Originally Posted by
tdracer
I've touched on this before in other threads, but the FAA has experienced it's own "brain drain" problem. I was a DER/AR for over 25 years before I retired. Must of the FAA people I dealt with were in the same age group as me - and now many if not most of them have also retired. Further, for a long time, many of the people at the Seattle FAA office were ex-Boeing (often disgruntled ex-Boeing but that's another story). They had real world experience working with aircraft systems, and it showed. The last few years before I retired, the new youngsters coming it simply had no real world experience - fresh faced kids right out of college with minimal mentor support from those with decades of experience. They were into box-checking without really comprehending what the meaning of those boxes was. Submit such and such document, check the box. They lacked the deeper understanding what checking those boxes meant - and hence lacked the judgement to determine if something was really safe regardless of if they could check their box.
I found it extremely frustrating trying to deal with them - submittals would get rejected for ridiculous reasons (seriously - I had a submittal rejected because my 8110 form listed one of the effected models as the 747-SP, when the TCDS says 747SP), and I frequently had to explain very basic aspects of the submittals that anyone familiar with commercial aircraft should know (again, seriously - I had to explain "EGT").
My experience has been similar. I actually like working with the FAA and most of the guys are pretty good. There are great guys in the FSDO in KORL, KABQ, TAD, MIDO ATL, ACOs in LAX... etc.. some are really good. Others make you shake your head.
example: We were asked to determine one device had no chance to the wing loads of the wing.... of a Boeing. A nontrivial matter. Proving a negative sounds like good scientific process, but has its own issues. So we thought about it, did some flight tests with a couple of jets and decided the most effective way of doing that was to use imaging of targets on the wing through a registered gnomon. It was pretty neat, and much later, we found that it was similar to a process that Airbus had tried and found effective for the same application. It was possible to determine the change in the spanwise and chordwise bending of the wing to a load, and we were able to use accelerated flight to prove the exact deflection to load that occurred. We got to the point of having to explain that with a steel ruler clipped to a table edge and moving the ACO's engineers pen along the beam of the ruler to show that, surprise, surprise, bending changes dependent on the arm and mass(force) applied. Even with that we ended up having to do other methods to actually get the ACO guy to accept the data we provided. Similar matter on ice accretion certification. After years of communicating with NASA Lewis on LEWICE modelling, they advised that the FENSAP modelling was so superior they recommended using that instead, and we did find that spectacular in it's realistic modelling of icing, and in fact of flow dynamics in the boundary layer and even sub boundary layer. And it is not approved by the FAA, even with the enthusiastic support of the FAA Icing Resource at that time, of Boeing, etc... so we are left with nonsense sus scale testing in the ice tunnel out of Bethpage, or doing in-flight icing modelling which is an absolute waste of time, resources and acts as an impediment to development while increasing flight test risk.
To make one point, we did a flight test in a military jet that had the ability to set up a known asymmetry in loading at a known arm to determine the impact on lift from the device we were certifying, the fact that lift and drag are orthogonal took some effort to achieve comprehension. We were able to prove measurable lift variations in the order of 30ft.lbs, which on a total lift of 8500lbs is pretty high resolution, around 0.1% change.... and that was not able to be comprehended by guys with aeronautical engineering degrees and years of experience in the OEM's prior to being brought into the FAA.