ETOPS rules flawed?
 

http://www.nata-online.org/2GovWatch...PSComments.htm

http://web.nbaa.org/public/ops/etops...ts20040315.pdf

http://www.avweb.com/eletter/archive...ll.html#186933
"Alphabet groups claim the FAA hasn't done its homework in a proposal to set a maximum 180-minute diversion time limit for the extended operations (ETOPS) of Part 135 aircraft (qualified commercial aircraft could be allowed to fly up to three hours from any suitable landing site). In written comments on the Notice of Proposed Rulemaking (NPRM), both the National Air Transportation Association (NATA) and National Business Aviation Association (NBAA) say the FAA can't accurately predict the fallout from the restrictions because there is no comprehensive database of aircraft performance to determine how operators might be affected by such a rule. NATA has asked that further action on the rule be postponed and that the comment period, which closed a week ago, be extended another 90 days. NATA's director of government and industry affairs, Eric Byer, said 180 minutes means different things to different operators of different aircraft. For flight-planning purposes, operators would have to translate the three hours into the distance they could travel on a single engine in a particular make and model of aircraft under a wide variety of circumstances. But the manufacturers haven't come up with those speed tables so the calculations are impossible, says Byer. "If data essential to analyzing the rule does not exist, how could the FAA have reasonably determined the impact?" he wondered. "