The most exciting part of my workday

Every day, Monday through Friday, excepting Federal holidays, the National Archives and Records Administration publishes the Federal Register. It is an exhaustive listing of proposed regulations, policies, and more for the entire federal government. Perhaps I exaggerated this article’s title a bit. The Federal Register is not (usually) the most exciting part of my day. But it does contain very important information and shapes much of my workload for the weeks and months ahead.

Image courtesy of the National Archives and Records Administration

Image courtesy of the National Archives and Records Administration

The Federal Government’s Journal

The Federal Register is described as the daily journal of the United States Federal Government. It was established by Congress through the Federal Register Act with the goal of addressing a growing government and a proliferation of agencies issuing regulations. The Federal Register allows agencies to promulgate and enforce federal regulations. If you’re interested in learning more about the Federal Register, the National Archives and Records Administration hosts an online course detailing everything you would ever want to know about the Federal Register.

How AOPA uses the Federal Register

Everyone in the Government Affairs department reads through the Federal Register each morning to see what actions are being considered or proposed. While the document is categorized by agency, aviation is subject to regulatory burdens beyond the FAA. Consider the Office of National Marine Sanctuaries (ONMS) recent decision to restrict overflight of National Marine Sanctuaries. The notice of proposed rulemaking (NPRM) was listed in the Federal Register under the National Oceanic and Atmospheric Administration (NOAA) which oversees the ONMS.

So really, we need to review the entire Federal Register for activities that have the potential of impacting general aviation. The Table of Contents alone is around 15 pages each day. From that, I may investigate anywhere from 3 to 10 announcements that have caught my eye. Most turn out to be harmless, routine, or not applicable to general aviation.

When I do find something that pertains to general aviation, it sets a lot of things in motion. Depending on the nature of the announcement, it could mean the beginning of months of work.

What happens when something is found

The first thing I do is analyze the proposal to understand exactly what the issue is, and start to determine how it may impact (positively or negatively) general aviation. I share a summary of the issue with my colleagues and map out our path forward for a response. One of the first actions is to submit a communications request, or comms request, which is AOPA’s internal mechanism for generating articles for our digital publications like the website or ePilot.

I may collaborate with industry partners or contacts at the FAA to gain additional insight or information as I begin to sketch out AOPA’s draft comments in response to the announcement. Depending on the issue, we may also notify and solicit input from our regional managers and affected Airport Support Network Volunteers (ASNVs). I use this input to refine our final comments and prepare for submission. If it is a particularly significant or groundbreaking issue, we will often run a second article sharing AOPA’s comments and reminding members to submit comments of their own.

There are a lot of steps and a lot of lead time needed to ultimately submit comments that are insightful and substantive. That is why we often request a comment period extension. It is not necessarily to slow down the process, but to allow us sufficient time to do all the leg work in preparation of submitting comments. The Federal Register is not very user friendly. Most pilots are not reading the Federal Register themselves. Instead, they rely on organizations like the AOPA to digest the information, summarize the important points, and alert them to significant items.

Have you ever submitted comments?

The Federal Register is important, but the comments submitted in response are crucial. Many of the decisions or policies proposed by the FAA and other agencies are made in a vacuum with little or no input from the general public. Submitting comments is our chance to shape the regulatory and operating environment. Have you ever submitted comments to an NPRM or other Federal Register announcement? Share your thoughts with us in the comments!

3 Responses to “The most exciting part of my workday”

  1. TR Scott says:

    I have left comments but it isn’t the easiest thing to find the correct subject and comment page with out a good link. I wonder if its that way on purpose?

  2. J veers says:

    Thanks to you and AOPA for doing this! Your watchdog efforts are one of the most important aspects of the organization. Without citizens keeping a constant watch on the register, these agency “rules” would slip into policy un-noticed by the public, sometimes with unforseen negative consequences.

    Thanks to AOPA bringing one of these issues to my attention a few years ago, I did navigate the register once to submit comments. It is not an easy process. When AOPA reports on these notices, it would be helpful to also include instructions for submitting comments, like how to navigate to the proper location online and find the document.

    Thank you again for your service.

    • Tom Kramer says:

      Thanks for the kind words! It is difficult to navigate to a particular docket or NPRM. I like your suggestion of providing more guidance on how to submit comments. I’ll see what we can do!