August 29 , 2014

VIA Electronic Mail Lynne S. Pickard Senior Advisor for Environmental Policy Office of Environment and Energy Federal Aviation Administration 800 Independence Ave, SW Washington, DC 20591 lynee.pickard@faa.gov
RE: Request for Thirty

- Day Extension of Comment Period for Implementation of Legislative Categorical Exclusion for Environmental Review of Performance Based Navigation , Docket No. FAA

- 2014

- 0510

Dear Ms. Pickard : Airports Council Int ernational

— North America (ACI

- NA) respectfully requests a thirty

- day extension of the comment period for the Notice Implementation of Legislative Categorical Exclusion for Environmental Review of Performance Based Navigation , Docket Number FAA

2014

- 0510, w hich was published in the Federal Register on August 19, 2014

. ACI

- NA represents local, regional and state governing bodies that own and operate commercial airports in the United States and Canada

. As you may know, ACI

- NA’s over 300 member airports enplane more than 95 percent of the domestic and virtually all of the international airline passenger and cargo traffic in North America. Nearly 400 aviation

- related businesses are also members of ACI

- NA, providing goods and services to airports.
ACI

- NA a nd our member airports are supportive of the FAA’s efforts to d evelop and implement performance based navigation (PBN) procedures , which have the potential for both operational and environmental benefits for airports. The FAA Modernization and Reform Act of 2012, Section 213(c)(2) (or CatEx2) , directed the FAA to further accelerate implementation of PBN procedures by categorically excluding procedures that “ result in measurable reduction s in fuel consumption, carbon dioxide emissions, and noise on a per fl ight basis as compared to aircraft operations that follow existing instrument flight rule procedures in the same airspace” . Due to technical challenges with measuring noise on a per

- flight basis, the FAA requested guidance from the NextGen Advisory Commit tee (NAC) on how to implement Section 213(c)(2).2

2 In response to this request, the NAC convened a work group representing a broad range of industry stakeholders

– including ACI

- NA and several of our member airports

– and developed a recommendation to the FAA for implementation of CatEx2 (t he Net Noise Reduction Method)

. The FAA requests public comment on the Method as recommended by the NAC, as well as on alternative approaches to a net noise reduction methodology described in the Notice. ACI

- NA and its members wish to provide constructive responses to these, and other questions posed by the Agency in the Notice

. In accordance with this goal, we and our member airports believe that an extension in the comment period is necessary for the following reasons : (1) Time is needed for ACI

- NA to communicate with our extensive membership who may hold differing views on the contents of the Notice (2) The comment period

— which extends from August 19, 2014 , to September 18, 2014

— occurs during a time period that is extremely busy for airports (including the ACI

- NA Annual Conference and Exhibition in early September)
ACI

- NA appreciates the opportunity to comment on the Notice and in collaboration with our members, looks forward to providing the FAA with meaningful responses
. To facilitate neede d industry participation in this process, we respectfully request that the FAA grant the thirty

- day extension of the comment period. Thank you for your time and consideration of this request. Sincerely,

Katherine Preston Senior Director, Environmental Affairs Airports Council International

– North America