Comment Submitted By David Ziemer, Seaborne Airlines

Upon review of the proposed rules, this will create significant financial hardship on small carriers that operate short segments to/from the U.S. to foreign countries. We operate 17 passenger aircraft in and around the U.S. (USVI) and British Virgin Islands (BVI) where passengers expect a hassle free experience including timely service. Some of our flights can be as short as 12 minutes from the USVI to the BVI. Advanced notification will likely delay flights as people check-in 15 minutes before their departure. Since we compete with ferry service on many of the same routes, this could create an unfair advantage as they will have passengers checking in 5 minutes before a ferry leaves and they can expect to be at their destination in 30-45 minutes. In addition to delays and creating an unfair advantage, the cost for developing the automation to meet these requirements may be unbearable. I'm sure that many small carriers share the same concerns as there are several operators flying short segments in the Caribbean and to the Bahamas. Recommendations: Any segments flight planned for 1 hour in length or less should be exempt from this rule. Furthermore, any flights between the U.S., U.S. Territories and U.S. Commonwealths must be exempt. Lastly, carriers should be able to submit a request for exemption on certain routes. Thank you for your consideration.