The Federal Aviation Administration should halt its proposed rulemaking to impose new cockpit voice recorder (CVR) and digital flight data recorder (DFDR) requirements until it conducts a thorough analysis of the costs of those requirements to Part 91 and 135 operators, the National Air Transportation Association told the agency in comments submitted last week. FAA in February proposed requiring operators to upgrade CVR and DFDR equipment to improve the quality and quantity of information recorded.
The requirements cover both aircraft operated in fractional ownership programs and for on-demand service, but FAA's analysis included no data on the effect the proposed requirements would have on those operators, NATA said. "This is more than a disservice to industry; it is non-compliance with FAA's mandatory obligations during rulemaking," NATA said.
NATA noted FAA did not analyze the number of Part 91 and Part 135 aircraft that would be affected, the number of supplemental type certificates that would be necessary, the types of CVR equipment currently in use in Part 91 and 135, the equipment changes that would be necessary on those aircraft or the costs of compliance. FAA further underestimated the number of small businesses affected by the proposal, NATA said. FAA estimated that only 98 small businesses would be affected, but NATA estimated there are some 2,500 small businesses in Part 135 alone.
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