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 International—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 FAA2014-0510, which 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 and our member airports are supportive of the FAA’s efforts to develop 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 reductions in fuel 

consumption, carbon dioxide emissions, and noise on a per flight 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 Committee (NAC) on how to implement Section 213(c)(2). 
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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 (the 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 needed 

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