Since When Has That Stopped Bureaucracy?
While acknowledging the necessity
for the US government to secure its international borders, the
Experimental Aircraft Association strongly disagrees with the
Department of Homeland Security (DHS) plan to accomplish it with
regards to general aviation.
As ANN reported, in September
DHS proposed requiring operators of private aircraft entering or
exiting the US to submit via the Internet detailed information,
such as passenger manifests, at least one hour prior to crossing
the US border.
On Tuesday, EAA submitted comments to the DHS notice of proposed
rulemaking, Advance Information on Private Aircraft Arriving and
Departing the United States (Docket No. USCBP-2007-0064), citing
significant safety, operational, procedural and legal issues that
need addressing before the proposed program can be implemented.
EAA contends the reporting requirements in the Congressionally
mandated rulemaking proposal are impossible to satisfy. The
requirement for passenger manifests, in particular, strikes EAA as
"unworkable" -- as most foreign GA landing facilities lack the
necessary Internet, cellular, or international phone line
capabilities.
"Our major point is electronic submission is unworkable and we
really want a single point of contact for the pilot to be able to,
by way of FAA, deal with the requirements," said Doug Macnair, EAA
vice president of government relations. "Pilots should not have to
contact a separate government agency from a remote location in a
foreign country simply to try to get permission to come back to
their homeland. This needs to be part of the flight planning
process."
EAA also notes potential operational
conflicts between existing requirements and those proposed in the
NPRM will likely result in operational delays, significant
inconvenience, safety risks, and costs that have yet to be
addressed.
Furthermore, the apparent lack of flexibility in method of
communication, and the inability to modify routes in flight due to
weather or other issues, pose "a significant safety threat that can
neither be justified nor has been addressed in the proposal."
EAA also notes it fails to see why departure notifications and
manifests are required for international travel from the US
abroad.
"We feel that the procedures do not take into account the
operational environment of personal aircraft conducting
international flights," Macnair said. "This is particularly true
when these flights operate into and out of undeveloped or
underdeveloped airports and/or unimproved landing facilities in
foreign countries, as is very often the case.
"We’re urging the DHS, FAA, and the International Civil
Aviation Authority (ICAO) to work together to design a notification
and approval system that works seamlessly with existing
international flight planning and in-flight operational procedures
used by pilots operating to and from the US," Macnair added. "The
significant safety, operational, procedural and legal issues need
to be addressed before any such program can be implemented."
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