American Ai lines May 16, 2023 The Honorable Carol A. (Annie) Petsonk Assistant Secretary for Aviation and International Affairs U.S. Department of Transportation 1200 New Jersey Avenue, SE ‘Washington, DC 20590 Re: Docket DOT-OST-2022-0071 Dear Assistant Secretary Petsonk: ‘American Airlines, inc. (American) respectfully urges the Department of Transportation (DOT) to provide regulatory clarity on the use of 14 CFR part 380 public charter regulations to provide a facsimile ‘of common carriage scheduled service through 14 CFR part 135 charter operations. This “scheduled charter” model, propagated most notably by Delux Public Charter, LLC (dba JSX Air), enables selling individual tickets on pre-scheduled flights like a 14 CFR part 122 airline, while operating under the comparatively less stringent security requirements for Part 135 charter flights Unlike passengers in Part 121 operations, passengers on “scheduled charter” flights are not required to be screened through a traditional Transportation Security Administration (TSA) checkpoint, nor are they required to pay the TSA’s security fee. Drawing on less stringent regulatory requirements to gain competitive advantage, JSX competes against Part 121 airlines on routes between major markets that Part 121 airlines serve. As characterized by Allied Pilots Association President Capt. Ed Sicher and other pilot representatives in a letter filed in this docket, the JSX model depends on “exploiting a ‘public charter’ loophole to fly a published schedule with 30-seat turbojet aircraft under Part 135.” American believes that the “scheduled charter” model as leveraged by JSX degrades our nation’s aviation system and distorts competition. DOT should end this misuse. ‘Thank you for your consideration of our views. Sincerely, Mo Wl —~ Molly Wilkins6n_ Vice Presidertt/Head - Regulatory Affairs and International Affairs American Airlines, Inc.