Originally Posted by
MechEngr
FAA has always had a divided charter - to promote the aviation industry and to promote aviation safety. Clearly the FAA cannot do both and be effective at both.
Actually the part about promoting aviation was removed from the FAA charter several years ago.
That being said, the FAA is still obligated to consider the 'cost effectiveness' of its various dictates. For example, if you look at proposed (and issued) Airworthiness Directives, it has a section where it estimates the costs of compliance with the intent of the AD.
I completely agree with Global about the delegation vs. ODA. The FAA has used delegation for many decades (DERs and DARs being just one example). The difference being that a DER reported
directly to the FAA (I was a DER for nearly 20 years before Boeing went ODA). DERs were selected by the FAA, and I had an FAA advisor that I could contact whenever I had a question or concern. With ODA, everything had to go through the Boeing compliance office - which not only had little knowledge of the intricacies of Propulsion), I was specifically bared from unilaterally contacting the FAA without going through the Boeing compliance office.
It also dumped far more responsibility on the ARs - along with the potential for 'undo pressure' from management. Personally I never experienced undo pressure as an AR (although, interestingly, I did as a DER - my case actually went into the development of the rules regarding undo pressure when Boeing went ODA) - and even had a Supervisor tell an engine manufacture to stop pressuring me when I raised concerns about functionality of a new FADEC s/w that I was responsible for certifying.
I don't know how much of it was the concept of ODA being fundamentally flawed, and how much was just the horrid Boeing implementation, but many of us raised concerns that the Boeing ODA was flawed and bound to fail.