Mark - I'd like to ask this with the utmost respect and careful choice of words. What is it about the work process that produces documents like this, that so often contain language that exhibits a profound lack of understanding about the area being regulated? That seem, to the educated layman, to lack basic common sense?
I expect this kind of thing from Congress. But the FAA has both position authority AND knowledge authority. It has true experts. Where are they in this process? Yet so frequently things like this come out and we get embroiled in a needless fight. (Example: sleep apnea.)
How difficult would it have been to, as part of the process, have someone other than lawyers look at it (because clearly no pilots or aviation experts did)? To send it - fax or email, to say the ALPA, AOPA, EAA, etc. with a cheery note that says "Hey y'all - here's something we are kicking around. Do you see any showstoppers? Any forehead-slapping thing that we might have missed? Hey, we're all human! Howzabout a friendly review before we go public?"
Why do we have to always start things out adversarially because of a (to put it mildly) lack of consideration of the screamingly obvious real world effects of the proposed change?
Thanks!