Rulemaking and Economic Analysis

Notices of proposed rulemaking (NPRM), final rules, direct final rules, interim final rules, ex parte communications and economic analyses — the federal rulemaking process can be confusing and often seem like a convoluted method for getting something accomplished. This process has developed over time through both statute and policy, and aims to ensure that the federal agencies have adequate information before making decisions that will have the force of law. Built into the rulemaking process are a series of protections for regulated individuals and businesses that require federal agencies to consider the impact (or cost) the proposed rules will have. These impacts must be weighed against the expected benefit of the rule change. However, for an analysis to be meaningful, the agency must have reliable data and the proper set of assumptions.

One of the core services that NATA provides its members is reviewing and commenting on proposed changes to federal regulations. One of the rules that NATA is considering now is a proposal for broad changes to the regulations governing certificated repair stations (14 CFR 145). This proposed rule would make major changes to the ratings issued to repair stations as well as the process by which a repair station is certified (click here to read NATA’s Regulatory Report on this proposed rule). Under this proposal, all existing repair stations would be required to update their manuals, make other applicable changes to their business and reapply for certification as a repair station.

During our review of the economic analysis associated with this rule, NATA identified a significant number of areas where the Federal Aviation Administration (FAA) has understated the cost of complying with this rule, either due to lack of accurate data or faulty assumptions regarding repair station processes. NATA believes this has led to a severe underestimation of the total cost for complying with the repair station NPRM. As part of our comments, the association intends to provide the FAA with data that can be used to create a better understanding of the costs that will be faced by existing repair stations.

To do so, however, we need your help. NATA has developed a survey that will gather the needed data from our members who operate certificated repair stations. This data will help us provide the FAA comments that show the true cost of the repair station rule to businesses like yours.

Please take some time today and complete the repair station NPRM impact survey using the link below.

http://www.surveymonkey.com/s/nata145survey

The survey will remain open until Friday, November 2.

Visit or return to NATA website: www.nata.aero.

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