Comment from AAAE/ACI-NA (Request to Extend Comment Period)

Please see attached joint AAAE/ACI-NA letter requesting an extension of time in which to file comments.

Comment Date:2023-11-17T05:00:00Z

Comment On Document ID:FAA-2023-1739-0003

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Comment from Alvin Brunner

I wholehearted support this change. While I fully support the concept of including AAM, UAS and space launch and recovery operations being expressly stated as an aeronautical activity, I find it completely unnecessary. Aeronautical activity by its plain language definition includes any flight or use of airspace by any aircraft or vehicle. The term itself is broad and should have included UAS years ago. I have even argued with Airport District Offices (ADOs) over what could or should be included in the realm of aeronautical activity, and each ADO dogmatically adhered to only those activities on the list provided in the order. FAA Order 5190.6B, attached for ease of reference, clearly states that "ANY" (emphasis added) activity related to aircraft operation is included and then it provides a list that includes "but not limited to" many examples. I am confounded that the FAA has refused to include UAS as an aeronautical activity. The use of the words "any" and "not limited to" provide a very broad scope for what may be included, yet the Office of Airports has refused to include any UAS operation for years. The FAA's General Counsel has shown time and again that the terms "any," "not limited to," or "such as" are not exclusive of all others. The FAA's recent legal interpretation of 49 USC 40125, governmental functions, leveraged the term "such as" to broaden the types of operations that may be considered a public aircraft operation. Now the Office of Airports is finally recognizing UAS, and subsequently AAM and space activities, as aeronautical activities; it is very long overdue. Moreover, to ensure any future aircraft innovation is included, the Office of Airports should reemphasize the fact that a flying jetson car device would and should be included as an aeronautical activity though not expressly stated in the definition.

In order to provide merit to my comments, I am considered an aviation expert and foremost a UAS expert with over 13 years' experience within the UAS industry. I have over 24 years of international flight experience and hold an ATP with several type ratings. I also have a Masters of Aeronautical Sciences from Embry-Riddle University.

Comment Date:2023-11-17T05:00:00Z

Comment On Document ID:FAA-2023-1739-0002

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Comment from United Airlines

Please see attached comment.

Comment Date:2023-11-17T05:00:00Z

Comment On Document ID:FAA-2023-1986-0009

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Comment from John C Calvert

See Attached

Comment Date:2023-11-17T05:00:00Z

Comment On Document ID:FAA-2023-1893-0164

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