Experimental Aircraft Association (EAA)

EAA would liek to provide the following comment concerning this proposed NPRM (FAA-2010-0997). Within this NPRM the FAA states that they will develop Advisory Circulars (AC's) and other documents that will contain guidance for developing and implementing the SMS program at part 139 airports. EAA has two specific comments concerning this issue: 1. The final rule implementation date for this NPRM be set 90 days after publication of all FAA-related SMS guidance tools, including Advisory Circulars, and other such documents. 2. The FAA include in the preamble section of the final rule a complete list of all such FAA guidance materials, including form numbers, Advisory Circular numbers, and Order numbers. To do otherwise would be a clear sign that the FAA does not fully support the SMS program and its true administrative impact on the airports impacted by this new mandate. Randy Hansen EAA Government Relations Director