In case you haven’t heard, the comment period is ending soon (Feb 27, 2009) for a Notice of Proposed Rulemaking (NPRM) that has been issued by the TSA. This NPRM seeks to amend the current Twelve Five Standard Security Program (TFSSP) and Private Charter Standard Security Program (PCSSP) and apply new security requirements to all aircraft weighing more than 12,500 pounds. In short, the rules that apply to charter and airline customers for aircraft weighing more than 12,500 would now be applied to part 91 operators too! If you fly an aircraft weighing more than 12,500 lbs than this will adversely affect you! Even if you don’t fly that size of aircraft, you will still feel the negative financial implications that a program like this will have on all of general aviation.
These new security requirements include:
- Crewmember fingerprint-based criminal history records checks (CHRCs)
- Watch-list matching of passengers
- Compliance with the prohibited items list (PIL)
- Compliance with security directives and information circulars
- Designation of an aircraft operator security coordinator (AOSC), ground security coordinator (GSC), and in-flight security coordinator (ISC)
- Training for crewmembers and other identified personnel
- Development and maintenance of contingency plans to respond to threats
- Compliance with security audit program (twice a year)
These items, although they sound harmless enough, would impose a very large, very costly overhead for all private operators of aircraft weighing over 12,500 lbs. Imagine if you are a small flight department with a KingAir 350, do you think you could possibly afford either the time or money that will be required to comply with these kind of regulations and security requirements? I know my flight department couldn’t.
The one that really gets my goat is the compliance with the Prohibited List Items. The only reason that many companies even own a plane is so that they don’t have to comply with that rule! Many operators use aircraft to ferry mechanics and their specific tools that airlines prohibit on board. Hopefully your passengers or owners don’t enjoy the occasional hunting trip, because you can kiss those trips (and the guns) goodbye!
Why 12,500 pounds? Well according to the FAA definitions a “large” aircraft is anything over…you guessed it, 12,500 lbs.
The TSA is convinced that large private aircraft have the same national security threat as a fully loaded 747. If the TSA thinks that, that’s fine and I have no problem, but they need to prove that hypothesis by providing the studies and evidence that support it (which they haven’t done).
I highly highly encourage you to submit your comments before the comment period is closed. Many citizens are disenfranchised with their government because they think they have little or no say. Well, here is your chance to let your voice be heard! Submit your comments and then call your congressman and senators to tell them specifically why you think this NPRM would adversely affect your business or career.
I thank you in advance for your help in defeating or in greatly modifying this oppressive regulation.