NBAA Welcomes Comment Period Extension on FAA’s Proposed SMS Rule

Contact: Dan Hubbard, 202-783-9360,

Washington, DC, Jan. 26, 2023 – The National Business Aviation Association (NBAA) welcomed this week’s decision by the Federal Aviation Administration (FAA) to extend the public comment period on a notice of proposed rulemaking (NPRM) that would require many business aviation operations to implement safety management systems, or SMS.

Issued earlier this month, the NPRM would update and expand 14 CFR Part 5 SMS requirements beyond Part 121 commercial airlines to certain Part 21 certificate holders, Part 135 air charter operations and companies holding a letter of authorization to conduct air tour operations under Part 91.147.

The FAA previously set a March 13 deadline for comments. The extension to April 12 grants the industry valuable additional time to review the proposed rule and fully assess its implications for business aviation, noted Doug Carr, NBAA’s senior vice president of safety, security, sustainability and international operations.

“We thank the FAA for granting our request for this extension as NBAA and other stakeholders continue to review the NPRM,” Carr said. “However, we must ensure that any rulemaking permits scalability to the specific size and needs of every affected flight operation.”

In his request for an extension, Carr noted that the FAA had sought information from certain single-pilot Part 135 operators that may lack the resources necessary to implement a full-scale SMS.

“While we remain strongly supportive of SMS as an effective solution to help improve flight safety, we must also ensure that any rulemaking is rolled out responsibly and in full consideration of the varied nature of many business aviation operations,” he added.

SMS is an important tool that can help operators proactively identify potential hazards and establish processes to effectively manage those risks. The FAA has required U.S. airlines to implement SMS since 2018, with Congress calling on the agency in 2020 to extend those requirements to other commercial aviation operations.

In responding to Carr’s request, the FAA noted that other industry stakeholders had also requested comment period extensions of up to 90 days, but the agency believes an additional 30 days provides sufficient time for commentors to weigh in on the proposal.

Review the FAA NPRM.


Founded in 1947 and based in Washington, DC, the National Business Aviation Association (NBAA) is the leading organization for companies that rely on general aviation aircraft to help make their businesses more efficient, productive and successful. The association represents more than 10,000 company and professional members and provides more than 100 products and services to the business aviation community, including the NBAA Business Aviation Convention & Exhibition (NBAA-BACE), the world’s largest civil aviation trade show. Learn more about NBAA at

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