Noise Compliance Rules

Noise Compliance Rules - Stage 3

July 6, 1999

Re: Comments of Reno/Tahoe International Airport

Reno has no objection to grants of waivers for the first category of requests involving non-commercial operations. Reno recognizes the merits of those requests and the adverse public interest impact that denial of such requests would have on the ability of the requesting airlines to adequately serve the travelling public with their stage-2 aircraft prior to the December 31, 1999 deadline. Those carriers have indicated that if a waiver was not granted, they may be forced to ground stage-2 aircraft well in advance of the December 3 1, 1999 deadline. Such grounding could seriously disrupt year-end travel plans of consumers throughout the nation, especially during the peak Christmas travel season. A limited waiver to allow the carriers to operate non-commercial ferry flights to position the aircraft for disposition to third parties and for other noncommercial purposes appears consistent with the public interest waiver provisions of ANCA and would allow the travelling and shipping public to get the full measure of benefits from stage-2 aircraft for the full calendar year 1999. Reno, however, strongly opposes the grant of any waiver to permit the continuation of commercial use of stage-2 aircraft after the December 31, 1999 deadline. We note that approximately six airlines (Kitty Hawk Air Cargo, Inc., TEM Enterprises d/b/a Casino Express, Transcontinental Airlines, Inc., Express One International, Inc., ABX Air, Inc., and Midwest Express, Inc.) have sought waivers to permit operation of commercial services after the December 31, 1999 deadline. Each of those carriers assert that for different reasons they may be unable to retro-fit their existing stage-2 aircraft in time to meet the ANCA deadline and that the denial of a waiver will result in economic harm to the carriers and to the consumers they serve.

Counsel: Shaw Pittman, Robert Cohn, 202-663-8060