” I smirked. “Seriously?”
“Oh, yes,” the heavy-iron PIC asserted. “Aside from important preflight preparations like assessing weather, route planning, calculating fuel requirements, selecting takeoff and landing alternates, and coordinating customs, I now have to count boogeymen and enumerate them on an asinine worksheet.”
“Boogeymen?” I asked. “You have to fill out a boogeyman worksheet?”
“The official parlance is Operational Risk Assessment Checklist,” the heavy-iron PIC grumbled, “but it’s really just a worksheet drawn up by management, a worksheet that assigns numerical values—hazard values, if you will—to what the FAA calls identified hazards. Night operations have a higher hazard value than day operations. IMC conditions have a higher hazard value than VMC conditions. Mountain airports have higher hazard values than their flatland counterparts. Low-time captains have higher hazard values than high-time captains. You get the picture.”
I nodded in the affirmative.
“The combined values of all the hazards pertaining to a particular flight constitute a score,” the heavy-iron PIC went on. “That score is called an Operational Risk Assessment (ORA) value. In my company, ORA values of 15 or more require Chief Pilot authorization.”
My guts knotted. “Are you telling me that your PIC authority is less than absolute?!” I demanded.
“Yes and no,” the heavy-iron PIC wavered. “The Chief Pilot can only prevent me from accepting the mission, He can’t force me to go.”
“But he can override your decision to undertake the flight?” I marveled.
“Yup,” the heavy-iron PIC affirmed. “And let me tell you, I’ve seen differences of opinion between experienced captains and inexperienced Chief Pilots turn ugly; but I’ve also seen a Chief Pilot lose his job for disallowing too many big-money flights. It’s a slippery slope, this SMS rubbish—for everyone. In any case, even the Chief Pilot’s opinion goes out the window if the ORA value for a proposed flight gets too high. At my company, ORA values of 20 or greater occasion an automatic no-go.”
“So,” I hazarded, “you’re obligated to triangulate your go/no-go decision with the Chief Pilot if the ORA value for a prospective flight exceeds 15?”
“That’s right,” the heavy-iron PIC confirmed.
I shook my head in disbelief. “And if the ORA value for a given flight is higher—let’s say, 18–and you bring it to the Chief Pilot’s attention, and he lets you go—”
“And I crash?” the heavy-iron PIC took up my line of thought.
“Yes,” I acceded. “What happens then?”
“Then,” the heavy-iron PIC said fatalistically, “I’m dragged before the FAA to endure the usual, post-accident blood-letting; except now, the FAA has an SMS worksheet that casts specious aspersions on weather, darkness, instrument approaches, and a thousand other, wholly normal flight conditions that I’ve been exhaustively trained to competently manage. In the end, some pencil-pusher who hasn’t logged an hour of flight-time in fifteen-years will burn me down because I had the audacity to proceeded with an aircraft operation that exceeded an imaginary threshold set by a preposterously quixotic document.”
The heavy-iron PIC’s frustration was obvious and—I had to concede—justified. I was about to tell him as much when he doubled-back to a former point in our conversation.
“What was it you meant about SMS being nothing new?” he asked.
“SMS?” I smirked. “I wasn’t talking about SMS. It’s the FAA’s push to legislate pilot expertise out of existence that isn’t new”
The heavy-iron PIC eyed me curiously. “Go on,” he urged.
“I’ve seen it before,” I said, “a long time ago …”
… A long time ago, in Alaska, on the salt-bleached streets of Spenard, between Ted Stevens Airport and Gwennie’s Old Alaska Restaurant, a bloody war was fought between the Anchorage FSDO and a swashbuckling young aviator who’s love of flying was surpassed only by his hatred of bureaucratic idiocy. The aviator was bright and likable, but his defining characteristics were focus and ambition. He’d paid for his own flight training, working sixty-hour weeks and sleeping on a succession of friends’ couches until a Seattle flight-school offered him a CFI position. He was lucky too, this aviator, and by dint of a little good fortune and a great deal of hard work, soon found himself flying King Airs for a Tacoma financial company. Aircraft lease agreements brought the aviator to the attention of a large, Part 135 operator on Seattle’s Boeing Field which offered him a better job and the opportunity to transition into more advanced aircraft. Type ratings in Learjets and Hawkers ensued, and in short order the aviator was living his dream.
