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NBAA Provides Comments on FAA’s Proposed Airport SMS Requirements

Sept. 16, 2016

NBAA supports the adoption of safety management systems (SMS) at larger commercial airports, but recently expressed concern that the FAA’s proposed airport SMS rule would require SMS programs at smaller airports with no international scheduled airline service.

NBAA Provides Comments on FAA's Proposed Airport SMS Requirements

The FAA began developing the SMS for Airports rule in 2006, to harmonize U.S. airport regulations with International Civil Aviation Organization standards, and the industry has been awaiting this rule since 2010.

In July 2016, the FAA released a supplemental notice of proposed rulemaking mandating SMS for several types of airports, including small, medium and large hubs and airports with more than 100,000 annual operations. It also proposes SMS programs at airports identified by Customs and Border Protection (CBP) as ports of entry, landing-rights airports or user-fee airports.

In comments on the draft rule, NBAA stated that airports with no international scheduled airline service should be excluded from SMS requirements, even if there is a CBP presence for general aviation (GA) flights.

“ NBAA recognizes and promotes the value of SMS among its operating members and believes in the importance of growing the safety culture at airports covered by FAA’s proposal,” said Alex Gertsen, NBAA’s director of airports and ground infrastructure. “ While safety is paramount, NBAA is concerned the FAA’s proposed criteria for applicability of SMS could present a significant challenge to some of the smaller airports that have CBP presence, but no international scheduled airline service. The requirement could also serve as a barrier to airports that desire to establish CBP services in the future.”

NBAA’s comments note that the ability of GA aircraft to travel internationally without an intermediate stop to clear customs is not only efficient, it reduces risk and environmental impact. Review NBAA’s full comments on the rule. (PDF)

Since the SNPRM also covers the non-movement areas of an airport, such as GA aprons and leaseholds, NBAA also cited the International Standard for Business Aircraft Handlers (IS-BAH) as a set of global industry best practices for ground handlers, with SMS at its core. If endorsed for use at GA ramps, IS-BAH could boost the overall airport SMS programs.

In addition, NBAA asked the FAA to clarify that the criteria requiring an SMS would cover only Part 139 airports. The FAA in 2010 proposed that all 544 Part 139 airports at the time participate in SMS, and the industry expressed concern with the proposal’s scope. The revised proposal, as written, covers 268 airports. There are approximately 70 airports with CBP presence but no other criteria, which would be required to implement an SMS under the SNPRM.

The FAA is also soliciting comments on a draft advisory circular (AC) that will accompany its final rule. Members who wish to provide comments on the AC and share how airport SMS requirements may impact them can email Alex Gertsen at agertsen@nbaa.org.