Tuesday’s notice is unusual in that it includes a questionnaire of sorts targeting many of the specific concerns that have been raised over the proposed rule. Anyone taking advantage of the extended comment period is asked to cover 15 points raised in the questionnaire. The questions are clearly directed at Part 91 operators who, under the proposed rule, would be required to upgrade to Part 121 or Part 135 operating certificates. This provision has caused the most controversy. The questionnaire even invites pilots to do a little role-playing and imagine that it was they who were trying to achieve the safety goals of the rule without ruining businesses. “Are there ways we (FAA) could achieve the results intended by the proposed rule that would impose fewer burdens on the industry?” it asks. If you’re planning on attending either (or both) of the public meetings, Tuesday’s notice also includes a summary of how the FAA wants those to go. Be brief, do your homework and stick to the issue, are the main messages. The agency is particularly interested in any new information that might not have been included in the thousands of submissions received to date. The public-meeting option was also a thorny issue between the FAA and the alphabets in the original NPRM process. Instead of public meetings, the FAA originally scheduled a weeklong Internet forum that it defends in Tuesday’s notice. The agency claims that many people who would not otherwise have been heard took advantage of the Web access opportunity.
