Review of Existing Regulations

FAA-2007-29291

November 17, 2007

Comments of Jet Airways (India)

It can be clearly seen, in the RED area, for slippery runway, that FAA dispatch regulations fall short of actual landing field length performance. In that, while the FAA LDR on slippery runway indicates a feasible dispatch by ensuring LDR=LDA, a 15% in-flight addition/check by the crew would lead to diversion, as 1.15ALD would exceed the LDA.

It is therefore that if you agree to what has been stated above, then you may like to consider amending landing field performance dispatch policy for slippery / contaminated runways.

By: Jet Airways (India)

November 20, 2007

Comments of Regional Air Cargo Carriers Association

While RACCA understands the mandate established by Executive Order 12866 to solicit comments regarding current regulations that should be amended, removed, or simplified, we believe the FAA should grant priority to regulatory issues that are already before it. 

Industry and government agencies have expended considerable time and money participating in Aviation Rulemaking Committees (the Part 125/135 ARC that concluded more than two years ago, for example) and similar joint agency‑industry efforts in the past few years. The specific purpose of these activities was to review and update current regulations, many of which fit clearly in the "amend, remove, simplify" window addressed by Executive Order 12866. In some cases, changes recommended by the 125/135 ARC are urgently needed. Others are not controversial and would be relatively easy to implement, as was suggested in a recent meeting between personnel of RACCA and other industry groups, and the FAA, in Washington, D.C. 

By: RACCA, John Hazlet, 508-747-1430

January 14, 2008

Comments of Boeing

We request that the FAA revise the definition of "major" repair to relate the classification to the degree of damage instead of focusing on the part that was damaged and needs to be restored.

We recommend that FAA allow "qualified" suppliers to classify repairs/damage as either being "major" or "minor."

By: Boeing, Douglas Lane

January 15, 2008

Comments of Cessna Aircraft

Cessna contends that clarification of the term “engine case” as currently used in the rule is needed.  Current technology turbine engines installations may use turbojet engines, turbofan engines with partial outer bypass ducts or turbofan engine with full length bypass ducts.  Depending on the configuration of the installed engine the term “engine case” can be interpreted differently.

By: Cessna, Neale Eyler

January 14, 2008

Comments of Delta Air Lines

Delta requests FAA provide additional guidance or clarity to the data requirements needed for substantiating a special flight permit per 14CFR part 21.197. This part states a permit to fly an aircraft can be issued “for an aircraft that may not currently meet applicable airworthiness requirements but is capable of safe flight” for the purposes of “Flying the aircraft to a base where repairs, alterations, or maintenance are to be performed, or to a point of storage”. If the aircraft is not required to meet applicable airworthy standards, do the requirements of 14CFR parts 25, 43, or 121 apply?

Delta suggests removing 14CFR part 43, appendix A – The listing of items to be considered Major Repairs and Alterations in this appendix is so antiquated and outdated to the point of being unusable.

Delta is seeking revision to FAR 91.171 so that it adds another method of compliance. This method is automatic thru the Flight Management System which does a cross check to verify VOR integrity each time the aircraft's FMS comes on line and makes the decision thru software as to whether or not the 2 VOR systems are valid data sources.

By: Delta, Kenneth Lorow

January 14, 2008

Comments of Helicopter Association International

HAI recommends that the definition of “suitable landing area” established in FAR 136.1 Applications and definitions:  Should be deleted.

HAI further recommends that FAR 136.9-Life Preservers Over Water, be amended with the addition of a new paragraph (d), stating that “No life preserver is required if during that portion of the flight over water beyond the shoreline, the aircraft is at all times within power off gliding distance to land.

HAI also recommends that Appendix A, FAR Part 136 be eliminated from FAR Part 136.

HAI Encourages Prompt Review and Consideration of the Recommendations of the Part 135/125 Aviation Rulemaking Committee.

By: HAI, Matthew Zuccaro

January 14, 2008

Comments of Palm Bay, Florida

The FAA's current approach for categorizing and regulating VAS does not account adequately for the different operating characteristics or the risks presented by VAS operations. The FAA's position also is inconsistent with current regulations. The FAA should greatly accelerate its consideration of UAS and develop a separate regulation to better define the VAS to be regulated and to prescribe narrowly tailored certification and operating requirements and standards. In the interim, the FAA should develop flexible guidelines and assist public agencies in securing a waiver to operate VAS for law enforcement and public safety.

Counsel: Kaplan Kirsch, Daniel Reimer, 303-825-7000

January 15, 2008

Re: Comments of Aircraft Owners and Pilots Association

AOPA recommends that the FAA eliminate the requirement that pilots hold a valid FAA medical certificate when exercising the privileges of a recreational pilot certificate, histead the FAA should permit the use of a valid and current U.S. driver's license in lieu of an FAA medical certificate when exercising these privileges.

By: AOPA, Melissa Rudinger

January 16, 2008

Re: Comments of Salt Lake Citiy Department of Airports

Implementation of the approach surfaces is often very complicated. In some instances, the various regulations conflict (CFR Part 77 - Objects Affecting Navigable Airspace, Advisory Circular - Airspace Design, and TERPS). These three sets of regulations are difficult to administer at a single geographical location. A single set of airspace regulations would help eliminate confusion during implementation on the ground. Increasing restrictions to these surfaces by the FAA has created new issues on the ground, particularly with heights and object penetration to the surfaces.

By: Randall Berg

January 29, 2008

Comments of Southwest Airlines

Counsel: Southwest, Robert Kneisley, 202-263-6284