ARSA Comments on Revised Rulemaking Procedures
On June 29, ARSA submitted comments on the FAA’s proposed revisions to 14 CFR part 11. The purpose of the rulemaking was to improve the clarity and flow of the rules; however, the proposal needed some input from the public to achieve that objective.
For instance, in § 11.27 the agency proposes to enumerate advisory committees from which the agency can receive rulemaking recommendations. This revision is unnecessary. FAA already has statutory authority to form advisory committees, making the proposed additions duplicative. Furthermore, the revision could confuse the public – and perhaps even the agency – regarding the ability to accept rulemaking recommendations from non-enumerated committees.
ARSA also believes agencies should refrain from including website addresses in regulations. If an agency feels compelled to use a web address in a rule, it should only use those that are the least likely to change. Web addresses and similar explanatory information are more appropriate for inclusion in guidance documents.
ARSA maintains that regulations should be clear, concise and free of superfluous text.
To read the association’s comments, click here.
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