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TSA Airport Badging Program: Security Directive 1542-04-08G
May 29, 2009
On May 28, 2009, the Transportation Security Administration (TSA) issued Security Directive (SD) 1542-04-08G, which modifies security protocols for transient aircraft and after-hours operations at commercial-service airports. This newest revision of the security directive – "Version G" – clarifies the TSA's initial security directive, SD 1542-04-08F, and addresses some of the immediate, top-level concerns raised by NBAA and other general aviation groups about how the TSA's "badging" program would be implemented and what impact it might have on security and safety.
Note: Due to the sensitive nature of the information included in the directive, the TSA has not made the full content of the document widely available.
TSA has provided additional clarification on the impact of the SD to general aviation operations:
As previously discussed, the purpose of the SD is to require background checks and identification for All PERSONS with UNESCORTED ACCESS to the SIDA and AOA at Commercial Airports. The affect of these badging SD's on General Aviation pilots will depend upon where they are operating:
- For HOME-BASED PILOTS, the badging requirements will apply if you have leased space or are part of a tenant program unless alternate measures have been approved by the airport operator. An example of an alternative measure would be an escort program.
- For TRANSIENT PILOTS, they will not be required to have airport badges or background checks from any of the NON Home-Based airports they visit. Transient pilots are advised to remain in the footprint of their aircraft and to and from fixed-based operator, service provider or airport exit. Special allowance will be given to transient pilot operators in the AOA who are fueling or in emergency status.
For additional information, listen to the NBAA Flight Plan Podcast: Industry Advocacy on TSA’s ‘Badging’ Security Plan.
On May 19, 2009, NBAA President and CEO Ed Bolen and leaders of other trade associations representing GA sent a letter to Department of Homeland Security Secretary Janet Napolitano explaining the negative impact that the Security Directive would have on GA operations. The letter points out that GA operations are unscheduled and often occur when airport staff or tenants are unable to serve as escorts. To overcome this obstacle, operators would have to obtain badges for every air carrier airport they plan to visit. This administrative burden would obviously be overwhelming for operators.
Since the issuance of the Security Directive, NBAA has been working with TSA to provide input on how the changes would impact business aircraft operations. Although the security directive makes regulatory changes, it did not go through the normal federal rulemaking process which would have allowed comments from NBAA and its Members.
The letter requests that Secretary Napolitano withdraw the Security Directive and initiate the required rulemaking process that is needed to make a change of this scope. NBAA will keep Members informed regarding the implementation of this Security Directive.
On May 29, 2009, NBAA issued a statement in response to SD 1542-04-08G:
The Transportation Security Administration (TSA) has addressed some of the immediate, top-level concerns raised by NBAA and other general aviation groups about how the TSA's 'badging' program would be implemented and what impact it might have on security and safety. The Agency's willingness to address our most pressing concerns gives us optimism that, over time, TSA officials will remain ready to discuss additional, unforeseen and unexpected effects of the program so that it does not become an impediment to operations. As NBAA Members know, the Association has long believed that the overall 'badging' security requirement is overly broad and ill-suited to the unique operating needs of business aviation, so we will continue working with the Agency to address our ongoing concerns.