Safety Management Systems at Airports Continued from page 39 associated with implementation are estimated at $238.9 million. These estimates do not include the cost of mitigations that may be required as part of the implementation process. Airports covered by the proposed legislation would have up to two years to implement an SMS after the effective date of the final rule, reflecting the need for additional time that many commenters to the NPRM identified as necessary to meet the requirements of the rule. Notably, the SNPRM does not require tenants of an airport to have a separate SMS. However, from a practical perspective, airport manag- ers must ensure that the airport SMS applies to any safety issues includ- ing employee safety, ground safety, vehicle safety, and passenger safety to the extent that they are related to air- craft operations. At a functional level, this requires that airports work in concert with tenants to ensure either that the tenant is working within its own SMS or is included in the airport SMS as a stakeholder and participant. The SNPRM provides some flexibility to airports in how general aviation operations are treated as well, allow- ing the certificate holder to scale their implementation to meet the unique operational needs of each airport. While the timing of the final rule may vary, we can be assured that regulated SMS for airports is a near- term reality. Though new regulations always produce some growing pains as the industry adjusts, this step by the FAA will be a good one for the airport industry, as it provides a systematic method for: improving communication, reducing opera- tional costs, improving operational 40 processes, prioritizing safety needs, and better utilizing resources. Still, there are obstacles to address to conform to the proposed regulation. Airport Challenges Airports certainly have their share of hurdles to overcome on the way to successful SMS implementa- tion and maturation. Diverse city, county, state, and airport author- ity management structures are only one issue that airports face that is unique in comparison with other types of aviation operators. The variations in airport governance and management structures can make efficient communication difficult to plan for, let alone execute. Likewise, determining the proper placement of safety personnel within that structure, and ensuring appropri- ate reporting channels are in place may require some experimentation. Consistent growth, projected to result in passenger enplanements increasing by roughly five percent per year, is another factor that airports must consider. Coupled with the fact that many airports face extreme geographic and layout constraints, growth has the capacity for exacer- bating a number of existing issues. Stakeholder diversity can also create challenges, especially in risk management, where a variety of user groups, both internal and external, may view the components of risk very differently. These disparate perspec- tives mean that local expertise—not just at the airport, but within in- dividual work units—is critical to ensuring risk is evaluated in context, and that mitigations are considered with the full breadth of downstream effects they may create. Creating training solutions that are scaled appropriately to the airport and to differing operations groups was identified as a key challenge during the FAA SMS 31-airport pilot project. Because the line airports often walk between governmental im- munity and exposures to ordinary tort law, safety management efforts can raise concerns about the liability associated with safety risk manage- ment practices. As underscored by Aviation Business Journal | 1st Quarter 2017
