Editor’s Note: This first appeared in Plane & Pilot.
When a federal agency, such as the FAA, seeks public input on a proposed policy, providing a substantive comment is an essential way to voice concerns, offer suggestions, and contribute to the policymaking process. With Modernization of Special Airworthiness Certificates (MOSAIC) on the horizon, you may be looking to add your thoughts to the process but aren’t sure how to create a comment that will have the effect you want.
A well-structured and thoughtful comment can significantly impact an agency’s final decision. In this guide, we will explore the key components of making a substantive comment to the FAA, highlighting examples and offering do’s and don’ts for effective commenting.
Do’s for Making a Substantive Comment
Take Time to Understand the Proposal
Thoroughly read and comprehend the FAA’s proposal to grasp its objectives, implications, and intended outcomes. You can read the MOSAIC proposal and take notes on how it may impact your personal or professional role in aviation.
Analyze the potential effects on safety, the environment, and industry. You may want to think about composing a comment that addresses a specific impact. Make notes that reflect your observations. Your note may not be your final comment, but you can use it to help construct the one you send to the FAA.
Example of a reflective note: “In the FAA’s proposal for implementing new air traffic control procedures, there is a potential impact on small airports and general aviation pilots, as they might face increased congestion and altered flight paths.”
Provide Specific Evidence and Data
When you’re ready to craft your comment, support it with factual data, research, and evidence to strengthen your argument. If you can, use statistics, studies, and case examples to back up your assertions and bolster your position.
Example: “I recommend that the FAA review the recent study by XYZ research group, which highlights the safety benefits of the proposed runway extension at ABC airport.”
Offer Constructive Suggestions
If you are opposed to a potential rule or aspect of one, try to present viable alternatives or solutions to address concerns and improve the proposed policy.
Consider the feasibility and practicality of your suggestions.
Example: “Instead of imposing a blanket curfew on all flights, the FAA should consider implementing noise reduction measures for late-night operations at major airports.”
Be Clear and Concise:
Articulate your points in a well-organized and coherent manner. Avoid jargon or technical language that may confuse readers. Keep your comment short so that it can be quickly read and digested.
Example: “I strongly advocate for the FAA to prioritize the implementation of bird strike prevention measures at airports with a history of avian-related incidents.”
Don’ts for Making a Substantive Comment
Avoid Emotional Language
Refrain from using emotional or inflammatory language that may undermine the credibility of your comment. Focus on rational arguments and evidence-based reasoning.
Example of an emotional claim: “The FAA’s proposal is a disaster! It will destroy our neighborhoods and ruin our quality of life!”
Steer Clear of Generalizations
Be specific and avoid making broad, unsubstantiated claims that lack evidence.
Example of an overgeneralized claim: “This proposal will lead to disastrous consequences for the aviation industry.”
Don’t Rely on Form Letters or Boilerplate Phrases
While form letters can show collective concern, personalized comments carry more weight. If many commenters send the same text, those responses may be lumped together rather than considered individually.
Customize your comment to include personal experiences or perspectives.
Example: “Although I support the general premise of the proposed air traffic control reform, I believe it should incorporate more considerations for rural airports like the one I operate.”
If you want to ensure your comment will be read and make an impact, it’s important to maintain a respectful tone, even if you disagree with the proposal or other comments. Promote a constructive and collaborative discussion.
Example: “While I understand the concerns raised by other commenters, I believe that we can find common ground by enhancing safety protocols and ensuring continued airspace access for all stakeholders.”
Engaging in the rulemaking process with substantive comments is a great way to actively participate in shaping federal policies like those proposed by the FAA. By adhering to the do’s and don’ts outlined in this guide, you can create impactful and persuasive comments that contribute to the agency’s decision-making process and help achieve better policies for aviation safety, efficiency, and fairness. Remember, your voice matters, so use the opportunity to make a difference through thoughtful and well-informed commenting.