Sat, Feb 28, 2009
The Battle May Just Be Beginning
National Business Aviation
Association (NBAA) President and CEO Ed Bolen submitted comments
Friday that clearly articulate the serious concerns raised by the
Transportation Security Administration's highly
controversial Large Aircraft Security Program (LASP).
NBAA's comments were submitted to the federal government's public
docket on the final day for public comment on the LASP.
"As NBAA has noted since the LASP was introduced last October,
this proposal completely misses the mark," said Bolen. "The TSA
needs to understand that in preparing the LASP, the agency has
attempted to overlay a security regime for the big airlines onto
tens of thousands of businesses all across the country. If left
unchanged, the plan would overwhelm these small businesses in a
time of economic crisis without providing a clear security
benefit."
NBAA's comments added to those submitted by more than 4,000
businesses, associations and individuals, all of which raise a
variety of criticisms about the TSA's proposal. NBAA's 30-page
document details the myriad ways the proposal would harm the GA
industry. The main concerns include:
- The 12,500-lb.Weight Threshold: NBAA's
comments note that the TSA has chosen a weight threshold for its
proposal without providing a data-driven, risk-based analysis. "A
12,500-pound airplane could fit nose to tail across the inside of
an airliner, which averages about 300,000 pounds" Bolen said. "The
TSA's ‘Large Aircraft Security Program' would apply to some
very small aircraft."
- The Prohibited Items List: The proposal
contains a list of more than 80 "prohibited items." "Unfortunately,
many of these items are routinely carried aboard business aircraft
– everyday tools, for example – because they are
central to NBAA Members' business needs or are products produced by
the company," Bolen said. NBAA's comments recommend that the TSA
establish procedures to control access to "restricted item(s)"
while on board the aircraft.
- Third-Party Watch List Service Providers and
Auditors: Security experts have long understood that
outsourced security programs can produce more risks than benefits,
and that the most effective approach to security is through a
closed system. The TSA's call for third-party security auditors
overlooks such findings. "Private aircraft operate within a very
secure system today, many involving sophisticated processes," Bolen
said. NBAA's comments oppose use of third-party watch list service
providers.
- Federal Air Marshals: NBAA is deeply concerned
with the TSA's proposal to require some aircraft to carry a federal
air marshal (FAM) on board. "These aircraft are privately owned and
operated by businesses," Bolen said. NBAA's comments maintain that
the TSA has no authority to mandate the transport of law
enforcement officers in any private vehicle.
NBAA's comments also renew the Association's call, first made
last January, for a rulemaking committee that would allow for a
productive dialogue to take place between government and industry
stakeholders on the development of reasonable security
policies.
"The business aviation community has
a long and demonstrated history of partnership with government in
developing effective yet workable security measures for the
industry," Bolen said. "A rulemaking committee would provide a
forum for stakeholder information sharing and the development of
sensible and implementable measures."
Bolen also thanked NBAA Members for making their voices heard on
the LASP. "The business aviation community has truly done an
outstanding job of getting our message to the TSA about our
concerns with the agency's plan," Bolen said. "Through the comments
submitted to the public docket, the messages sent through Contact
Congress, the participation in the TSA hearings and other measures,
our industry acted when called upon and sounded a forceful,
nationwide alarm about our grave concerns about the proposal. There
is still much work to be done, and we will continue to count on our
Members' support. But we appreciate their continuing dedication to
this issue, and to sensible security policies."
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