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 highly concerned with airport safety and taking the appropriate 

steps necessary to accommodate this proposal, but in order to do so, further analysis by 

our membership would be required. The current time-frame set forth in the Notice of 

Proposed Rulemaking (NPRM) is not sufficient.

More specifically, 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 helpful in assisting airports through their own costing 

analyses. Although, as previously stated, the end result is referenced 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 that 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 the “U.S. DOT/FAA - Initial Regulatory 

Evaluation” was not posted to the docket until after the proposal was published in the 

Federal Register, therefore limiting the amount of time for airports had to study, analyze 

and compare the necessary information.

Airports will need more time than that given by the FAA in order to analyze the proposed

requirements, some of which could have a large impact on the airport facility. Careful 

technical, financial, and labor analyses would be needed to formulate a feasible 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 especially 

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. Those within airport operations 

would be most involved in preparing comments to this rule. 

In conclusion, AAAE appreciates the opportunity to provide comments to the FAA on this 

proposed rule. We, along with the rest of the industry, hope to be able to provide 

meaningful feedback in order to achieve a final rule that will meet the necessary safety 

standards, but also one that does not cause undue and unintended consequences. 

Therefore, we hope that the FAA will honor our request of a ninety-day extension of this 

comment period. 

Thank you for the consideration of this request.

Leslie Riegle

Director of Regulatory Affairs

The American Association of Airport Executives