Anonymous

I believe this regulation discriminates against a few and I’m estimating 1700 inspectors. This rule does not take into account that the FAA employee may be tired of a government job and wants to go back to the public sector or the government employee retires from the FAA or if a FAA employee is fired. The FAA hires normally from someone inside their own district, so chances are they came from the operator they are now regulating. Now if they leave this proposal is stating you can’t work in your district basically even if they are fired. This now makes it so that employee has to move and creates a hardship for there family. The FAA I thought believed in families first this regulation goes against this concept. This proposed regulation is a knee jerk reaction because the previous upper, middle and front line management at the FAA did not do their jobs and these folks have all been replaced. Let’s at least admit that at least two field inspectors in the southwest case notified management and called AFS-1 and he did nothing. The rule should state if AFS-1 does not act based on a field inspectors statements about operators AFS-1 will be replaced and barred from employment with all 121 and 135 operators. I believe that rule will install a safety culture with the FAA management. This should also apply to all regional and office management. I think the problem has been fixed by retirements of these individuals and the rule serves no purpose but creating a hardship for FAA employees that are leaving the agency. The rule should also have been for FAA management not to question violations of field inspectors. The 2150-3 should have a statement excluding management questioning enforcements by field inspectors because of their bios. The 2150-3 should have individual inspectors working directly with legal leaving out management so this doesn’t happen again. This rule also does not cover office management, regional management or headquarters management from taking jobs with airlines, these people are the ones with the power and relationships with the operators and have the final say of the operators. This rule reminds me that if management messes up they punish the little guy and worse leave them without a job. If this rule is still adopted after all the comments it would make more sense to reduce the time to 6 months so not to create a hardship for an individual. He can at least collect unemployment and then go to work without moving. It should also exclude if an employee is fired or retires and should only apply to 121 operators, since the FAA has no data of this perceived action happening under any other part. It is important to note most inspectors have more then one operator. I estimate easily that they are responsible for 30 to 40 at a time and these operators change yearly so it is possible to have oversight of 60 to 80 in a 2 year period. So this rule has now caused that employee who is working hard for the public and this government to not receive a job from 60 to 80 employers.