"GAMA notes that the ARAC was tasked
with developing new regulations for long-range operations conducted
in accordance with 14 CFR Part 121 and for 14 CFR Part 135 (et.
al.). Part 121 long-range operations have been governed by FAA
advisory circulars for many years and are widely understood. On the
other hand, FAA has never provided guidance or regulations for
on-demand, long-range operations flown in accordance with Part 135.
These two very different communities have a very different
“awareness” of long-range operating procedures."
Source: Ron Swanda, Sr. VP of
Operations for the General Aviation Manufacturers Association, in
GAMA's response to the FAA's somewhat contentious ETOPS NPRM
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