### February 6, 2015

Ms. MollyW. Smith Federal AviationAdministration Office ofAviation Policy andPlans AP0-001 800 IndependenceAvenue, S.W. WashingtonD.C. 20591 Thomas L. Bosco Director 

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RE: Docket No. FAA-2014-1073, Notice of Proposed Rulemaking, Slot Management and Transparency for LaGuardia Airport, John F. Kennedy International Airport, and Newark LibertyInternationalAirport


### DearMs. Smith:
The PortAuthority ofNewYork and NewJersey ("Port Authority") respectfully requests an extension of the commentperiod in DocketNo. FAA-2014-1073, Notice ofProposed Rulemaking, Slot Management and Transparency for LaGuardia Airport ("LGA"), Jolm F. Kennedy International Airpmi ("JFK"), and Newark Liberty International Airpmi ("EWR"). The notice instituting this proceeding directs that comments be filed on or before April 8, 2015. We hereby request that the Federal Aviation Administration ("FAA") extend the comment period for 60 days, up to and including June 8, 2015, the Monday after the sixtieth day following AprilS, 2015.
The PortAuthority is appreciative ofthe FAA's efforts in developingtheNotice ofProposed Rulemaking ("the NPRM"), which was initiated in October 2010. It is clear that over the past several years, the FAA has spenttime onthe many complexissues relatedto slotmanagement.
Due to the length of the NPRM, the breadth of information sought, and the technical nature of its contents, the Port Authority believes that 90 days is an insufficient period in which to generate substantive commentsincorporating the considerable legal, policy and operational implications associated with the NPRM. The Port Authority has proprietary rights and responsibilities to manage the airport facilities which will be affected by the implementation of the NPRM proposals. As such, the Port Authority seeks adequate time to thoroughly research and understand the operational consequences, as well as the legal and policy implications, ofthis importantproposal. Keyto the PmiAuthority's review of the proposed rule is a comprehensive analysis ofthe impact of each component ofthe proposed rule, including but not limited to, the new daily and half-hourly slot limits, the revision ofthe minimum slot utilization standards, and the multiple proposals for the establishment of an official and regulated secondary slotmarket.

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72In addition to the comment period extension, the Port Authority requires additional information to perform a comprehensive review ofthe NPRM, particularly as related to the FAA's specific requests for comments. The Port Authority requests utilization records from the FAA for individual Operating Authorizations in a form that is suitable for analysis, such as a Microsoft Excel spreadsheet or Microsoft Access database. These records should include slot owner, slot operator (pursuant to any slot lease and trade agreements, including information about the terms ofthe lease), and historical slot utilization data. Additionally, the Port Authority requests all models, data and analysis cited in the NPRM and Initial Regulatory Analysis in support ofthe NPRM and the existing Orders, including specifically the MITRE queuing models and the University ofMarylandDelayModel.
The request for an extension ofthe comment period presents no adverse effects for the traveling public, the airports, air carriers or the FAA. All interested parties would benefit from a thorough and thoughtful review ofthe FAA's proposals. The FAA has issued three Orders entitled Operating Limitations at New York La Guardia Airport (Docket No. FAA-2006-25755), Operating Limitations at John F. Kennedy International Airport (Docket No. FAA-2007-29320), and Operating Limitations at Newark Liberty International Airport (Docket No. FAA-2008-0221), that set fmih interim rules limiting operations at LGA, JFK, and EWR at substantially equivalent levels to those proposed inthe NPRM. The Orders are in effect until the final Rule from this NPRMbecomes effective butnot later than October 29, 2016; further, the Orders can be amended to extend the effective date as necessary (as FAA has done multiple times in the past). Consequently, it is not anticipated that the requested extension wouldjeopardize the ability of the Port Authority and the FAA to continue to manage congestion in the interim. We believe that the additional time will be well spent on our intense study ofthe effects ofthese proposedrules on operations atLGA, JFK, EWRandthetraveling public whichthey serve. Wetherefore, respectfully requestthatthe commentperiodbe extendeduntil June 8, 2015.



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