On Thu, 5 Jan 2006 19:08:06 -0800, "Peter Duniho"
wrote in
::

Anyone who thinks that comments to a NPRM will have
any real effect on the outcome just hasn't been
paying attention to the way the FAA has handled them.

While I don't disagree with that analysis of the record, the NPRM
procedure does require the FAA to justify their decision with reasoned
responses to the questions/objections raised during the comment
period(s). It would seem that this opens an avenue to legally
challenge that rational in an effort to modify/strike-down the
rule(s).