Airport SMS, a revision of AC
150/5200-37 will be published
in conjunction with the SNPRM
and comments will be collected
concurrently with the SNPRM.
Want to get Involved?
AAAE’s Operations Subcommittee
SMS Work Group is preparing to
review and provide comments to the
SNPRM. The work group is led by
Joanne Landry, Landry Consultants,
and Scott Ayers, Hartsfield-Jackson
Atlanta International, and includes
56 members. The work group
is composed of various airport
and industry safety and SMS
experts who provide AAAE with
a knowledgeable and informed
resource to support regulatory
changes, standards and best
practices. The work group will
provide a forum to review and
compile comments for the upcoming
SMS regulatory requirements
predicted for early 2016. If you
are interested in being part of the
work group and the review process,
ACI-NA is seeking airport and
associate members to assist in
reviewing the SNPRM document
as ACI-NA prepares to submit
comments by the close of the 60-day
comment period. Participation
will include a series of three to
four conference calls, as well as a
possible onsite meeting at ACI-NA’s
Washington, D.C., office. If you are
interested in participating, contact
ACI-NA’s Chris Oswald at coswald@
aci-na.org or Paul Eubanks at
Joanne Landry is principal of Landry
Consultants LLC. She may be reached at
Ken Ibold is an aviation planner and national
SMS discipline leader for RS&H, Inc. He may
be reached at Ken.Ibold@rsandh.com.
How to Prepare for and
Deliver Rulemaking Comments
When the SMS SNPRM is published in the Federal Register, a link to the docket, where comments and documents reside, will be included in the “Addresses” section of the publication. The docket is located on
the www.regulations.gov website. All documents are posted to the docket as
received, including submitter’s information. Paper copies are scanned and
included to the docket as they are received.
DOT provides suggestions for effective comments on its website at www.
transportation.gov/regulations/rulemaking-process#prepare. Some key points
to consider when providing comments include:
1 Refrain from handwritten comments at the risk of potential
2 Submit comments electronically.
3 Always include the docket number, the RIN (Regulation Identification
Number), the title of the rulemaking, or the Federal Register date and the
page number to ensure your comments are routed to the correct docket.
4 Organize comments under specific headings or by specific sections in
the rulemaking proposal to help the public and the agency review the
comments more easily and effectively.
5 Explain views and reasoning as clearly as possible, provide the basis for
your assumptions, and provide empirical evidence or test data, wherever
possible, to support your views.
6 Provide specific alternatives to the proposed rule, including rule text.
7 Provide specific examples to illustrate your concerns.
8 Consider requirements and limitations of the statutory authority under
which the agency is making its proposal.
9 Contact designated experts directly, not through the docket. The
Federal Register provides contact information for questions regarding
technical or legal questions. Do not pose questions on the docket.
10 Comply with the deadline for submission of comments to ensure
comments are included in the review. Deadline dates are provided
in the Federal Register.