This public interest comment is in response to the Federal Aviation Administration's request for comment on its intent to initiate a rulemaking to amend 14 CFR 110 by removing part 380 definitions in 14 CFR 110.2 and delink FAA’s Safety regulations from DOT’s economic regulations. FAA's proposal would effectively expand the scope of some regulations that currently apply to only large commercial carriers to include small public charter services. We argue that the proposal lacks merit for several reasons:
- there does not appear to be an increase in public charter travel since relevant rules were first adopted;
- growth in this area on its own doesn’t appear to justify new rules;
- there is little safety benefit to changing rules; and
- there are substantial costs to a variety of communities—from small cities, to Native American tribes, to consumer segments who value the products provided.
Additionally, it is unclear that existing law provides the requisite authority to make the contemplated changes, and at a minimum there are a number of required considerations that must occur before they would do so.