Ms. Rosalind A.
Deputy General Counsel
Department of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Dear Ms. Knapp:
June 14, 2001, the Department of Transportation (DOT) submitted
a Federal Aviation Administration (FAA) draft final rule titled
"Revisions to Digital Flight Data Recorder Regulations for Boeing
737 Airplanes and for Part 125 Operators" to the Office of Management
and Budget (OMB) for review under Executive Order No. 12866. This
final rule would require all Boeing 737 series airplanes' flight
data recorder systems to record additional flight data.
the past month, we have raised questions and several concerns about
the relative cost-effectiveness of requiring additional flight data
recorder parameters that have been set forth in the final rule in
light of additional steps that will be proposed in a related Notice
of Proposed Rulemaking (NPRM) on general flight recorder improvements.
That NPRM is currently under development and is expected to be submitted
to OMB for review in the near future. We have suggested that some
of these concerns might be addressed by discussing the NPRM with
Departmental staff before taking action on the final rule.
the resolution of the concerns will take some additional time, I
am returning the draft final rule on flight data recorders to the
Department for your reconsideration. Our staff is available for
further discussion with you on the concerns that have been raised.
We look forward to working with you to improve this important rulemaking
John D. Graham
Office of Information and Regulatory Affairs