Applications and Petitions: None Answers and Replies: Operating Limitations at ORD - Comments of Airports Council International - North America and American Airlines Orders and Notices: None Rules and Regulations: None Grant of Petitions: None

	Operating Limitations at Chicago O'Hare International Airport FAA-2004-16944 March 22, 2006 Comments of Airport Council International - North America ACI-NA believes it is unacceptable to extend the current order without modification. If an airport applying for authority to impose a Passenger Facility Charge filed a competition plan, as required to do under current regulations, with a mechanism that did not accommodate an air carrier request for access to unused capacity, the FAA would, in all likelihood, reject the plan on competitiveness grounds and forbid the airport from imposing a PFC. It is ironic that the FAA proposes in this Show Cause Order to do the very thing that it would forbid an airport from doing in similar circumstances. A strong case can be made as well that the FAA is exceeding congressional intent by continuing to extend a “temporary” Order to a point where it is, in effect, creating “slots” out of arrival authorizations. While ACI-NA credits FAA Administrator Marion Blakey for putting together the original agreement with the air carriers that served Chicago O’Hare in 2004, this agreement no longer suits the industry or O’Hare in 2006. From a workload standpoint it is perhaps understandable that the DOT and FAA do not want to reopen the original agreement; it is a time-consuming process and the multiple bilateral carrier agreements that the FAA must negotiate are incredibly complex and difficult. But this highlights the point that this regulatory approach is a flawed enterprise. It is static, artificially limits capacity, does nothing to increase the efficient use of the airport or air space, and is incapable of responding to the needs of the aviation industry. We urge that the FAA reconsider and adopt one of the alternative options we enumerate above. Counsel: ACI-NA, Gregory Principto, 202-293-8500 March 22, 2006 Comments of American Airlines American does not object to the FAA's proposal to extend its order of August 18, 2004 limiting scheduled operations at O'Hare through October 28, 2006. American's position on the Notice of Proposed Rulemaking on long-term O'Hare congestion and delay reduction, pending in FAA-2005-20704, remains unchanged. See our comments in that docket submitted on May 24, 2005 and June 30, 2005, as highlighted in our comments in this docket submitted on August 1, 2005 in response to the FAA's prior Order to Show Cause to extend the duration of the August 2004 order. Counsel: American, Carl Nelson, 202-496-5647, carl.nelson@aa.com Index