Rewarding Weak Oversight

When endeavoring to understand the functioning of a large bureaucracy, such as the Federal Aviation Administration (FAA), it is instructive to look beyond the noble words of senior officials to the factors that affect the pay of those working in the countless cubicles.

Let’s look first at the words of Peggy Gilligan, the associate administrator for safety, which puts her in charge of oversight and compliance with federal regulations for the airline industry (manufacturers and airlines).


Peggy Gilligan, FAA associate administrator for safety

Peggy Gilligan, FAA associate administrator for safety


In announcing a town hall meeting for her subordinates, Gilligan mentioned the matter of customer relationships:

“Let me underscore the bedrock of what it is we do: The mission of safety and service will not change ….

“From now on, ‘customer’ is always a reference to the flying public [emphasis in original]. The Administrator stresses that he doesn’t want any ambiguity about this point and frankly, I agree. So we’re going to use consistency and standardization initiative to continue our efforts to communicate FAA rules and policies in a standard and more consistent manner. This isn’t a question of semantics. Since the word ‘customer’ was causing some confusion about who we serve, we need to make this clarification.”

Three points bear mention:

1) Note that the mission of “service” is not to be changed. Service to whom? Another bit of jargon comes to mind: the “stakeholders”, or those who have an acute and vested interest in the FAA’s oversight, or weaknesses in same. In other words, “service” to manufacturers and airlines. Of course, Ms. Gilligan did not clarify “service” as the unwashed millions of taxpayers who provide her six-figure salary.

2) Observe that Ms. Gilligan agrees with her boss. That’s nice, although loyalty to the Administrator and his policies is a given. If Ms. Gilligan did not agree that “customer” refers to the public crammed into ever more restrictive seating, she could of course resign.

3) Note the use of a prolix title — consistency and standardization initiative — as a heading for nebulously expressing the FAA’s regulatory oversight of the industry (e.g., stakeholders). Indeed, if consistency and standardization of FAA efforts is a problem, with one office taking a hard line on compliance, for example, while another takes a more forgiving attitude, the problem is far more than semantic: it reflects a deeper source of organizational dysfunction that requires in-depth probing, not the superficial use of an awkward new title.


The logo belies deep organizational dysfunction and should have a prominent crack through the face

The logo belies deep organizational dysfunction
and should have a prominent crack through the face


Rife organizational dysfunction is evident from numerous independent reports of FAA failings. These critical reports include those from the General Accountability Office (GAO) and the Department of Transportation Inspector General (DOT/IG). Rather than summarizing their numerous depressing reports of FAA management failings, let me cite from a May 2015 article by Scott Bloch, who headed the U.S. Office of Special Counsel, which dealt with numerous cases of aggrieved and abused FAA whistleblowers:

“Over and over, when the FAA is caught asleep at the wheel, those in charge rattle their sabers, fire low-level individuals and allow the management [who] refuses to play by the rules to stay in power. Soon it all slouches back into a comfy system because the FAA does not like oversight, does not tolerate whistleblowers, and will say whatever it takes for the cameras to stop rolling and the members of Congress to stop having hearings. I know because I shined the light on FAA malfeasance and cover-up for five years when I headed the independent oversight agency, the United States Office of Special Counsel (OSC).”

No doubt FAA employees read Gilligan’s missive with bored tolerance. Far closer attention was doubtless paid to the Outcomes and Expectations document, which directly affects each FAA employee’s performance rating. That rating, in turn, affects salary increases and bonus payments. Below is the part of the Outcomes and Expectations document which deals with “stakeholder” relations:

“- Customer Focus

“This Critical Outcome addresses the degree to which an employee uses customer service in routine and non-routine program, project, and other decisions. Primary measures are the degree of respect that internal and external customers display toward the employee, the use of information on customer needs to assist in priority-setting, the exercise of courtesy and consideration in interaction with customers, and the willingness to seek mutually satisfactory approaches to solutions to problems, and working relationships.”

A few comments are imperative:

1) The banned word “customer” surfaces in an internal document outlining performance expectations of FAA officials as they deal with manufacturers and airlines.

2) Note that the measure of “respect” a stakeholder accords the FAA is a criterion for evaluating said employee (as if that employee had any control).

3) The use of “customer needs” to develop an action plan for the FAA that will be “mutually satisfactory”. In other words, don’t impose deadlines which interrupt business as usual, and don’t demand solutions which require aircraft to be grounded for repairs, or certification of new aircraft designs to be delayed.

Nowhere does the Outcomes and Expectations document place primary emphasis on the FAA employee safeguarding safety. Rather, the document is shot through with admonitions to listen to the “customer” and to “balance” the agency’s desires with that of the aviation industry. Collegiality, not effectiveness, is paramount.

Which type of FAA official is likely to receive bonuses and promotions?

  • The FAA official who is going to treat “customers” in the industry with deference, accommodation, and the minimal approach to safety. Imposing penalties for non-compliance is a subject never broached. Model leadership behavior is expressed as “constructively works with others to achieve organizational goals.”

Or –

  • The FAA official who accords stakeholders a fair hearing and then gets on with ordering compliance with regulations in as rapid a pace as possible, with grounding of non-compliant airplanes or airmen a distinct possibility, with fines to follow. Model leadership behavior is “to improve safety in accordance with regulations without delay.”

Also, one might well ask, which of these two personality types is likely to rise to the level of associate administrator of the FAA? Mr. Go-along-to-get-along or Mr. Get-your-act-together?

The flying public would prefer the latter, but their views don’t count.

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