Originally Posted by
forgot to bid
Plan A would be the air carrier definition. And I thought the idea of going after the legal definition of air carrier would be something to take up with the DOT for government clarification similar to what was done with the Whitlow letter in 2000?
If we get the interpretation to be that a holdings company is STS then RAH, AMR/AE and anyone else is out.
The DOT would tell us to go away. "We don't do scope disputes".
They will say that the FAA regulates "certificate holders" and they don't care about "air carriers" because their focus is on safety and our little dispute is a perfect example of why they don't want to get tied up in knots over corporate shell games.
Our scope clause however, is precisely concerned with corporate shell games.
The DOT would say, "The Congress defined "air carrier" in the US Code, why don't you use that definition?"
(to which I would say --->
what a great idea! )