Why ACI-NA Wants Changes to the FAA’s SMS Proposal

Last week, ACI-NA filed extensive comments on FAA’s proposed Airport Safety Management Systems. In our comments, we expressed a number of serious technical concerns about the proposal and have urged the FAA to withdraw the proposed rule at this time.

Do our comments imply that ACI-NA doesn’t think that SMS and airport safety are priorities?  Far from it!  As we noted in our comments, U.S. airports (as well as Canadian airports for that matter) have enviable safety records that are the result of years of collaborative work among airport operators, the FAA, the airlines, and other airport tenants and service providers.  Both the U.S. and Canada also have extremely strong airport design, construction, and operational standards; well-trained professional staff; and demonstrated commitments to safety as our top priority.

It is precisely because of our industry’s serious commitment to safety that we’ve asked the FAA to withdraw and reconsider its proposal.  We think that the proposal deserves the same level of serious and thoughtful consideration that it will demand from the airport operators implementing its provisions.

As noted in our comments, such consideration requires:

  • A serious and defensible regulatory analysis that actually considers the real risk reduction airport SMS will provide;
  • Consideration of real-world lessons learned about airport SMS implementation, both internationally and through the not-yet-completed FAA SMS airport implementation pilot study;
  • Working with airport stakeholders to revise airport SMS implementation guidance and advisory circulars that detail how the proposal would be implemented;
  • Understanding the real-world complexities associated with implementing numerous of the proposal’s provisions;
  • Honestly addressing resource constraints that will affect both the FAA’s and airports’ ability to implement SMS in addition to already rigorous minimum design standards;
  • Seeking legislative action at the federal and state levels to provide needed SMS data and liability protections; and
  • Working out the details regarding how airport SMSs will function effectively with the SMSs developed by the other FAA lines of business.

We are hopeful that the FAA will take our comments to heart and work with airports in developing a serious and practical airport SMS program.  We at ACI-NA stand ready to help.

Also, you can find a set of resource materials related to the proposal on ACI-NA's website.

Contact ACI-NA’s Chris Oswaldfor more information.