Thu, Jul 07, 2011
Comments Filed In Proposed Rulemaking For Safety Management
Systems, Safety Enhancements For Part 139, Certificated
Airports
Airports Council International – North America (ACI-NA)
submitted comments Tuesday in response to the FAA's Proposed Rule,
“Safety Management Systems (SMS) for Certified
Airports” and the Notice of Proposed Rulemaking (NPRM),
Safety Enhancements Part 139, Certification of Airports.
Gregory Principato
As a result of serious technical concerns about the Proposed
Rule, ACI-NA has urged the FAA to withdraw the Proposed Rule at
this time and instead focus its efforts on the following:
- Developing a more serious and defensible regulatory
analysis;
- Completing the third airport SMS pilot study;
- Completing and refining its revision to airport SMS
implementation guidance and advisory circulars that detail how the
Rule would need to be implemented;
- Seeking legislative action at the federal and state levels to
provide needed data and liability protections; and
- Working out the details regarding how airport SMSs will
function effectively with the SMSs developed by the other FAA lines
of business. Once these actions are completed, a more effective
airport SMS rule can be developed.
“U.S. airports have an enviable safety record and are part
of one of the safest aviation systems in the world,” said
ACI-NA President Greg Principato. "Nevertheless, our members have
striven to continuously improve the safety of their facilities. It
is critical that safety and security dollars be well spent. FAA
must fully address the concerns of U.S. airports before taking any
further action on this rulemaking."
ACI-NA also provided additional comments on the proposal for
“Safety Enhancements Part 139, Certification of
Airports”. The organization originally submitted comments
regarding the Proposed Rule on May 13, 2011. Since that date, the
FAA published the Initial Regulatory Evaluation (IRE) of the
Proposed Rule to the docket on May 26, 2011 and reopened the
comment period associated with the Proposed Rule. ACI-NA stated in
its comments that after fully reviewing the IRE, airports remain
concerned that the FAA is proposing to implement costly and
time-consuming requirements on airport operators without providing
any tangible evidence that these requirements will enhance airport
safety.
It is ACI-NA’s recommendation that before issuing a final
version of the Proposed Rule, the FAA redo its regulatory
evaluation utilizing both empirical data and industry-accepted
analytical techniques.
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