Comments on: New airline ground delay rules need a lot of work http://www.elliott.org/blog/new-airline-ground-delay-rules-need-a-lot-of-work/ The travel troubleshooter. Mon, 22 Mar 2010 01:46:06 +0000 http://wordpress.org/?v=2.9.2 hourly 1 By: Mekhong Kurt http://www.elliott.org/blog/new-airline-ground-delay-rules-need-a-lot-of-work/comment-page-1/#comment-14420 Mekhong Kurt Sat, 06 Sep 2008 01:38:17 +0000 http://www.elliott.org/?p=5198#comment-14420 SirWired makes an excellent point. SirWired makes an excellent point.

]]> By: SirWired http://www.elliott.org/blog/new-airline-ground-delay-rules-need-a-lot-of-work/comment-page-1/#comment-14360 SirWired Tue, 02 Sep 2008 15:14:05 +0000 http://www.elliott.org/?p=5198#comment-14360 I just thought I would point out that this is not a proposed rule or regulation. (Yeah, I know it's at "regulations.gov".) The docket clearly states that it is "nonrulemaking". Given that it uses words like "voluntary", and explicitly states it is going to use the word "should" to further reinforce this, is an indication that this is more of a "best practices"-like document then any proposed mandatory standard. Think of it as something like the Food Guide Pyramid rather than something you are going to see in the FAR/AIM/CFR any time soon. I just don't see commenting calling for mandatory standards being particularly useful here. Comments on government documents are only paid attention to if they are actually about the document in question. Comments calling for stronger mandatory standards in a document made by the "NATIONAL TASK FORCE TO DEVELOP MODEL CONTINGENCY PLANS TO DEAL WITH LENGTHY AIRLINE ONBOARD GROUND DELAYS" are going to be ignored. The whole point of the document is to create voluntary model plans. Yes, regulation is needed, but commenting on a document not intended to create a regulation is not going to make it happen. A better use of time would be further prodding of your elected officials and prodding of the FAA through the passenger complaint process, which is taken surprisingly seriously by both the FAA and the airlines. (I'm not even sure the legislation covering the FAA would even allow them to set mandatory standards for ground delays... remember that regulatory agencies cannot exceed the authority given them by legislation.) Campaigning to have the weasel words taken out of this document would be like writing the Department of Agriculture because the Food Guide Pyramid didn't legally ban french fries. It just isn't going to accomplish anything because the comments would be going to the wrong place. SirWired I just thought I would point out that this is not a proposed rule or regulation. (Yeah, I know it’s at “regulations.gov”.) The docket clearly states that it is “nonrulemaking”. Given that it uses words like “voluntary”, and explicitly states it is going to use the word “should” to further reinforce this, is an indication that this is more of a “best practices”-like document then any proposed mandatory standard. Think of it as something like the Food Guide Pyramid rather than something you are going to see in the FAR/AIM/CFR any time soon.

I just don’t see commenting calling for mandatory standards being particularly useful here. Comments on government documents are only paid attention to if they are actually about the document in question. Comments calling for stronger mandatory standards in a document made by the “NATIONAL TASK FORCE TO DEVELOP MODEL CONTINGENCY PLANS TO DEAL WITH LENGTHY AIRLINE ONBOARD GROUND DELAYS” are going to be ignored. The whole point of the document is to create voluntary model plans. Yes, regulation is needed, but commenting on a document not intended to create a regulation is not going to make it happen. A better use of time would be further prodding of your elected officials and prodding of the FAA through the passenger complaint process, which is taken surprisingly seriously by both the FAA and the airlines. (I’m not even sure the legislation covering the FAA would even allow them to set mandatory standards for ground delays… remember that regulatory agencies cannot exceed the authority given them by legislation.)

Campaigning to have the weasel words taken out of this document would be like writing the Department of Agriculture because the Food Guide Pyramid didn’t legally ban french fries. It just isn’t going to accomplish anything because the comments would be going to the wrong place.

SirWired

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