Writing Comments to Federal Regulatory Proposals
Writing comments to a federal rulemaking proposal is likely one of the most difficult things a business aviation operator can undertake. Unlike “hangar flying,” where new pilots can learn from seasoned experts, people rarely get together to share stories about their best legal arguments to prevent bad regulations. There are many turns on the rulemaking road that are out of public view, which makes the few visible moments even more important to those in the aviation community who want to have their voices heard by Washington’s regulatory agencies.
A key component of any regulatory agency’s rulemaking process is to solicit input from the public. NBAA can help you develop a constructive response to proposed rules that could ultimately affect the way you use or operate your company aircraft.
Effective comments to a federal rulemaking proposal cover a few key points. Download the NBAA Member Resource titled “Writing Comments to Federal Regulatory Proposals” (PDF) or click on the links below to learn more about each step of the process.
- Standing – State your basis for submitting comments
- Major Issues – Identify the elements having the most significant impact on your operation
- Specific Concerns – Describe additional elements of the proposal that require comment
- Cost Consequences – Identify the financial consequences of the proposal on you individually and on your company
- Alternatives – Suggest alternatives to achieve the outcome desired by the regulator while reducing the burden on you
- Submitting Your Comments – Upload your comments to the government’s regulatory web site
- What’s Next – What to expect after submitting your comments
International Business Aviation Council Ltd.