A culture of aviation safety has broad industry support. But requiring general aviation airports to implement safety management systems (SMS) based on programs at commercial-service airports would impose crippling burdens on the smaller facilities, AOPA said in a regulatory filing.
With their limited staff, general aviation airports also could face heightened liability exposure under a draft revision of an FAA advisory circular on safety management systems for airports, AOPA said in formal comments that registered the association’s “significant concerns” about the redrawn advisory circular AC 150/5200-37A.
“The provisions of the AC seem to impose a cumbersome, expensive administrative burden on all but the largest airports,” wrote John Collins, AOPA manager of airport policy, in comments submitted Aug. 31. “We are especially concerned with the impacts on small general aviation airports as well as the smaller Part 139 airports, many of which will not have the staff and resources to implement SMS as intended by the FAA.”
Collins cited numerous management burdens for small airports with modest project budgets such as added compliance bureaucracy, delayed programs, and a thorny “documented risk” provision that could make airports a target for litigation. He urged the FAA to develop an advisory circular specifically addressing the needs—and management scale—of those airports.
Applying the SMS mandate to smaller airports should only be considered after the FAA has gained “substantial” expertise with SMS operations at commercial airports, as determined by a minimum of five years’ experience, Collins wrote.
The FAA has proposed that its AC revision apply “to all civil airports, when adapted to the size, activity level, staff level, and resources of each facility.”
As an alternative, AOPA recommended that the FAA implement a “robust training system curriculum for airport managers and FAA personnel tasked with overseeing the SMS program,” and then revisit the issue after the five years of evaluation.