The deadline for submissions to the proposals in NPRM 09-02 Part 61 Stage 2 closed on February 1, and GAA knows of submissions being prepared only hours before CAA HQ locked its doors at 5pm.
For the first time, many submissions were accessible to the entire general aviation audience – via the GAA website.
Some objectors raised submissions as a direct result of GAA publicity. They wrote to say that they would have otherwise missed the plot.
GAA supporters will thank those who agreed to the publication of their submissions on the website, and admire the knowledge, detail, effort and – yes – the passion and belief that underlies their contributions. You can view these submissions under the CONSULTATION tag.
Much of what has been submitted makes compelling reading.
You have to wonder why the CAA chose to draft its proposals in-house, and ignore external expertise and wisdom – some evidence of which is now up there on the GAA website for everyone to see.
Hundreds of people oppose what the CAA proposes in Part 61. In all the dialogue and submissions about it on this website, you will find not a single word of support. But there are plenty of positive suggestions.
The GAA website didn’t fly until towards the end of the consultation period, but arrived just in time to publicise what many believe to be the folly of the CAA’s course, its evident abandonment of industry involvement and the curious timing of its process.
Once upon a time, you’d have cried in the wilderness, sent your paperwork to CAA – and the rest of GA would have been none the wiser.
That way of doing things is history, and anyone who thinks otherwise is living in the past.
If GAA serves any useful purpose, it is to broadcast what’s happening and what people think about it. ASAP.
So, CAA: Why the busting rush with Part 61?
A period of reflection in Featherston Street is now in order. It should result in a decision to dump this flawed bag of bolts and start afresh.
But this time, the process must be honest, open and truly inclusive. It should involve experts from the CAA user base and provide adequate time for careful consideration by the people who pay for the CAA.
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