February 11, 2010
AOPA ePublishing staff
The Transportation Security Administration’s (TSA’s) proposal to implement security procedures at FAA-certificated repair stations in the United States and abroad is not feasible, oversteps its bounds, and is redundant, according to AOPA.
The association filed comments Feb. 11 regarding the repair station security proposal, recommending that the rule be limited to foreign repair stations. Currently, the proposal would impact 4,227 repair stations in the United States, 3,000 of which are not located on an airport, and another 694 repair facilities abroad. These facilities would have to implement security procedures and infrastructure such as access controls to the facility or aircraft, means to identify those who should have access to the facility, procedures for challenging unauthorized people who are trying to get access, a security awareness training program, and more.
The proposal stems from a congressional mandate, the Vision 100—Century of Aviation Reauthorization Act, but AOPA maintains that the proposed rule goes beyond the intent of the legislation. The act is limited to oversight of foreign repair stations performing work on air carrier components.
In its comments, AOPA pointed out that general aviation repair stations should not be included in the proposal. And although the TSA did make a differentiation in repair stations, saying that those who service aircraft that weigh less than 12,500 pounds (maximum takeoff weight) would not need to meet the same security requirements as those working on larger aircraft, AOPA believes it should be based on operation (air carrier), not weight.
Because repair stations are not all located on airport property, the current proposal would be unrealistic to implement. Repair stations on and off airports are so different that it wouldn’t be possible to create a security plan and audit system to fit all of the stations.
The association also explained that the proposal contains many security procedures already required by Security Directive 1542-04-08G, which requires any person with unescorted access to an airport operations area to undergo a security threat assessment and gain an airport ID. The redundant procedures are unnecessary, AOPA said, reiterating is opposition to the way security directives have been used to skirt the public comment period associated with the regulatory process.
Those who wish to submit comments to the TSA regarding its repair station security proposal must do so before Feb. 18. Comments can be submitted online to docket number TSA-2004-17131.
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