How’s Marshall?
July 26, 2021 | Categories:
ARSA News & Updates
On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. He is recovering at home and is on track to continue his passion as…Read More
ARSA Submits Comments on OMB Good Guidance Practices
January 10, 2006
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
FAA to Restart Global Leadership Meeting
On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read MoreLawmakers Explore Aviation Workforce Diversity
July 21, 2021 | Categories:
ARSA News & Updates, FAA
The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce.
The witnesses were (click a name to download their written testimony):
Rebecca Lutte,…Read More
Unpacking AD Authority
July 20, 2021 | Categories:
ARSA News & Updates, ARSA Works, FAA, Maintenance, Operations, Regulatory, Training
On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC…Read More