Years passed. Bill Clinton behaved badly, Boeing delivered the first 777-300 to Cathay Pacific Airways, and the Part 135 operation for which the aviator had gone to work flourished. More years passed. The 20th Century drew to a close, and in the last weird months of that alternately bloody and beautiful epoch, the aviator was hoisted from the line-captain rank and file and named Chief Pilot of an operation that had grown to 44 aircraft and 100 pilots. Times were good. Commerce was vigorous. Bush had beaten Gore and the dot-com bubble had created immense, paper wealth. Down BFI way, the connerie riche were queueing to charter jet-aircraft and fill them with high-priced prostitutes and Louis Roederer Champagne. The aviator’s luck had held. He had reached the top of his profession at age 32—a full year younger than Edmund Hillary had been when he summited Everest.
Twenty-three-hundred miles north, far from the new Chief Pilot, Boeing Field, dot-com millionaires and their demimonde companions, soulless beasts skulked and amassed their venom in the cold, drab halls of the Anchorage Flight Standards District Office. A conflict was in the offing, one that would pit expertise and pragmatism against incompetence and pedantry.
In January 2000, the new Chief Pilot was summoned to Anchorage to make his obeisance before the Principal Operations Inspector to whom he and his employer were accountable. Subject POI was a decent, reasonable chap whose flight experience made him a good fit for the flourishing Part 135 operation. The new Chief Pilot prostrated himself in accordance with accepted hierarchical norms and all might have been well had the decent, reasonable POI not announced his impending departure from the FAA’s employ and the imminent assignment of an interim POI. This interim chap’s flight experience comprised primarily single-engine, VFR, seaplane operations. He had never flown a turbine aircraft, let alone a straight-pipe jet. When the new Chief Pilot voiced his concerns about a career Cessna-206 driver overseeing ten Gulfstreams, a dozen Hawkers, and twenty Learjets engaged in 24-hour, all weather, on-demand charter operations, the outgoing POI replied as any soon-to-be-ex-fed with a line on a cushy, civilian job would—he informed the new Chief Pilot that the cookie had crumbled, and wished all concerned parties good luck.
To the new Chief Pilot’s surprise, the interim POI wasn’t as bad as he’d expected—he was worse. Far worse. The first meeting between the two was a worrying preview of the difficulties with which the following months would be fraught. Tempers flared as the two men realized each was the other’s antithesis. The new Chief Pilot’s casual confidence infuriated the interim POI whose dearth of jet experience engendered a pathological insecurity for which he compensated by harping constantly about insignificant peripheral matters—paperwork mostly. For all his ignorance of jet aircraft and their practical applications, the interim POI was gifted bureaucrat whose propensity for pushing paper and dispensing red tape approached genius.
In the winter of 2002, the interim POI, whose tenure was leaning increasingly toward permanence, tasked the not so new Chief Pilot with the creation of an Operations and Maintenance Placarding and Procedures Manual. The fact that such a manual was neither required nor recommended by the FAA, DOT, NTSB, or any other regulatory body in no way dissuaded the POI from ordering its creation. When the Chief Pilot inquired after what an OMPP manual should contain, the POI instructed him to populate the thing with descriptions and breakdowns of every operational procedure not addressed in the flourishing certificate holder’s Part 135 manual, Ops Specs, AFMs/POHs, or the FARs.
The Chief Pilot, lacking the POI’s capacity for self-delusion, argued that such a manual could not be created insomuch as it sought to quantify, catalog, and prescribe procedures for an infinite number of aviation scenarios, foreseeable and otherwise. Politely, but firmly, the Chief Pilot suggested that the POI was an idiot, and that all the manuals in the world could not replace the expertise of an experienced airman. The Chief Pilot went on to point out that belief in the possibility that expertise could be superseded by a manual spoke to psychosis, and that the POI would do well to consult his flight surgeon for a psychiatric evaluation. This suggestion angered the POI, who gave the Chief Pilot thirty days to concoct the OMPP manual, then curtly dismissed him from the Anchorage FSDO.
For two fortnights, the Chief Pilot labored. He wrote and rewrote. He cut, pasted, and when necessary plagiarized. The document he created was a masterpiece of useless, self-evident, rhetoric reminiscent of a textbook for special-needs kindergartners. The work encompassed procedures for removing aircraft control locks, stowing passenger baggage, and parking aircraft on varying ramp surfaces. An entire chapter was dedicated to properly applying INOP stickers to MEL’d equipment. In all, the undertaking comprised over one-hundred pages of remedial drivel.
