Experimental Aircraft Association

The Experimental Aircraft Association (EAA) agrees with the FAA that implementing a Safety Management System (SMS) at part 139 airports would create an additional and effective risk management tool at these airports. That said, the proposed SMS rule does not say how this program will be funded by airports. As a mandated ICAO and DOT (FAA) safety tool it is imperative that the 562 airports identified in this proposal be allowed to use Airport Improvement Program (AIP) funds for developing and implementing the SMS programs, and for developing and implementing the mandated SMS training programs. It is also critical that if the FAA decides, in the future, to impose SMS safety programs for all public-use recreational and general aviation airports (i.e., non-part 139 airports) that AIP funding is made available to these airports as well. Therefore, EAA requests that when this proposal becomes a final rule that the FAA clearly state that AIP funds are an approved source to pay for 100% of the expenses incurred in the development and implementation of the ICAO and DOT (FAA) mandated SMS program. This is the only effective way to ensure all 562 designated airports meet the 18-24 month SMS implementation deadlines. Randy Hansen EAA Government Relations Director