Runway Overrun Effort Concerns GA

The work being done by the Aviation Rulemaking Committee (ARC) on new take-off and landing performance assessments is increasing concern in the general aviation community, according to the National Air Transportation Association, which published a letter to the FAA, concerning the fact FAA is dictating the new requirements and expects the industry to rubber stamp its proposal.
The agency is trying to gain an extra 15 percent margin to avoid runway incidents which has met with industry resistance. NATA said that the team that developed the proposed requirements is so married to it that it is perverting the collaborative ARC process.
“We are increasingly concerned with the non-collaborative approach demonstrated by the FAA team,” said NATA President Jim Coyne in his letter to Director-Flight Standards James Ballough. “It has become quite worrisome that the FAA team appears to have entered into the ARC with a predisposition towards the 15 percent solution put forth in SAFO 06012. It seems that several FAA representatives believe that the solution they developed is the only acceptable intervention strategy. In retrospect, it may not have been ideal for the FAA to place the same landing performance team that developed the SAFO in a position where perhaps they feel a need to defend their prior work. There is little motivation on their part to embrace other potential solutions.”
NATA charged that the entire methodology of collaboration between industry and their regulators is at stake. “[FAA’s insistence on the 15 percent margin] is absolutely contrary to the process we have come to anticipate as a member of prior ARCs,” it said. “Our industry approached this ARC, and advocated for its creation, because we found problems with the methodology contained in the SAFO. We believed that working with the FAA we would be afforded the opportunity to dispassionately analyze the available safety information, absent preconceived prejudices, so that we could then engage in a collaborative discussion to develop appropriate recommendations which consider safety, the unique operational environments common to our industry, public access needs, and a review of the overall costs versus benefits. The proposals offered by the 135/125/91K work group (including a split system of safety margins based on additional training relevant to our section of the industry) have been summarily rejected by the FAA team. To us, it appears that in addition to dismissing any safety concept other than the 15 percent scheme, the FAA is also not willing to entertain an alternative method for enhancing safety for the 135/125/91K segment of the industry, despite the additional training or other factors the work group may propose. If the FAA's intent was to have industry rubber stamp SAFO 06012, what was the purpose of forming the ARC? If the FAA intends to dismiss the concept of individualized standards for 121 and 135/125/91K, what was the purpose of having two separate working groups at all?
NATA rejected the rubber stamp ARC methodology and said it is increasingly difficult to get operators to expend resources on ARC when “the FAA team seems inflexible and steadfastly wedded to their solution despite numerous identified flaws in its development and potential implementation.” The organization went on to state, “We do not believe that the blanket application of a 15 percent additive is justifiable given the accident/incident information pertaining to Part 135 and 91K operations, nor do we believe that the agency is capable of adequately answering the numerous procedural questions raised by this policy (i.e., how operations at uncontrolled/unmanned airports would be conducted) that will unnecessarily restrict operations if the SAFO process is adopted unchanged.”