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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, it stated “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.”
In addition, NBAA asked the FAA to clarify that the criteria requiring an SMS would cover only Part 139 airports. In 2010, the FAA proposed that all Part 139 airports (544, 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 NBAA wants owners and operators to know that the FAA is also soliciting comments on a draft advisory circular (AC) that will accompany its final rule. NBAA 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. KA
OCTOBER 2016
KING AIR MAGAZINE • 19