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Old 9th Jan 2023, 06:50
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pattern_is_full
 
Join Date: Jan 2008
Location: Denver
Posts: 1,225
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Key Takeaway - the FAA is under the thumb of politicians who may be both for and against certain levels of regulation (and changing every 2-6 years). It has to work with other agencies, both US and foreign. it is not a free agent or dictator who can simply issue a new rule

Time line (mostly from the first document you gave us above)....

2001: Nov 12 - AA 587 rudder loss and crash

2004: Oct 26 - After 3 years of research and investigation, the NTSB determines and issues its report on the probable cause of the accident - https://www.ntsb.gov/investigations/...ts/AAR0404.pdf
Among the findings of that reports are recommendations to the FAA to:

Modify 14 Code of Federal Regulations Part 25 to include a certification standard that will ensure safe handling qualities in the yaw axis throughout the flight envelope, including limits for rudder pedal sensitivity.
2011: FAA tasks the external Aviation Rulemaking Advisory Committee (ARAC) with studying such a rule, and whether there are other ways to solve the problem.

ARAC consists of outside advisors representing various stakeholders: https://www.faa.gov/faq/what-purpose...committee-arac

The ARAC delegated that work to its Transport Aircraft and Engine Subcommittee, which further delegated it to its Flight Controls Harmonization Working Group (FCHWG).

2013: The FCHWG and ARAC finish their reports and provide them to the FAA.

2018: FAA issues a public Notice of Proposed Rulemaking on the subject. The manufacturers, and pretty much anyone else with a stake in the rule (and their lawyers) issue comment:

The FAA received comments from the NTSB, Airline Pilots Association, International (ALPA), ATR, Crew Systems, Textron Aviation, Airbus, The Boeing Company, and Bombardier Aerospace. The NTSB, ALPA, ATR, and Crew Systems supported the proposal and did not suggest changes to it. Textron Aviation and Airbus requested that the rule specify a single, full-pedal command followed by one rudder reversal and return to neutral, rather than three rudder reversals as proposed in the NPRM. Those two companies, along with Boeing, also requested other changes, as described in this section of the preamble. Bombardier Aerospace commented on the rule's cost, suggesting that the FAA issue guidance to limit the rule's applicability.
After considering the comments, the FAA reviewed considerations not strictly related to safety, as it is required to by law. Such as Regulatory Flexibility, International Trade Impact, Unfunded Mandates, Paperwork Reduction, International Compatibility, Environmental Analysis. Or by Presidential Executive Orders, such as Protection of Federalism (rights of/effects on the individual States); Regulations that Significantly Affect Energy Supply, Distribution, or Use; and International Cooperation.

2022: FAA, having accounted for all of the above, issues the rule.

So the length of the rulemaking has many fathers and mothers, of which the FAA is mostly low man on the totem pole.
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