Comment from Thibaut Giret
Thibaut GiretSupportIndividual
Summary: Thibaut Giret, a legal practitioner in the airport infrastructure industry, argues that the draft order creates compliance uncertainty for design-build projects due to structural conflicts with Buy American requirements and lacks clear definitions for "unique complexities." He proposes amending the order to include a staged certification mechanism and a non-exhaustive list of factors to better accommodate airport technology and systems programs.
I am respectfully submitting the attached comment on Draft FAA Order 5100.38E_Airport Improvement Program (AIP). As a legal practitioner in the airport infrastructure industry, I recommend two amendments to section 3-4.2.7:
(1) Consider a staged certification mechanism for Buy American compliance; and
(2) Establish set criteria for projects qualification as uniquely complex.
The suggested amendments are comprised in the attached document.
Your consideration is greatly appreciated and I welcome any opportunity to discuss further.
Thibaut Giret, Esq.