February 6, 2015 

Ms. Molly W. Smith 

Federal Aviation Administration 

Office of Aviation Policy and Plans 

AP0-001 

800 Independence Avenue, S.W. 

Washington D.C. 20591 

Thomas L. Bosco 

Director 

& 

RE: Docket No. FAA-2014-1073, Notice of Proposed Rulemaking, Slot Management and 

Transparency for LaGuardia Airport, John F. Kennedy International Airport, and Newark 

Liberty International Airport 

Dear Ms. Smith: 

The Port Authority ofNew York and New Jersey ("Port Authority") respectfully requests an extension of 

the comment period in Docket No. FAA-2014-1073, Notice of Proposed 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 Port Authority is appreciative of the FAA's efforts in developing the Notice of Proposed Rulemaking 

("the NPRM"), which was initiated in October 2010. It is clear that over the past several years, the FAA 

has spent time on the many complex issues related to slot management. 

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 comments incorporating 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, of this important proposal. Key to the Pmi Authority's review of 

the proposed rule is a comprehensive analysis of the impact of each component of the proposed rule, 

including but not limited to, the new daily and half-hourly slot limits, the revision of the minimum slot 

utilization standards, and the multiple proposals for the establishment of an official and regulated 

secondary slot market. 

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In addition to the comment period extension, the Port Authority requires additional information to 

perform a comprehensive review of the 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 of the 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 of the NPRM and the existing Orders, including specifically the MITRE 

queuing models and the University of Maryland Delay Model. 

The request for an extension of the 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 of the 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 in the NPRM. The Orders are in 

effect until the final Rule from this NPRM becomes effective but not 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 would jeopardize 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 of the effects of these proposed rules on operations 

at LGA, JFK, EWR and the traveling public which they serve. 

We therefore, respectfully request that the comment period be extended until June 8, 2015. 

l:~, l:y Sub I itted, 

'Ilmas 1

. . . o~~o D1rector . 

Aviation Department