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NATA Comments to FAA on Authorization to Use Lower Than Standard Takeoff, Approach and Landing Minimums at Military and Foreign Airports

February 10, 2012

Docket Operations, M-30
U.S. Department of Transportation
1200 New Jersey Avenue, SE
Room W12-140, West Building Ground Floor
Washington, DC  20590-0001

Delivered electronically via www.regulations.gov

RE:  Docket No. FAA-2012-0007, Authorization To Use Lower Than Standard Takeoff, Approach and Landing Minimums at Military and Foreign Airports

The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments.  NATA’s 2,000 member companies own, operate, and service aircraft.  These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft.  NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation, and the military.

NATA represents more than 800 on-demand air charter carriers operating under Part 135 regulations.  The association supports this direct final rule to permit eligible carriers to utilize lower than standard minimums at military and foreign airports.

The rule change will permit those operators that obtain authority for lower than standard minimums operations at U.S. airports to have the same authority at foreign and military airports.  As noted by the agency in the rule discussion, similar authority already exists for Part 121 air carriers and Part 91 operators.  Permitting Part 135 carriers this same ability, subject to issuance of the proper Operations Specification, will not have an adverse impact on safety and should pose positive economic benefits due to the elimination of delays experienced when an aircraft must delay departure until weather conditions improve to at least “standard” conditions. 

NATA appreciates the Federal Aviation Administration’s timely response to this issue and welcomes the implementation of this regulatory change.

Sincerely,

Jacqueline E. Rosser
Director, Regulatory Affairs

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