December 12, 2012

Mr. Michael O’Donnell

Director, Office of Airport Safety and Standards

Room 621

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

mike.o’donnell@faa.gov

RE: Request for Extension of Comment Period for Clarification of Wildlife Hazard 

Management Requirements for Non-Certificated Federally Obligated Airports in the 

National Plan of Integrated Airport Systems (NPIAS), Docket No. FAA-2012-1306

Dear Mr. O’Donnell:

The American Association of Airport Executives (AAAE) respectfully requests a thirty-day 

extension of the comment period for the Notice 2012-29591, Clarification of Wildlife Hazard 

Management Requirements for Non-Certificated Federally Obligated Airports in the National 

Plan of Integrated Airport Systems (NPIAS) (the Notice), which was published in the Federal 

Register on December 10, 2012.

Founded in 1928, AAAE is the world's largest professional organization for airport executives, 

representing thousands of airport management personnel at public-use commercial and general 

aviation airports. AAAE’s nearly 5,000 individual members include some 3,000 airport 

professionals representing nearly 850 different airports, from large hubs to general aviation 

facilities. Our members, in particular our general aviation airport members, who accept Airport 

Improve funding, will face new significant requirements under the proposed notice.

AAAE and our member airports are reviewing the Notice to understand the implications. We 

share the FAA’s mission and commitment to aviation safety and feel it is important that we take 

time to prepare thoughtful and construction comments. We believe that an extension in the 

comment period is necessary for the following reasons:

(1) Time is needed for industry to evaluate both the safety risk reduction benefits and costs 

associated with the proposed changes. We note that this information does not appear in 

within the Notice and respectfully request that the FAA provide such information, which 

should have been developed in accordance with the FAA’s internal airport safety 

management system policies (i.e., FAA Order 5200.11).
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(2) The Notice needs to be reviewed in conjunction with other key guidance documents, 

particularly just-released draft FAA Advisory Circular 150/5200-33C, Hazardous 

Wildlife Attractants Near Airports which comment period closes January 31, 2013.

(3) The comment period—which extends from December 10, 2012, to January 9, 2013—

occurs during a time period that is extremely busy for the airports who will have a key 

role in reviewing the notice.

AAAE appreciates the opportunity to comment on the Notice and looks forward to providing the 

FAA with meaningful comments regarding it on behalf of our members. We also appreciate the 

collaborative relationship with have with the FAA on important matters of safety and to 

maximize needed industry participation on this important matter, we respectfully request that 

FAA grant the thirty-day extension of the comment period.

Thank you for your time and consideration of this request.

Sincerely,

Melissa Sabatine

Vice President, Regulatory Affairs

AAAE