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."

FMI www.eaa.org