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EAA Weighs In on Two FAA Proposals


September 12, 2012 - This week EAA submitted comments to the FAA regarding two important FAA policy change proposals by the FAA for GA airports: "Residential Through-the-Fence (RTTF) Access at General Aviation Airports" and "Draft FAA Advisory Circular (AC) 150/5200-37A, Safety Management Systems (SMS) for Airports."

RTTF Access at General Aviation Airports: During three years of discussions with the FAA Airports Division, EAA fought for the rights of residential property owners adjacent to their GA airport to gain direct access to their airport for flight purposes. As a result of those joint efforts by EAA, the Independence Airpark Homeowners Association (Independence, Oregon), the Oregon Department of Aviation, ThroughTheFence.org, and Congress, the FAA issued a draft policy change to the Airport Compliance Manual (FAA Order 5190.6B), granting RTTF access.

"In our comments we clearly state appreciation for the FAA clarifying and re-establishing three fundamental rights that all aircraft and homeowners should have including those who operate as an RTTF homeowner," said Randy Hansen, EAA government relations director. "The FAA clarified that all aircraft owners have the right to self-maintain/refuel their own aircraft, conduct non-aeronautical commercial businesses out of their homes, and be able to tie a standard 30-year home loan into their airport RTTF access agreement."

In compliance with the FAA Modernization and Reform Act of 2012, all costs associated with creating a RTTF access point on a GA airport should be borne solely by the RTTF homeowner. EAA, however, strongly disagreed with this requirement if the homeowner is forced to change an access point due to a change in the airport's master plan or as directed by the Transportation Security Administration (TSA). In these situations, all direct and indirect costs associated with that change should be borne by the airport and the FAA through the airport improvement program (AIP).

The FAA is accepting comments until Friday, September 14, 2012, so if you wish to submit comments on this FAA policy change do so immediately.

Draft AC 150/5200-37A, Safety Management Systems (SMS) for Airports: EAA agrees with the FAA that SMS safety programs are the wave of the future to develop operating practices and procedures to improve the all aspects of safety on civil public-use airports.

"There are more than 5,000 public-use airports in the U.S. ranging from the large commercial hub and spoke systems used by airliners to small sod strips maintained by volunteers," said Tom Charpentier, EAA government advocacy specialist. "Because of this vast diversity in airport size and operational complexity it is impossible to have a single airport SMS policy that fits all, yet that is what the FAA is proposing.

"EAA is strongly encouraging the FAA to modify its SMS AC guidance to incorporate an active and viable process of scalability in their airport policies and procedures."

To accomplish the recommended (and highly desired) SMS scalability, EAA requested the FAA change the AC's applicability statement in Section 2 to clearly identify Part 139 (commercial airports) as the focus of this specific airport guidance. The EAA-recommended wording change reads, "This AC establishes guidelines for SMS implementation for and by airport operators at airports certificated under title 14 Code of Federal Regulations (CFR) part 139, Certification of Airports."


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