Originally Posted by
Mayhemxpc
Apart from re-emphasizing that this should be done according to well established risk management processes rather than the lemming method, the limited consultation and ad hoc changes are even more concerning. As we all know, whenever the FAA wants to change something, they have to publish the change in the Federal Register as a notice of proposed rule making (NPRM). EAA has been very active in responding to FAA NPRMs, objecting to or proposing useful revisions to the notice. In fact, all government agencies are required to post proposed changes that can be reasonably expected to affect the general public. What many people do not know is that EACH COMMENT must be INDIVIDUALLY addressed. (Similar comments can be bunched together for a single answer.) These comments and their answers are posted as part of the final rule. So why doesn't EAA do something similar with rule proposals that will have such a drastic effect on their members? This is the kind of consultation we are asking for. It is also a process that will help assure that some of the things cited here, and the changes to the EAA policy that have already been incorporated as a result, will be considered and incorporated into a final rule (or second review) BEFORE people start to implement the requirements of the rule (like all of those who already exposed their SSN.)
Even the BSA opened its recent rule changes for public comment before implementation, and revised some provisions before they became effective. Certainly EAA can do the same (or better.)