Wed, Jan 05, 2011
Dick Knapinski Details EAA's Plan For NPRM Response
In response to the
insightful comments Bruce Hadow shared with
ANN over the eccentricities and problems inherent in
the FAA's proposed NPRM over Airman Photo IDs and the like, EAA's
Dick Knapinski explained why Hadow did not see any EAA comments or
responses to the NPRM at that time.
Dick explains that, "Once an NPRM is officially released, a
particular period of time (such as 45, 60 or 90 days) is indicated
for public comments. Our first step is to thoroughly read the
document for any particular areas of concern or questions that we
may have. After that review, EAA will often discuss the NPRM with
other stakeholders that would be directly affected by the proposal.
Those could be EAA members, other pilots, user groups, industry and
so forth. The input we receive from them will go into the first
draft of our response. That draft is reviewed by our government
programs staff and any other EAA group that might have expertise in
the area (such as legal or medical councils, maybe the Vintage or
Warbirds groups, and the like).
We also determine if this is an NPRM that would benefit from
direct member or group comments. If so, we'll get the word to our
members to review the NPRM and submit comments if they wish. EAA
will share some of its concerns but also urge interested parties to
review the NPRM on its own. At times, those members, chapter or
other groups will copy EAA on its comments. There have been times
when the number of questions have caused EAA or other aviation
groups to request an extension on the comment period. Often those
are granted, especially in complex NPRMs that may take several
pages of comments.
EAA's Dick Knapinski
The final draft of comments is typically completed about a week
before the deadline date. FAA or other federal agencies do not
weigh comments as to the date submitted. Many times, EAA's
comments will be sent to FAA in the final days prior to the
deadline after a final review of the NPRM to make sure it is as
comprehensive as possible. For instance, the deadline for the Photo
ID NPRM is Feb. 17. I'm estimating that our comments would be
submitted to FAA sometime after Feb. 10."
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