November 19 , 2010

Mr. Robert Hawks Office of the Chief Counsel, Regulations Division Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Re: Extension to Comment Period for Safety Management System for Certificated Airports

Sent via: www. regulations.gov

Docket ID: FAA

- 2010

- 0997

Dear Mr. Hawks:

The American Association of Airport Executives (AAAE) would like to request a ninety

- day extension of the comment period for the recently Proposed Rule, “ Safety Management System for Certificated Airports ”

, published in the Federal Register on October 7, 2010.

Our airport membership is high ly concerned with airport safety and takin g the appropriate steps necessary to accommodate this proposal

, but in order to do so, further a nalysis by our membership would be required

. The current time

- frame set forth in the N otice of P roposed R ulemaking (NPR M ) is not sufficient

.

More s pecifically, the membership is interested in reviewing the data associated with the SMS pilot studies beyond the summary that was posted within the proposal, or in the supporting document posted on October 13, 2010 . The resulting costs and benefits along with methodologies would be he lpful in assisting airports through their own costing analyse s

. A l though , as previously stated, the end result is reference d at certain points in the proposal, including the cost/benefit analysis, and in general when establishing the implementation costs, no further detail is given. While we are appreciative tha t the FAA conducted these careful studies prior to proposing this rule, the details behind this information would be beneficial for airports in order to determine these details for themselves. The summary information within th e “ U.S. DOT/FAA

- Initial Regulatory Evaluation ” was not posted to the docke t until after the pro posal was published in the Federal Registe r

, therefore limiting the amount of time for airports had to study, anal yze and compare the necessary information.

A irports will need more time than th at given by the FAA in order to analyze t he proposed requirements , some of which could have a large impact on the airport facility . Careful
t echnical

, financial

, and labor analyses would be needed to formulate a feas i b le approach and strategy

.2

Additionally problematic

, the deadline of the proposed comment period

, January 5, 2011, falls right after the busy Thanksgiving and holiday travel season . This is an es pecially difficult time for those in airport operations

, not only for the increased amount of holiday traffic, but also as the winter months add additional strain. T h ose within airport operations would be most involved in preparing comments to this rule.

In conclusion, AAAE appreciates the opportunity to provide comment s to the FAA on this proposed rule. We , along with the rest of the industry

, hope to be able to provi de meaningful f

eedback in order to a chieve a final rule that will meet the necessary safe ty standards

, but also one that does not cause un due and unintende d consequences

. Therefore

, we hope that the FAA will h onor our request of a ninety

- day extension of this comment period.

Thank you for t he consideration of this request.

Leslie Riegle Director of Regulatory Affairs The American Association of Airport Executives