Aerospace Industries Association of America, Inc. 1000 Wilson Blvd., Suite 1700, Arlington, VA 22209 Tel (703) 358-1000 Fax (703) 358-1011 Internet: http://www.aia-aerospace.org General Aviation Manufacturers Association

Internet: http://www.GAMA.aero Rond Point Schuman 6 B-1040 Brussels, Belgium Tel +32 (0) 2 234 77 09 1400 K Street NW, Ste 801 Washington, DC 20005

Tel +1(202) 393-1500 January 20, 2011

Scott Van Buren Chief System Engineer for Aviation Safety Office of Accident Investigation and Prevention (AVP)

Federal Aviation Administration 800 Independence Avenue, SW., Washington, DC 20591

SUBJECT: AIA/GAMA Request for Comment Extension to NPRM 10-15, Safety Management Systems (Docket No. FAA–2009–0671)

The Aerospace Industries Association (AIA) and General Aviation Manufacturers Association (GAMA) represent manufacturers of commerc ial and general aviation aircraft, engines, avionics and components who also provide airworthine ss and maintenance services to nearly every commercial and general aviation operator in the U.S. AIA/GAMA respectfully request the Federal Aviation Administration (FAA) extend the comment period for the review of NPRM 10-

15, Safety Management Systems [SMS] for Part 121 Certificate Holders (75FR68224) for an additional 60-days, as it is necessary in the interest of the aviation organizations that may be directly affected by this proposed rule and the traveling public. AIA/GAMA offer the following comments in support of this request.

This NPRM proposes to establish a brand new FAR part 5, creating a general framework for SMS requirements with initial applicability to require each part 121 air carrier to develop and implement an SMS. However, the FAA clearly states that "Although this proposal extends only to part 121 operators, the FAA has developed these general requirements with the intent that in the future, they could be applied to other FAA-regulated entities, such as part 135 operators, part 145 repair stations, and part 21 aircraft design and manufacturing organizations and approval holders, consistent with ICAO requi rements... FAA solicits comments on possible future application of these general requirements (75FR68232).” This proposal and the new part 5 will serve as the foundation for SMS requirements for the foreseeable future, so it is extremely important that it’s initial establishment take due consideration of its intended application across the broader industry.

AIA/GAMA are submitting this request for an extension to the comment period because we believe it is necessary in order to provide an adequate opportunity for our member companies and all other FAA-regulated entities, such as part 145 repair stations and part 21 aircraft design and production approval holder organizations. T he additional time is necessary for industry outreach to assure that there is awareness of this NPRM and understanding that although the title extends only to part 121 operators, FAA states on the ninth page of the proposal the intent to apply these requirements to many other organizations in the future and specifically requests

their comments. GAMA 11-09AIA/GAMA Request for Comment Extension, NPRM 10-15 Safety Management Systems Page 2 of 3 January 20, 2011

The SMS proposal is a significant rule in terms of its complexity and potential impact upon nearly every facet of an aviation organization including safety, regulatory compliance and business management decision making processes. There is a significant "learning curve" for any organization who wishes to comment upon this NPRM to understand the proposed requirements, obligations and costs, and intended benefits associated with SMS. Adequate time is necessary for industry to become fam iliar with the proposal and to provide substantive comments and recommendations which results in better rules in the interest of aviation safety and the traveling public.

Equally important are comments and questions raised by industry to ensure a common understanding of the intent of the regulatory language and methods of compliance. This information needs to be clearly communicated during this rulemaking process so as to ensure efficient implementation which will achieve t he desired benefits. Part 5 are performance-based requirements with the objective of providing scalability and flexibility across a broad range of organization size and complexity and to recogni ze processes that companies already have in place. Therefore, it is particularly import ant that FAA receive comments from the broadest range of companies possible. The NPRM references related draft documents (initial regulatory evaluation, AC120-92-NPRM, and Order 8900.1 Chapt er X) available from the docket, which provide a lot of information regarding FAA’s interpretation and envisioned implementation of the proposed SMS requirements. However, additional time is necessary if industry is to be able to perform an adequate review and comment to these draft documents.

The FAA Aircraft Certification Service (AIR) has been developing a manufacturer SMS (MSMS) pilot program to build experience with the pr actical implementation of SMS requirements upon part 21 design and production organizations. AIR plans to make the MSMS implementation tools and guidance available on the FAA’s website once the initial kick-off meetings with the first pilot program company is completed next week. These MSMS pilot materials will provide significant information and understanding regarding the application of SMS requirements to part 21 design and production organizations and will be very important and helpful in the development of substantive comments and recomm endations in response to the SMS NPRM. Therefore, additional time is necessary for the FAA MSMS pilot implementation tools and guidance to be made available to industry to take into consideration.

AIA/GAMA member companies endorse the principles and concepts of SMS and have supported FAA’s consideration of possible SMS requirements through participation on the SMS Aviation Rulemaking Committee (SMS-ARC). However, the broad range of industry sectors represented on the SMS-ARC have also expressed concerns about the potential difficulty, complexity and burden of regulatory compliance with new SMS requirements without commensurate safety benefit. Therefore, it is extremely important that FAA provide adequate opportunity for the broad industry to review and understand the SMS NPRM and related draft implementation materials and develop subst antive comments and recommendations and raise questions as needed. The unfortunate timing of this NPRM having been put out for comment over the holiday season has only further exacerbated the limited amount of time industry has

available for review and comment.

AIA/GAMA respectfully request that the Federal Aviation Administration (FAA) extend the comment period for the review of NPRM 10-15, Safety Management Systems [SMS] for Part

121 Certificate Holders (75FR68224) for an additional 60-days as it is necessary in the interest of the aviation organizations that may be directly affected by this proposed rule and the travelingAIA/GAMA Request for Comment Extension, NPRM 10-15 Safety Management Systems Page 3 of 3 January 20, 2011

public. We appreciate your consideration of this request and look forward to continued collaborative efforts between FAA and industry toward the development and implementation of safety management systems.

Sincerely yours,

Todd Sigler Walter Desrosier Asst. Vice President, Civil Aviation Vice President, Engineering & Maintenance Aerospace Industries Association General Aviation Manufacturers Association (AIA) (GAMA)

Copy:

Peggy Gilligan Associate Administrator for Regulation & Certification

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591

Tony Fazio Director, Accident Investigation and Prevention

Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591