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 (ACI-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 for projects at their airports. ACI-NA and our 

member airports are working to understand the implications of the Notice and offer constructive 

comments to the FAA regarding it to better achieve 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 
 2 

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