The FAA is writing mandates, but federal coordination systems can’t keep up
By Laura Crabtree
Laura Crabtree is CEO and co-founder of Epsilon3. She previously served as a lead operations engineer at SpaceX.
On January 29, 2025, PSA Airlines Flight 5342 descended toward Ronald Reagan National Airport with no warning of the Army Black Hawk closing on its path. The CRJ-700 jet had ADS-B Out — the technology the Federal Aviation Administration mandated across most of the fleet in 2020. It did not have ADS-B In, the capability that would have shown the approaching helicopter to the crew, because the FAA had not approved ADS-B In installation for that aircraft type.
This certification gap shows the structural problem Congress is attempting to solve. The ROTOR Act and the ALERT Act each propose required collision-avoidance technology across large swaths of the national fleet. But regardless of which act eventually moves toward passage, unless the FAA, its federal partners and industry build the execution capacity to support these mandates, these policies will be difficult, if not impossible, to implement.
Let’s examine what the FAA and federal government are up against.
The certification pipeline is already full.
Every new avionics installation on an existing aircraft type requires an FAA Supplemental Type Certificate (STC). But application volume is capped by the agency’s capacity to process requests. The Transportation Department’s Inspector General has documented 138 certification applicants who waited more than three years for action, with one application pending since 2006.
The need for skilled talent at the federal level compounds the problem directly. Approximately 400 probationary FAA employees were terminated in early 2025, and more than 1,300 accepted early retirement — including aviation safety technicians and certification engineers. Any congressional mandate to retrofit thousands of aircraft arrives on a certification pipeline operating below its 2020 throughput, and rebuilding federal capacity won’t happen overnight.
Repair stations and workforce constraints limit capacity.
The U.S. has more than 30,000 retrofit-eligible aircraft but only a few hundred repair stations qualified to do this kind of avionics work, placing an even larger burden on an already strained capacity.
The aging workforce compounds the problem. The median age of the certificated aircraft mechanic is 54. The Aviation Technician Education Council projected a shortfall of more than 5,000 certificated mechanics against commercial aviation demand in 2025 — up to 18,000 including non-certificated roles. On the government side, the looming retirement cliff is even steeper: only 8% of federal workers are under 30, according to Office of Personnel Management data.
These senior avionics technicians and their federal counterparts carry institutional knowledge that has never been systematically captured. That loss is the difference between a program that finishes and one that generates defects and delays for years afterward.
The market structure does not permit new entrants to close the gap.
A retrofit mandate assumes the market will scale up to meet the new requirement, but federal certification rules make that nearly impossible. Certification takes years and costs millions, qualified installers are locked into incumbent original equipment manufacturer (OEM) agreements, and installation slots are already full. As a result, any federal mandate funnels demand straight back to the same small group of suppliers operating within the system, with no competitive acquisition mechanism to accelerate throughput.
The Pentagon’s recent moves to encourage competition from defense startups and accelerate research and development offer a critical demand signal that allows disruptors to access the capital they need and pushes incumbents beyond business as usual. Innovation is possible, but only if the government actively makes room for it.
The software workaround carries its own unfunded burden.
Some lawmakers have proposed letting pilots use existing tablet apps — tools like ForeFlight or Garmin Pilot — to display traffic and collision alerts. But this software does not have the FAA certification appropriate for this purpose.
Moreover, this workaround comes with serious cybersecurity risks. Any operator of an e-enabled aircraft — which this solution would create — must comply with the FAA’s requirements for an Aircraft Network Security Program (ANSP), an expensive and highly technical mandate that most airlines have yet to implement. The potential cybersecurity threat vectors on connected aircraft are novel, and the overhead of ANSP introduces elevated requirements that airlines, OEMs, and the FAA are not currently prepared to handle.
What failed at Reagan National was upstream of the aircraft. Between October 2021 and December 2024, FAA systems recorded 15,214 close-proximity events between commercial aircraft and helicopters at DCA. An internal FAA working group recommended relocating the helicopter corridor in 2013, but the recommendation was shelved.
In December, the Transportation Department and FAA awarded Peraton a multi-billion-dollar contract to serve as prime integrator of the brand-new air traffic control system. The program addresses the ground side of the system, but it does not fund avionics retrofits, nor expand STC throughput or MRO capacity. It also does not build the inter-agency coordination between the FAA, the Defense Department, airport operators, and commercial carriers that the NTSB found had failed catastrophically leading up to the Reagan National collision — a coordination failure that no amount of hardware investment will fix on its own.
These preventable coordination problems require coordination infrastructure.
The prescription: Build the execution infrastructure.
I spent a decade in commercial space launch — an industry where civil, military and commercial stakeholders coordinate safety-critical operations across stakeholders on timelines measured in hours. Launch campaigns run on streamlined configuration-controlled procedures across teams, executed with visible shared state, audited in real time, and updated against what actually happens. Institutional knowledge is captured in the system of record rather than in the heads of people who happen to be in the room.
The federal aviation system does not have this coordination infrastructure. Inter-agency procedures live in PDFs; hotlines are analog and coverage is inconsistent. Expertise lives in the memories of retiring mechanics, and the FAA is operating with 6% fewer controllers than a decade ago against 10% more flights. Every new legislative mandate adds workload to a federal coordination layer already operating past its limits, without funding the capacity needed to absorb it.
The FAA and its federal partners must prioritize developing a shared execution infrastructure. They need a system that accelerates STC procedure execution, audit package creation and compliance documentation — compiled against the specific configuration of a specific aircraft type, and exchanged with the FAA through a defined interface rather than fragmented submission practices. A stronger audit capacity solution would also solidify more streamlined, executable processes that can support new auditor training, faster output, more capacity for retrofits, lower costs and faster approvals within the FAA. Federal contractors with experience in safety-critical operations management are positioned to support this modernization, but only if the FAA defines a clear acquisition path for these capabilities.
Requirements without implementation capacity produce paper compliance, not safety. Congressional mandates without a coordination substrate produce equipped aircraft operating in the same fragmented environment that killed 67 people at Reagan National.
Congress and the FAA need a bolder, more complete re-imagining of the nation’s integrated aviation safety infrastructure: one that pairs every new mandate with the funded federal capacity to execute. For industries like aerospace and aviation where operational failure puts lives on the line, system coordination is a matter of life or death.
The space launch industry engineered its coordination model deliberately because the alternative was unacceptable. Aviation has seen these painful results of failure time and time again. The FAA, Congress, and the broader federal aviation enterprise have the power to change course. They need to take action now to prevent another tragedy.
