Centerlines - October 2011 - (Page 17)

POLICY CORNER Regulations and the Need For A More Difficult Conversation comments on FAA’s proposed Safety Management System, where the analytical, procedural and technical problems with the proposal were so serious that no other alternative made sense. EPA’s Effluent Limitation Guidelines and New Source Performance Standards for the Airport Deicing Category proposal is another instance where airports are not opposing reasonable regulations, in this case rules for establishing technology-based standards for controlling discharges from deicing operations. The problem is the “one size fits all” approach EPA suggested, which does not take account for the fact that airports and airlines have not only reduced the amount of deicing fluid used, but also the toxicity of that fluid. In September, I joined Roy Furman, Chair of ACI-NA’s Environmental Affairs Committee; Katherine Preston ACI-NA’s Director of Environmental Affairs, and senior officials from the Air Transport Association at an EPA meeting to make these points, given that a fi nal rule may be issued later this fall. The group also emphasized that complex safety and operational issues were not adequately considered; concerns we understand that FAA also raised in interagency meetings. These arguments and the lack of a cost justification for the proposed rule were also emphasized during a recent meeting with the Office of Management and Budget. Money, or more precisely the lack thereof, brings up the need to have a more difficult conversation—one that asks the following question: Given reduced airport funding for regulatory compliance, what can we afford to do? This not only affects airports but also the regulatory agencies. Given the pressure to cut federal spending and reduce the deficit, it is a certainty that FAA and EPA will have less, perhaps TSA as well. The FAA’s action in June to limit mandatory application of its “internal” SMS order to projects at large hub airports only demonstrates that these are not just idle considerations. Determining how airports and our regulators can restructure and reprioritize existing and proposed regulations to reflect funding, staffi ng, and other resource constraints will remain a top priority for ACI-NA in the coming year. In doing so we believe that we can actually achieve better safety, security, and environmental outcomes by concentrating our attention on areas where regulation is appropriate and eliminating it where it isn’t. DEBBY MCELROY EXECUTIVE VICE PRESIDENT, POLICY AND EXTERNAL AFFAIRS ACI-NA AC I - N A H A S TA K E N some tough stands over proposed rules and regulations that we believe will have significant operational and fi nancial consequences for airport operators. From safety management systems to TSA security directives to EPA effluent limitation guidelines, we have made clear that proposed requirements need to be rational, implementable, and result in clear benefits that justify their implementation costs. Many people don’t realize that the importance of industry comments in rulemaking processes was recognized more than 60 years ago, with the passage of the Administrative Procedures Act in 1947. This law established and defi ned the procedures for the “Notice of Proposed Rulemaking.” In almost 30 years of working in aviation I can’t remember a proposed rule that did not benefit from comments from those who would be affected by it. ACI-NA takes our role as the “airport industry watchdog” seriously and continuously seeks to provide informed and constructive comments regarding proposed federal regulations and legislation that affect you, our members. Unfortunately, in some cases the proposed rules are so fatally flawed that there is no alternative but to suggest that they be withdrawn. That was the case with our comprehensive | CENTERLINES 17

Table of Contents for the Digital Edition of Centerlines - October 2011

Welcome Message
President’s Message
Canadian Airports
Associates’ Corner
Policy Corner
On the Hill and On the Stump
The 2011 William E. Downes Jr. Award
Host Airport
Cover Story: Money, Service and Regulations are Top Concerns at Small Airports
Feature: Celebrating 20 Years of Annual Conferences
Feature: The Heart of the City—Aerotropolis Concept Positions Airports as City Cores
Security: TSA Reauthorization
Passenger Focus: Wings for Autism
On Management: Health and Happiness—Wellness Programs Benefit Employee and Employer
Grand Openings
Now Underway
New Members
Conference Sponsors
Conference Exhibitors
Index of Advertisers/
Box Scores

Centerlines - October 2011