Donald DeGraw

Please find listed below specific comments regarding proposed rule by the FAA for "Safety Management System for Certified Airports". The purpose of the comments listed below is to give real world input to the NPRM process. 1. Summary Section page 1, Recommend the requirement to apply to only Class I airport - This would target the majority of Air carrier passengers in the US and allow small airports to avoid costly and burdensome regulations. Class II,III and IV airports could have a SMS program be a recommended resource. 2. Summary Section page 1, Recommend the requirement be applied to only FAR part 139 airport areas, general aviation ramps, taxiways and other areas not included in FAR part 139 air carrier use should be exempt. 3. Flexibility Section page 10, Recommend the FAA develop the basic components, language, and specific details of the plan and not just"only the general frame work". Sections can be then expanded and revised to include specific airport details, but the general plan should be the same for all airports and the FAA should do 95% of the work for the airports to maintain consistent safety and standards from region to region. Draft SMS plans to the airports should be a fill in the blank plan and a plan that has the most common hazards, risks and mitigation measures for airports already identified, airports can then add hazards if needed or make minor adjustments. 4. Safety Promotion page 20, positive safety culture should be established by FAA specific guidance and then adjusted as needed by the airport with fill in the blank section or the; senior management statement, establishment of internal policies and allocation of resources. 5. Implementation process page 21, Development for the implementation plan should be lengthened from 6 months to 12 month for Class I airports and from 9 months to 18 months for Class II, III and IV airports with the process also being moved upward from 18 to 24 months for a Class I, and 24 to 36 for the Rmdrs