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In this section: letters • issue briefs • testimony • events • agency filings • related links • court filings

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agency filings

ATA frequently participates in rulemaking and other regulatory proceedings affecting the airline industry. The U.S. airline industry is heavily regulated -- federal agencies regulate not just safety and security, but a variety of aspects of domestic and international air transportation. ATA advocates for efficient, effective rules to minimize the economic burden of regulation. ATA also participates in judicial proceedings that raise significant legal and policy issues broadly affecting the U.S. airline industry. ATA public filings to regulatory agencies and courts are included here.

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New York Slot Auction Rules

ATA comments support FAA’s proposal to rescind the slot confiscation and auction rules for LaGuardia, John F. Kennedy and Newark Liberty airports. ATA also urges the FAA to permit slots to be sold and leased on a long-term basis. (June 15, 2009)

Extension of JFK and EWR Scheduling Orders

ATA comments support extending the scheduling orders for John F. Kennedy International Airport and Newark Liberty International Airport, which expire on October 24, 2009, but recommend an indefinite extension instead of just a one-year extension. ATA also recommends that FAA permit slots to be sold and leased on a long-term basis. (June 19, 2009)

ATA Comments on the FTC’s Market Manipulation Rule

ATA comments on the FTC’s revised proposal to prohibit manipulation in wholesale oil and refined products markets. ATA supports the FTC’s initiative to prevent market manipulation but recommends the FTC retain the rule as originally proposed instead of the revised proposal as it is more in keeping with the broad anti-manipulation mandate of the Energy Independence and Security Act of 2007. (May 21, 2009)

ATA Comments on DOT’s Passenger Protection NPRM

The Air Transport Association of America, Inc. filed comments on March 9, 2009, in response to the Department of Transportation NPRM concerning potential actions to enhance national airline passenger protections. ATA members share the Department’s goal of ensuring that passengers receive timely information and that carriers provide basic services when extraordinary circumstances cause delays. ATA comments explain why some of the proposals make sense but others go too far and will only cause further cancellations and passenger delay. (March 13, 2009)

ATA Comments on TSA Large Aircraft Security Program (LASP) NPRM

ATA filed comments on the TSA Notice of Proposed Rulemaking (NPRM) that seeks to amend the Twelve-Five Standard Security Program and the Private Charter Standard Security Program (PCSSP), and to apply new security requirements to all aircraft weighing more than 12,500 pounds. (February 27, 2009)

ATA Comments on Regulations Proposed by CFTC

ATA comments support regulations proposed by the Commodity Futures Trading Commission (CFTC) to close the so-called “Enron loophole” by requiring monitoring of, and limits on, “significant price discovery contracts” traded on exempt commercial markets. ATA recommends that the CFTC modify the proposed regulations to better deter excessive speculation and urges the CFTC to vigorously enforce the regulations once adopted. (February 10, 2009)

ATA Supports FTC Market Manipulation Rule

ATA comments to the FTC support a proposed rule to prohibit fraud, manipulation and deceptive conduct in energy markets in order to guard against conduct that would undermine the integrity of those markets and harm consumers. (October 17, 2008)

ATA Comments on Proposed Slot Auction Procedures

ATA comments on procedures for slot auctions proposed by the Federal Aviation Administration (FAA) point out that FAA lacks authority to auction slots - a conclusion now supported by an extensive legal analysis and opinion rendered by the Government Accountability Office (GAO). In addition, FAA provided confusing and incomplete information, failed to address several significant matters necessary for carriers to prepare for an auction. The proposed auction procedures also violate the Administrative Procedure Act. (October 2, 2008)

Protesters Comments on the Program Office's Response to Protest

In support of its formal protest of a planned FAA Auction of slots at Newark Liberty International Airport, ATA filed its response to the FAA's opposition to the protest. (September 12, 2008)

Protester Reply to FAA Stay Opposition

A protest was filed with the Office of Dispute Resolution Acquisition (ODRA) regarding FAA’s refusal to delay the Newark Sept. 3 slot lease auction until the ODRA has time to make its decision on a pending auction protest. (August 22, 2008)

ATA Petitions DOT to Delay Certain Drug Testing Provisions

On August 18, 2008, ATA filed a joint petition with the Regional Airline Association to delay the effective date of certain "direct observation" provisions in a recently issued DOT final rule. Given the drastic changes required by the rule, with little notice, carriers will need additional time to hire and thoroughly train personnel in the new explicit sample collection prodecures. (August 18, 2008)

ATA Protests Newark Slot Auction

ATA has filed a formal protest of FAA’s planned auction of slots at Newark airport with the FAA Office of Dispute Resolution for Acquisition. (August 14, 2008)

