The “one size fits all” surface operations training requirements in an FAA proposal for Part 139 airports doesn’t account for the differing needs of a wide variety of airports, AOPA told the FAA April 4.
The FAA proposal would change the Part 139 certification standards for general aviation and air carrier airports, including a provision that would require driver education for vehicle operation on ramps and aprons and annual recurrent training. AOPA said that the proposal fails to take into consideration the unique characteristics and physical layout of individual airports, particularly those that have GA operations, and that the recurrent training would be onerous for smaller airports.
“The proposed mandatory recurrent training is in our opinion overly burdensome for a number of smaller airports whose personnel and budget resources are limited,” wrote AOPA Vice President of Airport Advocacy Bill Dunn. “Rather than requiring mandatory recurrent training, the airport sponsor should have the flexibility to implement training requirements as they believe necessary to maintain safety at the airport.”
Dunn said that initial training should be enough to familiarize airport personnel with nonmovement areas on an airport, and that recurrent training should only be required under special circumstances, such as if there is a change in airport infrastructure or if there has been a history of violations.
The proposal would affect GA airports that have a Part 139 certificate but do not handle airline operations, as well as Part 139 airports where GA facilities are located some distance from other critical areas of the airport. Dunn pointed out that “non-movement areas for airports that serve airline operations are far different than airports that only serve general aviation aircraft.”
The FAA said its proposal is intended to enhance safety at Part 139 certificated airports. In addition to the training requirements, it would require the airports to conduct pavement surface evaluations and surface movement guidance controls for low-visibility operations, and includes a clarification of an existing requirement against providing false statements in the certification application.