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Tuesday, 19 August, 2008

Docket FAA-2007-29281, Notice of Proposed Rulemaking - Removal of Regulations Allowing For Polished Frost On Wings Of Airplanes

What's at Issue
NATA recently submitted comments to the FAA regarding a proposal to remove an exception for operations where frost has been polished smooth.

August 19, 2008

Docket Operations, M-30
U.S. Department of Transportation
1200 New Jersey Ave, SE
West Building Ground Floor, Room W12-140
Washington, DC 20950

Re: Docket FAA-2007-29281, Notice of Proposed Rulemaking - Removal of Regulations Allowing for Polished Frost on Wings of Airplanes


NATA appreciates the opportunity to comment on the changes proposed in this rulemaking and believes that the FAA presents a convincing case for removal of the exception permitting operations with polished frost. NATA concurs that the adherence of contaminants such as frost can have adverse aerodynamic impacts.

However, given that the vast majority of affected operators are in Alaska, we are concerned about the potential unintended negative consequences this rulemaking may create.

The FAA has identified four alternatives for operators to utilize once this exception is removed. Reviewing other comments to this docket reveals that several affected operators are concerned about the lack of sufficient and available hangar space and the difficulty of installing wing covers as potential obstacles. NATA encourages the agency to consider these legitimate concerns carefully to determine an appropriate compliance/transition timeline.

With regard to the FAA's decision to respond to the Part 125/135 Aviation Rulemaking Committee (ARC) recommendation to clarify §135.227(c), NATA is pleased the agency has taken this step to correct an often misunderstood regulation. As a member of the ARC, we believe it is vital for the agency to continue to act upon the numerous recommendations in as timely a manner as possible.

Sincerely,


Jacqueline E. Rosser
Director, Regulatory Affairs

For general press inquiries, contact Shannon Chambers at 703-298-1347 or schambers@nata.aero

The National Air Transportation Association (NATA) has been the voice of aviation business for more than 80 years. Representing nearly 3,700 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.