Disclosure of Safety Critical Information

On behalf of the General Aviation Manufacturers Association (GAMA), Aerospace Industries Association (AIA) and our respective member companies, we respectfully submit these consolidated industry comments to NPRM 24-10, Disclosure of Safety Critical Information [Docket No.: FAA-2024-0159] published in the Federal Register on January 25, 2024. GAMA and AIA members include nearly all the manufacturers of transport category airplanes and the engines, systems and articles installed thereon who are directly impacted by this proposed rulemaking on disclosure of safety critical information. Our member companies also include a significant number of applicants for TC/ATC and STC/ASTC directly impacted by the new requirement for application to be accompanied by a proposed certification plan. We appreciate the opportunity to review the proposed changes to 14CFR Part 21 and respectfully submit these consolidated industry comments in the following two attached documents: - GAMA-AIA General Comments Cover Letter - GAMA/AIA detailed section-by-section comments using the FAA Document Comment Log format in MS Excel

The Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) submit the attached comment letter which respectfully requests a 90-day extension to the comment period for FAA's notice of proposed rulemaking titled "NPRM 24-10, Disclosure of Safety Critical Information." As stated in the attached comment, this rulemaking proposes changes to the type certification process with very broad impact across all TC, ATC, STC and ASTC applicants, and with respect to all product categories of airplanes, rotorcraft, powered lift, engines, propellers, etc. which includes both large organizations and a massive number of small organizations. In addition, applicants and holders of part 25 transport airplane TCs/ATCs are discussing the proposed definition of safety critical information and a common understanding of practical approaches for showing compliance with the newly proposed requirements for this information.