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July 15, 2011
By Dan Namowitz
AOPA is urging the FAA to recognize differences in operations and resources between large hub airports and general aviation airports before moving to require safety management systems (SMS) at the GA facilities.
Commenting on a proposed FAA rule that would broaden application of SMS policy to non-movement areas at 562 large airports, AOPA pointed out that GA airports may lack the means to adopt the new SMS requirements that larger airports have been required to follow since last month. It was unclear what steps a GA airport would have to take to implement an SMS in non-movement areas, or how to comply with training requirements.
AOPA recommended that the FAA conduct additional study of the challenges GA airports would face when implementing an SMS. Then the FAA should take a phased approach to the education and preparation processes.
AOPA submitted its comments in response to an Oct. 7, 2010, notice of proposed rulemaking (NPRM) to require Part 139 certificated airports to establish a SMS program for their “entire airfield environment” as part of their certification process.
Although the proposal only applies to the certificated airports, past FAA guidance put forth an intent to apply the programs to other airports in the National Plan of Integrated Airport Systems later, wrote John Collins, AOPA manager of airport policy.
“AOPA recommends that such additional implementation take place only after a long phase-in period, prior to which a detailed evaluation of the development and implementation process has been undertaken for the SMS programs that includes significant input from all stakeholders,” he wrote in AOPA’s July 5 response to the NPRM. “We suggest that the lessons learned will help smaller airports understand how to better implement and use this program, and help the FAA understand to what extent each part of the program should be implemented at these airports, if at all.”
AOPA’s comments noted questions that the proposed extension of SMS policy would raise for GA airports—such as the expected broadening of SMS training requirements to any individuals beyond airport staff who accessed movement and non-movement areas.
“We are uncertain how that would be implemented so that training received at one airport would suffice for a requirement for SMS training at another airport. Is the FAA considering a generic training course, would there be a logbook endorsement or other recordkeeping requirement? Is the training something that could be done at the individual’s convenience such as Web-based training or will it require attendance at a classroom? Is this a one-time requirement or will it require recurrent training?” he wrote.
AOPA also recommended that the FAA delay for 12 months a proposed requirement that would apply to some GA airports to prepare safety risk assessments (SRAs) in connection with Airport Improvement Projects. The association recommended that the FAA initiate an educational process to help the airports conduct the assessments.
If the FAA then determined that requiring SRA’s at GA airports was necessary, it should take a phased approach, “including extensive marketing and promotion of the FAA’s educational efforts at regional and state airport conferences,” Collins wrote.
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AOPA thanks our members for their continued support in protecting the freedom to fly.