ATA Slot Lease Auction and Congestion Management Comments

ATA issued comments to the Notice of Slot Lease Auction -- Newark and Notice of Proposed Rulemaking Congestion Management for John F. Kennedy International Airport and Newark Liberty International Airport. (August 11, 2008)

Fort Lauderdale-Hollywood International Airport Final Environmental Impact Statement

ATA filed comments July 28th on the Final EIS for a runway extension project at FLL. ATA commended FAA's rejection of the sponsor's alternative including operating restrictions on the new runway capacity, and expressed concerns about the expansion of the noise mitigation area beyond the 65 DNL. (July 28, 2008)

Kennedy and Newark Congestion Management NPRM

On July 21, 2008, ATA filed comments in response to the FAA Kennedy and Newark Liberty Airport Congestion Management NPRM, which would impose an hourly operational cap and confiscate and rellocate slots via auction. ATA comments explain why the FAA lacks legal authority to implement auctions and why the proposal is not jusitfied on other policy grounds. (July 21, 2008)

ATA Comments on the DHS US-VISIT Exit NPRM

ATA comments oppose the DHS proposed rule to implement the US-VISIT Exit program. ATA’s comments explain in detail why DHS does not have the legal authority to impose this program on the airline industry and why it fails to meet basic cost-benefit standards. (June 23, 2008)

LaGuardia SNPRM

On June 16, 2008, ATA filed comments in response to the FAA LaGuardia Airport Congestion Management SNPRM, which would impose an hourly operational cap, confiscate and reallocate slots via auction, and retire some slots. ATA comments explain why the FAA lacks legal authority to implement auctions and why the proposal is not justified on other legal and policy grounds. (June 16,2008)

BUR Application for Noise Curfew

ATA filed comments on the Burbank-Glendale-Pasadena Airport Authority’s proposed curfew applicable to Stage 3 aircraft operations at Bob Hope Airport (BUR). This is the first application for a mandatory access restriction under FAR part 161. (June 12, 2008)

ATA Aircraft Re-Registration Comments

On May 28, 2008 ATA submitted comments on the FAA's aircraft registration proposal, which would require all aircraft owners to renew aircraft registration and renew triennially thereafter. ATA comments explain why FAA does not need to completely eviscerate its current registration program to accomplish its goal of removing errant N-numbers from the aircraft registry. (May, 28, 2008)

NPS Definition of “Substantial Restoration of Natural Quiet” at Grand Canyon

ATA filed comments on the National Park Service’s proposed clarification of the definition of "substantial restoration of natural quiet" as it relates to management of aircraft overflights at Grand Canyon National Park (May 8, 2008)

ATA Comments on DOT's Proposed Amendments to its Airport Rates and Charges Policy

ATA comments on DOT's proposed amendments to its Airport Rates and Charges Policy. (April 3, 2008)

ATA Comments on Newark Airport Flight Limits Order

ATA's comments to the FAA's proposed order limiting operations at Newark Airport hihlight FAA's lack of statutory authority to impose slot auctions and suggest several practicalchanges to he order. (April 1, 2008)

ATA Comments on ADS-B NPRM

Attached are the comments of ATA on the ADS-B proposed rulemaking. (March 3, 2008)

ATA Comments on DOT Passenger Protection ANPRM

ATA filed comments in response to the DOT ANPRM concerning enhancing national airline passenger protections. (January 22, 2008)

ATA Comments on DOT Gate Reporting NPRM

The Air Transport Association of America, Inc. and the Regional Airline Association jointly filed comments in response to the Department of Transportation NPRM concerning revisions to airlines service quality performance reports and disclosure requirements. (January 22, 2008)

Department of Transportation Petition

The Air Transport Association and the Air Carrier Association of America, on behalf of themselves and their passenger and cargo member airlines, request DOT to exercise its authority and declare that new "privilege fee" imposed by the Township of Tinicum, Delaware County, Pennsylvania on aircraft landing at Philadelphia International Airport is preempted and prohibited by the Anti-Head Tax Act. (October 11, 2007)

ATA and RAA Comments on LGA Interim Order Amendment

Attached are the comments of ATA and RAA on the proposed amendments to the LaGuardia Interim Order. (September 7, 2007)

ATA Comments on Composition of Proxy Groups

The Air Transport Association filed comments with FERC on the "Composition of Proxy Groups for Determining Gas and Oil Pipeline Return on Equity". (August 30, 2007)

ATA Joins Fight Against LAX Fee Increases

Because LAX is limited by statutory and regulatory restrictions, ATA's brief in this DOT case disputes LAX's claim that it cannot act like a commercial landlord and unilaterally impose so-called market rents for essential terminal facilities. (May 3, 2007)