A week after submitting the completed manual for review, the Chief Pilot received a letter from the POI stating that FAA approval would not be forthcoming. A problem had been identified in the chapter addressing the parking of aircraft on uneven or sloped, airport surfaces. This vexed the Chief Pilot who contended that the subject of where and how to park company aircraft had been addressed comprehensively. To substantiate his assertion, the Chief Pilot cited text directing flight-crew members to position parked aircraft into the wind; to utilize pitot-tube covers; static-port, and engine plugs; to install rudder gust locks; and to chock all parked aircraft, regardless of attendant ramp personnel and ramp conditions. The POI was unimpressed with the Chief Pilot’s contention, however, and pointed out with insufferable smugness that the manual failed to spell out how to fit pitot-tube covers, or chock tires. This further vexed the Chief Pilot, who unreservedly acknowledged that his manual contained no instructions for how to chock a tire—just as it contained no instructions for how to don a headset, grip an aircraft control yoke, or zip one’s trousers after using the aircraft head.
“Hold on,” the heavy-iron PIC interrupted. “There’s no way a Chief Pilot openly and aggressively attacks an FAA Inspector and keeps his job. This guy you’re describing, this young Chief Pilot who called his own POI an idiot—”
“Suggested,” I clarified. “He suggested the POI was an idiot.”
“It doesn’t matter,” the heavy-iron PIC countered. “He’d be lucky to only be busted down to his old, line pilot job.”
“True enough,” I agreed, “but that isn’t the point.”
“Oh, I see the point,” the heavy-iron PIC remarked. “The point is, the FAA—like most governmental agencies—prefers systemic mediocrity to individual excellence. It’s far easier to regulate automatons than high-functioning experts. The latter are complex, nuanced, and difficult to constrain in legislation. No boss wants to run a shift full of master craftsmen who know the work better than he does.”
“Good analogy,” I commented.
“It gets better when you take into account the rather curious fact that a great many FAA Inspectors are failed pilots and general non-hackers,” the heavy-iron PIC concluded.
Almost three-weeks have passed since the interviews for this writing were conducted. Notwithstanding the invaluable input of no less than nine professional pilots, my thoughts have lingered stubbornly on the heavy-iron PIC. His sharp words and acerbic tenor belied a profound sadness—a grief deriving of an unstated but deepening belief that his epoch aloft was drawing to a close.
The joy he’d taken in urging great, shining machines skyward was dead—snuffed by federal agencies more interested in avoiding controversy and litigation than pursuing probity and progress. He’d seen the last days of aviation’s frontier—the heavy-iron PIC had. He’d flown first for the sport, then for the science, and finally for the pay—but always for the freedom. And now, the freedom was gone. Regulatory overreach had made a black and white monotony of the wild blue yonder. A great, intrusive, all-seeing lens had been fashioned from SMS, ADS-B, and ASRS. In Washington D.C., politicians had hatched the blatantly condescending, Pilot Professionalism Assurance Act. This tyrannical travesty proposed to allow airlines to review cockpit voice recordings when cases were brought against pilots for misbehavior—or to evaluate or monitor the judgment or performance of an individual pilot. The heavy-iron PIC knew a witch-hunt when he saw one, even if the thumbscrews and stakes and flames had been swapped out for satellites and digital processors.
And he isn’t alone. User 123494 at Tapatalk’s Airline Pilot Forum states:
I’m an airline pilot who is beginning to realize that this job isn’t for me. I like flying airplanes, but all the BS with management, COVID, and having to CYA for nearly every little thing has gotten me sick of the job.
Internet forums like Quora, Reddit, and Yahoo! Answers abound with similar posts by pilots on the cusp of fleeing the airlines to pursue terrestrial careers. A distressing number of these disheartened aviators are hanging up their wings to take jobs as plumbers, HVAC technicians, and cops. That pilots would rather face armed felons than go on operating $400M aircraft to glamorous destinations is a scathing indictment of an industry lethally middled between the pilots who give it life and the politicians who give it leave to live—between utopian notions of eradicating risk and the gritty realities of managing it.