Join ARSA Ask ARSA Pay ARSA

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

Respond to “First of Kind” Survey on Female Aerospace Leadership

ARSA partner Oliver Wyman has invited association members to support its survey updating the “Lift off to Leadership” report published in 2021 as a joint initiative with the International Aerospace…Read More

FAA Confirms SMS Compliance Dates Under U.S./EU Bilateral

On July 8, the FAA published InFO 24007 confirming the compliance dates for U.S. repair stations either applying for or holding EASA approval under the bilateral agreement between the United…Read More

Grantham Gets Cycle’s First ARSA PAC Contribution

Air Force and aviation industry veteran Travis Grantham, a candidate for Arizona’s fifth congressional district, has received the first ARSA Political Action Committee (PAC) contribution of the 2026 election cycle.…Read More

Review FAA’s Methods, Techniques, and Practices

The FAA has engaged industry to help review AC 43.13-1B Acceptable Methods, Techniques, and Practices—Aircraft Inspection and Repair that is applicable to aircraft inspection and repair. The AC primarily supports…Read More

Drafting Regulatory Purpose into Order 8130.21

On June 17, ARSA and the Aircraft Electronics Association (AEA) jointly submitted a rewrite of the FAA’s Draft Order 8130.21J, “Completion of FAA Form 8130-3 under 14 CFR part 21.”…Read More
ARSA