This section contains the nature of the case and procedural background.

It is common for a fishing or hunting guide in Alaska to serve as the pilot of the light aircraft used in their trade. In 1963, the FAA consistently advised guide pilots that they were not governed by regulations dealing with commercial pilots. In January 1997, P, aware that the FAA was considering a new regime for regulating Alaskan guide pilots, submitted a petition for rulemaking. In January 1998 without having responded to P's petition, the FAA 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 pilots to abide by FAA regulations applicable to commercial air operations. P contends that the Notice to Operators altered D's well-established interpretation of its regulations and should have been promulgated pursuant to notice and comment rulemaking. D contends that the Notice never changed any authoritative interpretation and was thus exempt from notice and comment.

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