The FAA makes changes to the FARs all the time. They go thru a Notice of Proposed Ruling Making process where they do a study, come up with recommended changes to the Regs, write a draft Reg, post it for public comment, evaluate the comments and then write a Final Regulation. The other Feds do the same thing. But the Feds own the process, they are under no obligation to incorporate the public's comments. This goes on all the time with over 2500 NPRMs published last year.

Look at the front of the process, the Feds are under no obligation to take the recommendations of a study into a proposed draft Reg.

So what is different about the the recommendations of the Part 23 Study committee recommendations, which includes recommendations to streamline the small aircraft design, certify, and production as well as recommendations for a new Primary Non-Commercial (PNC) aircraft category, and ways to ease the introduction of avionics? If you go back to the first paragraph, you will notice that there is no mention of the Legislative process. The great majority of Regulation changes happen without Legislation. These Study recommendations are different. Different, how so?

Congress inserted themselves by making the Small Aircraft Revitalization Act (SARA) the Law, Public Law 113-53. The law uses soft language but mentions Study by name and directs the FAA to achieve the objectives of study. Again, not real direct language but SARA is a very short law and the study and it's recommendations are the only reference.

If the FAA wanted to ignore part of the recommendations they might have been able to, but Congress inserted themselves for some purpose. Normally when you see that happen it is because some special interest didn't like something and congress bows to them and says don't do something.

Here we have the opposite. Congress passed SARA without any exceptions. So why should we let the FAA decide they can pick and choose. Not only did Congress pass SARA, it passed unanimously in the House (!!!). When was the last time you saw unanimity in the House?

So, we need to not be sheep, we need to point out that Congress did something unusual, they made something regulatory the law. Let's not let The FAA shortchange us where we have a Law that is great for us. Don't let the FAA deny us what is now the Law.