Regional Air Cargo Carriers Association

We believe this petition should be granted for the following reasons: 1. There would be no safety issue involved, since there are no significant operational or handling qualities differences between the ?light? and ?heavy? EMB- 110 aircraft, other than the presence of engine firex T-handles in some airplanes. As the petitioner points out, this item can be adequately handled in Differences Training. 2. The public interest is served by reducing air traffic, since positioning flights to make a ?heavy? aircraft available for type rating checkrides would be eliminated. The resulting reduction in operating cost allows the operator to provide its services more economically, also in the public interest. 3. Grant of the petition eliminates an unjustifiable economic burden upon the operator. 4. There are numerous examples of common-type-rating aircraft which do not require the largest, or heaviest, or most complex variant to be used on the rating ride, and which encompass much wider variations in aircraft systems, engines, and procedures than addressed by this petition: Boeing 737 (more than eight model variants), DC-6 and 7, Boeing 707 and720, LR-JET (23, 24, 25, 28, 29, 35, 36, etc.), Lockheed Constellation (one rating ride covers model 49, 149, 649, 749, 1049, 1649) etc. ? so this petition is clearly not precedent-setting. We also believe that, since the petition is not precedent setting, expedited handling with waiver of the publication and public comment period would be justified.