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President's Perspective – NBAA Leading Response to TSA’s New Security Proposal
NBAA Members know that business aviation takes a back seat to no one when it comes to security. In the years since the terrorist attacks of Sept. 11, 2001, we have consistently demonstrated our commitment to work with federal government officials on ways to harden our industry from terrorist threats.
For example, we worked to establish an experimental secureaccess program in the New York area, known as the Transportation Security Administration (TSA) Access Certificate, by helping to develop general aviation (GA) airport security guidelines, and by participating in vulnerability studies.
We have also worked with other GA associations to require pilots to carry a government issued photo ID. We’ve helped the Treasury Department develop methods to identify suspicious financing transactions. And, we’ve helped foster participation in the post-9/11 Airport Watch program.
In short, security is an area where NBAA and the rest of the general aviation community have led, not merely followed, the regulators.
Given all we have done to promote security, our frustration with a new proposal for Part 91 operations, recently made public by the TSA, is understandable.
The TSA’s proposal, known as the Large Aircraft Security Program (LASP), doesn’t appear to reflect even a basic understanding of the non-commercial nature of Part 91 operations. It also fails to recognize the effective security measures we have already adopted. Instead, what has emerged from the TSA looks like nothing more than a regulation for commercial operations cut and pasted onto Part 91 operations.
For example, the proposal contains a list of more than 80 “prohibited items,” some of which may be routinely carried aboard business aircraft (everyday tools, for example), because they are central to NBAA Members’ business needs. Also included is language regarding the carriage of law enforcement officers, even though it is hard to imagine why a non-commercial operator would ever be required to transport a law enforcement officer.
These provisions, and a number of others included in the proposal, appear to carry onerous restrictions on mobility and significant additional cost and administrative burdens – without demonstrably enhancing security. To NBAA and its Members, this approach doesn’t make sense.
“We are convinced there are ways to maintain the vital balance between enhancing aviation security and preserving the mobility and flexibility that are at the foundation of business aviation. ”
For the business aviation community, any new mandates must simultaneously promote security and mobility. Our guiding principle is that proposals must be prudent, effective and workable. We will not support any proposal if it’s not done right.
NBAA has carefully scrutinized the TSA’s 260-page plan, and the Association is listening to the concerns raised by the Membership. (Read the related news article on the LASP in this edition of Business Aviation Insider).
In a joint letter sent with the Aircraft Owners and Pilots Association, NBAA asked the TSA for an extension to the 60-day comment period on the proposal. The TSA granted the extension, giving the industry until February of next year to provide comment. Based on our analysis and input from our Members, we will be filing substantial comments on the proposal.
We’re also making sure NBAA Members have the resources they need to make their voices heard on the issue. Members can directly comment to the government’s public docket right from a designated NBAA web site, www.nbaa.org/lasp. And, in this issue of Business Aviation Insider, you’ll find Internet links to tools you can use to assess its impact on your operation.
We are convinced there are ways to maintain the vital balance between enhancing aviation security and preserving the mobility and flexibility that are at the foundation of business aviation. It’s an approach we will continue to promote – and we will also need you to make your voice heard on this critical issue.