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# S Department ofAviation, 

# A\T~ RANDALL H. WALKER ~REOTDP ROSEMARY A. \IASSILIADIS DEPUTY DIPECTOR

______ POSTAL BOX 11005 McCARRAN INTERNATIONALAIRPORT LAS VEGAS, NEVADA 89111-1005 (702) 26’l- 5211 FAX (702)597-9559

- E-MAIL: webmaEter’2Bmccarran.com December 2, 2010
Filed electronically: www.regulations.gov Docket ID: FAA-2010-0997 Mr. RobertHawks Office ofthe ChiefCounsel, Regulations Division Federal AviationAdministration 800 Independence Avenue, SW Washington, DC 20591 RE: Extension to Comment Period forNPRM

— Safety Management System DearMr. Hawks: The Clark County, Nevada Department ofAviation requests a 90-day extension ofthe comment period for the Notice ofProposed Rulemaking for the proposed rule on “Safety Management System for Certificated Airports,” 75 Red. Reg. 62008 (Oct. 7, 2010). The proposed SMS rule would fundamentally alter the regulatory environment for certificated airports, would require. substantial operational and administrative changes at certificatedairports, and would materially change airports’ exposure to liability forsafety problems at their facilities. In order to understand these significant changes, operators of airports like Clark County Department ofAviation need to give thoughtful and analytical consideration to the proposal in orderto provide the agency with meaningful cOmments. It will take Clark County considerable time to assemble these comments fromnumerous Clark County divisions and consultants. In addition, because the SMS proposal is novel, Clark County needs time to research the implications ofthe proposal bothfor McCarran International Airport, as well as for the smaller County airports. The fact that the NPRM was issued only shortly after the FAA issued Order 5200.11 means that commenters need also to understand the interplay between these two important regulatory changes. Clark County staff and consultants have attended, and intend to participate in conferences, webinars, and other industry forums to learn more about the FAA’s pilot program, the experience ofotherpilot programs participants andto compare Clark County’s experience with those of other airports. All of this research, data gathering and technical analysis willtaketime. With the busy Thanksgiving and Christmas holiday season, the FAA’s comment period is practically far shorter than the 90 days that will have elapsed by the January 5, 2011 comment
Clark CountyBoard of Commissioners ~J e. Rory Reid, Chair • SusanBrager,Vice Chair

Larry Brown • Tom Collins. • Chris Giutichigliani • Steve Sisolak • LawrenceWeekly 4.’,p~.Mr. Robert Hawks

- December2, 2010 Page-2 deadline. A 90-day extension will afford Clark County adequate time afterthe holiday rush to complete our research and technical analysis and to prepare meaningful comments on the NPRM.

- - Giventhe importance ofthe proposed amendmentto Part 139-and the long-term implications for all certificated airports, it would be appropriate for-the FAA to allow additional time for airport proprietors like the ClarkCounty Department ofAviation to prepare comments. We appreciated theFAA’s cotisideration ofthis request. Sincerely,

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~ - TERESA R. MOTLEY, AICP AirportPlanning Manager
cc:

- Randall II. Walker RosemaryA. Vassiliadis Cecil Johnson JosephKubacki Christine Santiago