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Rick -
As I understand it, the FAA has chosen to publish the document in the Federal Register. My guess is that they are very much aware that it has raised a lot of concerns and are now treating it as a formal rule making. If this assumption is correct, it will be listed as a Notice of Proposed Rule Making (NPRM) and the purpose is to solicit comments from all parties. This is as close to "due process" as it gets; absent filing a law suit. I certainly would contact EAA and ask for the opportunity to have your case worked into their comments, or to be part of the group that drafts the document. A carefully reasoned statement from you and your customers, supported by as much evidence as you can muster, would be the minimum effort.
Hope this helps,
John Schroeder
Why not get Epic's input? This is the problem we have, no two way communication only new rules without due process.
Rick
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