LAS VF1~AS Department of Aviation,

A\T~ RANDALL H. WALKER

~REOTDP

ROSEMARY A. \IASSILIADIS

DEPUTY DIPECTOR

______ POSTAL BOX 11005

McCARRAN INTERNATIONAL AIRPORT 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. Robert Hawks

Office ofthe Chief Counsel, Regulations Division

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

RE: Extension to Comment Period for NPRM — Safety Management System

Dear Mr. Hawks:

The Clark County, Nevada Department of Aviation requests a 90-day extension ofthe comment

period for the Notice of Proposed 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 certificated airports,

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 of Aviation need to give thoughtful and analytical consideration to the proposal in

order to 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 both for 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 ofother pilot programs participants and to compare Clark County’s

experience with those of other airports. All of this research, data gathering and technical

analysis will take time.

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 • Susan Brager, Vice Chair

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

- December 2, 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. - -

Given the importance ofthe proposed amendment to 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 Clark County Department of Aviation to prepare comments. We appreciated

the FAA’s cotisideration ofthis request.

Sincerely, - -

~ ~ -

TERESA R. MOTLEY, AICP

Airport Planning Manager

cc: - Randall II. Walker

Rosemary A. Vassiliadis

Cecil Johnson

Joseph Kubacki

Christine Santiago