April 1, 2008

**[VIA EMAIL]{.underline}**

Docket Operations

U.S. Department of Transportation

West Building, Ground Floor

Room W12-140

Routing Symbol M-30

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: NPRM- Policy Regarding Airport Rates and Charges

Docket No. FAA-2008-0036

To Whom It May Concern:

Pittsburgh International Airport sees the effects of airspace congestion
in the northeast United States on a regular basis. It is not unusual for
flights in and out of Pittsburgh to be delayed by the situation in the
Northeast. This is a situation that is affecting the travel habits of
our customers. We would like to make the following comments to the NPRM.

First, this notice proposes to clarify the Rates and Charges policy by
explicitly acknowledging the ability of airport operators to establish
two-part landing fee structures, consisting of both an operation charge
and a weight-based charge, in lieu of the standard weight-based charge.
Such a two-part fee would serve as an incentive for carriers to use
larger aircraft and increase the number of passengers served with the
same or fewer operations.

1.  This approach is not comprehensive and will not address or solve the
    overall problem of scheduled over capacity. This is a noble first
    attempt but, many additional steps will be needed to address this
    problem. While some airlines will cut down on the number of
    operations through the use of larger aircraft, without caps or other
    restrictions, other airlines will just add flights. Again, back to
    the original problem of not enough capacity. Also, when different
    rates for different size aircraft are established the larger more
    secure airlines will have the advantage. Monetary penalties, as
    these would be perceived as, are not a substitution for sound
    directive policies. .

2.  Many operators and users have long term use and lease-agreements and
    fee structures already in place. This proposal does not address the
    specifics that will be required to be properly implemented. Airport
    operators, without specified guidance on how to implement this plan,
    would be vulnerable to litigation. Litigation of any type would
    cause undue delays and increased costs in any implementation plans.

3.  The increased utilization of alternative airports that are operating
    at less than their respective capacity should and must be a valued
    consideration to any plan to address the congestion in the Northeast
    portion of the U.S. An excellent example for this concept would be
    Pittsburgh International Airport. PIT can handle the type of traffic
    both in size as well as numbers to ease the congestion problems we
    are faced with today. We feel that airlines could significantly
    reduce operating costs and increase passenger service if there were
    increased use of the terminal and airspace capacity available in
    Pittsburgh.

Second, this action proposes to expand the ability of the operator of a
congested airport to include in its airfield fees, a portion of the
airfield costs of other, under-utilized airports owned and operated by
the same proprietor.

1.  This action should be amended to read as follows:

> To expand the ability of the operator of a congested airport to
> include in its airfield fees, a portion of the airfield costs of
> other, under-utilized airports that are participating in a program to
> reduce congestion at the congested airport no matter if they are owned
> (operated) or not owned (operated) by the same proprietor.
>
> This is a national congestion problem, not a local congestion problem.
> Therefore, if any under-utilized airport comes to the aid of a
> congested airport, it should be entitled to some benefit no matter if
> the operators are the same or not.

Third, this action proposes to permit the operator of a congested
airport to charge users a portion of the cost of airfield projects under
construction. This notice proposes two alternatives. The first would
permit the costs to be included in the rate base only during periods
when the airport experiences congestion. (There must be a detailed
definition of "periods of congestion.") The second would permit these
costs to be included in the rate base of the congested airport at all
times.

1.  This proposal should be expanded to include all airports that are
    participating in a program to reduce congestion at the congested
    airport not just "congested airports". Any airport that makes
    improvements that increases capacity for the overall national system
    should be allowed to pass along the cost as the construction is
    occurring. The problem must be viewed as a national concern not just
    "congested area" concerns.

2.  The second alternative of permitting these construction costs at all
    times would be the only logical avenue to consider. To say that
    these costs could only be incurred during congested periods would
    place an undue burden on the airport and users to define what are
    "congested periods." Also, when delays are factored in, the
    congested periods would be prolonged and impossible to define. If,
    due to any construction at any airport, delays and congestion are
    eased the overall national system benefits. When the national system
    improves it is a benefit to all the users of the system. Therefore,
    since all users benefit it would only be fair that all share the
    burden of the cost.

Thank you for your consideration. If you have any questions or comments,
please feel free to contact me at 412.472.3510.

Sincerely,

Bradley D. Penrod, A.A.E.

Executive Director/CEO