Alaska Professional Hunters Ass'n v. Federal Aviation Administration

Opinion for the Court filed by Circuit Judge RANDOLPH.

RANDOLPH, Circuit Judge:

In January 1998 the Federal Aviation Administration published a “Notice to Operators” aimed at Alaskan hunting and fishing guides who pilot light aircraft as part of their guiding service. The Notice required these guide phots to abide by FAA regulations applicable to commercial air operations. The question in this peti*1031tion for judicial review, brought by a guide organization and individual guides, is whether § 553 of the Administrative Procedure Act required the FAA to proceed by way of notice and comment rule…