ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

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.

To see all the ways ARSA works on behalf of the aviation maintenance industry, visit the ARSA Works page.



More from ARSA

ARSA Files Brief in Accountable Manager Litigation

On July 17, ARSA filed an amicus brief urging the Ninth Circuit Court of Appeals to reconsider the relationship between the regulatory responsibility of an “accountable manager” and his or…Read More

U.S. Signs Maintenance Agreement with Singapore

On July 12, the FAA signed and released the initial Maintenance Agreement Guidance (MAG) with the Civil Aviation Authority of Singapore (CAAS). The MAG details the agencies’ responsibilities under the…Read More

Online Training – Building a Positive Government Relationship

This session provides a roadmap for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators,…Read More

2017 NextGen Awards – Celebrate Young Talent

ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association…Read More

[Updated] RCCB to Clarify Guidance on 100 Percent Replacement

Update: On July 11, the FAA responded via email to ARSA’s June 29 request for clarity on the ability of repair stations to replace 100 percent of an article while performing…Read More
ARSA