It was one of those off-handed remarks that for some reason stuck with me. In fact I don't even remember who said it or the circumstances under which it was said but I think I remember it because of the, uh, makeup of those in attendance. I can't remember who they were but they were captains of aviation industry and they were talking about the 2024 election-back in about 2022.
On one hand, I agree as someone who develops requirements and does stakeholder engagement and management in my day job. On the other, if the goal is a reduction in government regulations, you can’t rely on the approach you suggest because the stakeholder approach is not incentivized to reduce bulk and complexity in regulations. Here’s a thought exercise for you. MOSAIC is still possible under a two-for-one rule with some effort. You combine experimental, light sport, and standard (under 12,500 lb gross) categories into one simplified category, and you construct the new regulations to have an effect rather than specify the details but much further than MOSIAC took it. Just look at the mess the stall speed requirement under MOSAIC created because stall speed was an imperfect metric at best and a poor metric at worst for the effect they were trying to achieve. And MOSAIC is still extremely verbose. You eliminate 2, maybe 3, airworthiness categories and get 1 back. Q.E.D. But the FAA’s slow and meandering ways, in fact all of government’s, are not suited to this approach. One of the only exceptions I know of is 47 CFR 97 where they allow a community planning and policing approach. On the other hand, the complexity and politics simply shifted from the government to elsewhere.
Its laughable to think larger twins, turboprops, pressurized airframes and light jets (Mustang/Vision) would be certified in the same way as experimental and light sport.
Two-for-one, if implemented, will be the policy in the aggregate. Two public mental health policies will be dumped and one (MOSAIC) will be retained, for example. Retain/innovate vs ridicule/eradicate will be a function of the amount of business interests backing a given rule.
Maybe it shouldn’t take a law degree to understand the regulations that apply to a particular thing.
A great start would be incorporate the myriad legal interpretations and orders that alter or redefine the rules. Some of these date back decades and, should you not know where to look for them, could have drastic negative implications for you.
The approach worked well last time. We should look forward to reduced bureaucracy and smaller government, less fraud, waste and abuse. There will always be opposition to ideas, even good ones.
I think what gets missed in the call for deregulation that will be a theme of the next four years is that regulations are crafted in consultation with the stakeholders like those folks who were talking about it a couple of years ago. They spend thousands of hours writing letters, talking on the phone and yes, arm twisting politicians trying to make sure the new rules reflect what’s needed for their business.
I would agree with this when stakeholders request a particular piece of regulation. Often, however, a rule is proposed and stakeholders consult because they must; if they don’t they are crushed in an avalanche of paper like the rest of us.
Absolutely looking forward to it! The policies of the last 4 years were not sustainable. I beleive many Americans learned they have to vote for policy over personality.
I’ll take my chances with the new gang that will be in charge come January 20th, 2025. My economic well being and overall quality of life was much better under that Administration than it has been under the current “Gang that cannot shoot straight” that is in Power now!
I was in the Defense Department the last time around. The way it was handled there was a complete review of all regulations. Every office responsible for particular regulations (in my case, I was in Acquisition, Technology, and Logistics) had to justify keeping a regulation or to suggest how that regulation could be merged with other, similar regulations. Justifying a regulation began with identifying the statutory authority or requirement for the regulation. For example, something in a Defense Authorization Act that included, “the Department shall publish regulations that…” Apart from simple statutory justification, it is really amazing how many regulations are duplicative of other regulations, either in whole or in part, create apparent contradiction with other regulations, or just pile one on top of another. In this review, identifying opportunities for combining regulations can reduce the size of the regulations, just in the process of merge and edit. Hypothetically, you could combine three regulations into one, and that revised regulation would be perhaps only a little longer than one of the originals. This is aside from identifying regulations that were written for another time and have been overcome by events, other processes, or technology.
Remember, though, the requirement was to IDENTIFY regulations to be removed. That removal would still be subject to the normal regulation review process, which could wind up keeping or further amending that regulation.
The general goal is good but it will be messy, especially with TheMouthX and TheMouthT making decisions.
As for stakeholders, some of them should want regulations written more competently thus clearer - that often
There’s a problem with legalities, recall some in this forum wanted detail rather than FAA making judgements, note shysters spend court time trying to wriggle their customer out of penalty for bad/illegal behaviour.
And problems with government employees, such as:
Henry of Transport Canada who had to be pointed to the AC allowing what he objected to (a verbose AC even back then in the 1980s)
the MIDO Seattle person who consciously did not obey an HQ directive (that office may have been feeling legal sting for giving a flight permit to a prototype to fly from Oregon to OSH, it disappeared enroute).
yet Seattle FAA used 500 miles on a flight test permit for a DC-8, test almost cancelled due weather as good weather for air work was a bit over that far away (originally forecast suitable in region but weather does vary, fortunately it cleared in time to complete that costly exercise)…
What’s needed is clear enunciation of principles, coaching during the work, and firing as needed.
The “Two-for-One Rule” is a flawed, arbitrary policy that prioritizes optics over substance. It risks safety, innovation, and public welfare by undermining critical regulations in aviation, workplace safety, and environmental protection.
One more thing, Russ. You usually avoid political commentary, but this piece quietly critiques the “Two-for-One Rule,” highlighting its flaws, possible comeback, and how it ties into broader governance issues. Good read!