NBAA and the National Air Transportation Association submitted comments critical of the FAA's proposed rule to modify recording, sampling and installation requirements for cockpit video recorders (CVRs) and flight data recorders (FDRs). The comments were submitted just before the deadline last week. According to NBAA, the FAA's economic analysis required for this rule "failed to address a single business aircraft affected by this proposal." The association estimates that this rule could cost the Part 91 and 135 community more than $1 billion to meet these new requirements, and it has asked that the FAA halt any further rulemaking on this issue "until it completes the required economic analysis." The comments from NATA were much the same: "The agency failed to conduct even a cursory review of the feasibility and economic impact of the rule for aircraft operated under Parts 135 and 91. This oversight has resulted in substantial flaws in the FAA estimates of time to complete CVR retrofits, the overall costs of the upgrades and the number of small businesses impacted" by the proposal. NATA also wants the agency to suspend action on the rulemaking.