GUEST EDITORIAL. If you had any doubts about why the FAA's new Form 2150-7 "ticketing" procedure is a bad idea, consider the recent case of the Florida FAA inspector who tried to ground a Cessna 182 because the pilot couldn't produce a Form 337 for its yoke-mounted handheld GPS! FAA-designated Aviation Safety Counselor (and AVweb reader) Ron Levy lays out the sorry details in a letter to Administrator Garvey. Good grief! With incidents like this one, is it any wonder that users are up in arms about the FAA's new "frontier justice" program?
May 28, 1998
Ms. Jane F. Garvey
Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, D.C. 20591
Dear Ms. Garvey:
A recent incident demonstrates a number of problems with the current system of FAA
handling of alleged violations, and why you were absolutely right to put a stop to the
Form 2150-7 "ticketing" plan.
A couple of weeks ago, a pilot parked his Cessna 182 on the ramp at a Florida GA field.
The pilot's hand-held GPS was clamped to the yoke, with one cable leading to the cigarette
lighter and another leading to an antenna suctioned to a window. An FAA inspector
wandering down the ramp saw the airplane, peered through the window, and saw the GPS. He
posted a correction notice on the 182, stating that the aircraft was unairworthy unless
the pilot had a 337 for the "installation" of the GPS in the aircraft, along
with updated weight and balance data including the GPS, mount, and antenna. The pilot
involved was rather upset, since the use of yoke mounts for handheld GPSs is very common,
and he had no idea that this constituted a major alteration or installation requiring a
337. He spoke to a friend who is an experienced professional test pilot, who also was
surprised. The test pilot asked several other pilots, including me, if they'd ever heard
of such a thing. Clamping hand-helds to the yoke is a very common practice, and none of us
had ever heard of any objections by the FAA before.
I am one of your Aviation Safety Counselors one of the volunteers out here who
assist the FAA in promoting aviation safety. In case you're unfamiliar with this valuable
program, we are highly experienced ATP/CFI pilots who, without compensation (we don't even
get mileage) assist the Aviation Safety Program Manager at our local FSDO in the
development and conduct of aviation safety programs. In many ways, we also act a buffer
between pilots and the FSDO, as pilots will often ask us questions or raise issues that
they hesitate to discuss with FSDO personnel for fear of resultant enforcement action. As
such, I have a number of contacts inside the FAA that other pilots don't, and I called on
one of them, [name withheld to keep his phone from ringing off the hook], who has assisted
me on maintenance documentation matters in the past.
I started to tell him the story, and when I got to the part where the inspector was
"wandering down the ramp," my friend started to laugh and interrupted me.
"Don't tell me," he said, "the inspector gave him a correction
notice." When I said yes, he expressed considerable chagrin.
He went on to say that this is not an "installation" and requires no
paperwork. I asked what should be done, and he told me to have the pilot get in touch with
the manager of the inspector's FSDO, and explain the situation.
The manager should tear up the paper and sort out the inspector on what is legal and
what is not. Further, my friend provided the names of two people in the proper section of
the Regional office to whom the issue should be elevated if the FSDO manager didn't get it
right. And he told me that he's proud to be one of those FAA employees who "loves the
smell of avgas in the morning." Although he works on the maintenance side, he's an
active GA pilot, and flies as much as he can. He also suggested that the pilot be advised
to leave the GPS under the seat rather than on the yoke while parked not to avoid a
repeat of the incident, but to avoid theft of the GPS, which I thought to be excellent and
It's a good thing this happened under the current system, as it allowed the situation
to be resolved with no entries in the affected pilot's record. It's a good thing the pilot
involved was part of a network of people with the knowledge, contacts, and authority to
fix the situation before it got out of hand, and to do so without running up anyone's bill
for legal advice or wasting a lot of FAA time. It's too bad that there are inspectors out
there who aren't trained well enough to tell what is or is not an actual violation of the
rules, and what is or is not serious enough for a correction notice (which starts the
paper trail) rather than a quiet note or low-key discussion pointing out the problem. It's
too bad there are a lot of pilots out there who don't know anyone who can help them if a
misinformed inspector lays paper on them.
Unfortunately, this isn't the first time something like this has happened the most
famous was the Q-tip propeller incident at Hawthorne, California, a couple of years ago
and it probably won't be the last. Now, I have no idea how big this problem is, whether it
involves a tiny fraction or a large portion of the correction notices written. I have no
idea whether this involves a small or large portion of the inspector force. And I have no
idea how many of the inspectors involved were counseled or retrained as a result, much the
way pilots are often assigned remedial training after their involvement in a rules
What seriously concerns me is that I don't think you know, either. I hope you, in the
wake of your wise decision to cancel the Form 2150-7 program, will initiate a thorough
examination of the system to ensure that the inspector force is trained properly not only
in what is legal, but also what is appropriate. Failure to do so will perpetuate an
adversarial relationship between pilots and the FAA which cannot help but degrade
significantly the effectiveness of the FAA in doing its most important job making
Ron Levy, ATP, CFI, Aviation Safety Counselor
Unfortunately, reports of Administrator Garvey's "wise decision to cancel the Form
2150-7 program" appear to have been premature. FAA inspectors have now been trained
in this new program, and our best information at this point is that the Administrator has
only placed the program on temporary hold in order to review various industry objections.
For details on how this new enforcement program operates and why we think it's unfair to
airmen, read Phil Kolczynski's article "Ramp Check '98:
The FAA Inspector as Traffic Cop."