The FAA published a meeting announcement in today’s Federal
Register (80 FR
52839) for a public meeting of their Aviation Rulemaking Advisory Committee
(ARAC) on September 17th, 2015 in Washington, DC. At this meeting
the ARAC will receive status updates from a number of working groups, including
the Aircraft Systems Information Security/Protection (ASISP) Working Group.
The ASISP was formed
in February of this year and tasked with providing “recommendations
regarding Aircraft Systems Information Security/ Protection (ASISP) rulemaking,
policy, and guidance on best practices for airplanes and rotorcraft, including
both certification and continued airworthiness.”
This meeting is open to the public,
but there is limited seating so you should confirm your attendance with Renee
Pocius (email Renee.Pocius@faa.gov).
There have been provisions made for attending the meeting
by telephone and Ms. Pocius should be contacted to make the arrangements
for that as well. There will be a public comment period at the meeting.
Coordination with Ms. Pocius for presenting an oral statement should be made by
September 10th. Physical copies (25 each) of written statements
may be provided to Ms. Pocius prior to the meeting or brought to the meeting.
Commentary
It is not clear at this time whether the ASISP update will
include any actual recommendations for regulatory actions. Given the short
amount of time that the Working Group has been in operation, I would be
surprised if this was anything more than a list of areas of potential concern
and an idea of how much longer it might be before a recommendation was provided
to the full Committee.
It is a shame to see that the FAA is still stuck in the 1960’s.
The requirement to deliver 25 physical copies of written statements is archaic
in the extreme. Most Federal Agencies use the Federal eRulemaking Portal (www.Regulations.gov) for the purpose of
submitting written statements for meetings of this sort. This ensures that not
only can the Committee members and staff have ready access to the documents,
but the public has such access as well. And don’t even get me started about the
failure to provide even a toll free line for the telephone bridge access to
this meeting, much less an electronic connection. No wonder the Agency is
having problems trying to modernize its traffic control systems; it has not
bothered to modernize its administrative procedures.
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