December 12, 2012
VIA Electronic Mail 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: Airports Council International—North America (A CI-NA) 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. ACI-NA represents local, regional and state governing bodies that own and operate commercial airports in the United States and Canada. As you may know, ACI-NA’s over 300 member airports enplane more than 95 percent of the domestic and virtually all of the international airline passenger and cargo traffic in North America. Nearly 400 aviation-related businesses are also members of ACI-NA, providing goods and services to airports. The Notice will impose significant new requirements on non-certificated airports in the NAS who seek to use Airport Improvement Program funding fo r projects at their airports. ACI-NA and our member airports are working to understand the imp lications of the Notice and offer constructive comments to the FAA regarding it to better ac hieve our mutual goal of meaningfully enhancing the safety of the nation's air transportation system. In accordance with this goal, we and our member airports believe that an extension in the comment period is necessary for the following reasons: 1. Time is needed for ACI-NA to evaluate both the safety risk reduction benefits and costs associated with the proposed changes. Such evaluations are needed to inform our comments regarding the Notice as well as to better understand the Notice’s potential effects on AIP and airport financial resources. To assist us in this evaluation, we also respectfully request that the FAA provide any safety risk assessments or regulatory

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impact evaluations it has conducted regarding the Notice. It is our understanding that the FAA should have performed a safety risk management review of the proposed Notice (either via safety assessment screening or safety risk management panel) in accordance with it’s the Office of Airport’s safety management system policy (i.e., FAA Order 5200.11). 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

. 3. The comment period—which extends from December 10, 2012, to January 9, 2013— occurs during a time period that is extremely busy for airports—which have a key role in commenting on the Notice. ACI-NA appreciates the opportunity to comment on the Notice and we and our members look forward to providing the FAA with meaningful comments regarding it. To facilitate needed industry participation in the rulemaking process, we respectfully request that FAA grant the thirty-day extension of the comment period. Thank you for your time and consideration of this extension request.

Sincerely,

Christopher Oswald Vice President, Safety & Regulatory Affairs