ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

ARSA Submits Comments on OMB Good Guidance Practices

ARSA has recently submitted comments on a draft bulletin, issued by the Office of Management and Budget (OMB), concerning the issuing of guidance by Federal agencies. The bulletin includes policies and procedures for agencies to develop, issue and use guidance documents.

OMB has been particularly concerned that agency guidance practices should be more transparent, consistent and accountable. Because guidance documents often do not receive the benefit of careful consideration accorded under the procedures for creating regulations, this bulletin stresses that agencies should follow established and effective procedures in developing guidance. This will help ensure that Federal agencies do not engage in rulemaking through guidance.

In its comments, ARSA thanked the OMB for issuing such an important bulletin, and cited examples where the FAA has used guidance documents as rulemaking. Additionally, ARSA made several suggestions which, if adopted, will increase the OMB’s ability to review guidance documents and make them more easily available to the public. These revisions would force agencies to identify affected parties even if documents are labeled as “internal.”

To download a .pdf copy of ARSA’s comments, Click here.

To download a .pdf copy of the OMB draft bulletin, Click here.



More from ARSA

ARSA’s Filler to Lead Panel at FAA-EASA Conference

Marshall S. Filler, ARSA managing director and general counsel, will moderate a panel on “aviation maintenance in the digital era” during the 2018 FAA-EASA International Safety Conference in Washington, D.C.…Read More

Tell Congress to Support Maintenance Workforce Bill

Members of the aviation maintenance community need to join ARSA’s aggressive effort to include the association’s workforce development legislation in the FAA reauthorization process. The bill would create a new…Read More

Travel Well with “Going Global” Regulatory Training

International markets mean expanded business opportunities that require an expansive regulatory understanding. Working on your global knowledge with two on-demand training sessions from ARSA Managing Director & General Counsel Marshall…Read More

AMT Day 2018 – How Will You Celebrate Charlie?

Charles Taylor Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 150 years later – we celebrate him with every…Read More

Industry Sets Remote Connectivity Baseline for FAA

On May 7, ARSA and 15 of its aviation industry allies jointly submitted a draft advisory circular to the FAA providing “guidance for using remote connectivity technology and tools.” The…Read More
ARSA