April 14, 2011
By Dan Namowitz
A government-wide review of the efficiency and cost of regulations provides an opportunity to reverse economic hardships for three Washington, D.C.-area airports, simplify security-awareness training for flight instructors, reduce Customs-related paperwork, and eliminate patchwork security rules, AOPA said in a letter to the Department of Homeland Security (DHS).
AOPA offered the recommendations in response to DHS’s March 14 request for user comments on the “continued validity” of its regulations. DHS is conducting the review under an executive order that seeks to make regulations more effective and less burdensome.
DHS should eliminate the severe limits on operations at the so-called “Maryland 3” or “DC-3” airports College Park, Washington Executive/Hyde Field, and Potomac Airfield, wrote AOPA Vice President of Operations and International Affairs Craig Spence in formal comments submitted April 12.
Under rules governing operations in the Washington Special Flight Rules Area and Flight Restricted Zone, pilots using the airports must undergo a background check and be issued a personal identification number (PIN). The process is time-consuming and inconvenient for most pilots, “and extremely prohibitive for pilots outside the Washington, D.C.-metro area,” he wrote. The rules duplicate background checks done on all pilots and are unnecessary because all flight within the SFRA is conducted on active flight plans and under positive control. The restrictions have burdened pilots and aviation businesses in the area “with no apparent increase in necessary security,” Spence wrote.
AOPA also recommended eliminating a requirement under the electronic Advance Passenger Information System (eAPIS) for pilots to file outbound manifests with U.S. Customs and Border Protection.
No other mode of private transportation is required to file manifests when leaving the country, Spence wrote, pointing out that the provision appeared when the eAPIS final rule was proposed and “exceeded the legislative requirement.”
Security directives that have an impact on general aviation should either be repealed or codified through the Administrative Procedures Act, which would ensure that their economic impact be studied, Spence wrote. His comments focused on a December 2008 security directive mandating that any person who has access to the airport operations area of commercial service airports must undergo a Security Threat Assessment (STA) and be issued an airport ID—including all general aviation aircraft owners and operators residing at the airport.
Security directives bypass the normal regulatory process and change some provisions of existing Transportation Security Administration regulations, resulting in “a patchwork of non-compatible procedures being implemented at airports nationwide that continue to exist instead of expiring naturally after a threat has passed.” Their limited dissemination has the effect of creating “communication gaps and misunderstandings” among users, he said.
Regulations on flight training for aliens need modification and streamlining, especially the rule requiring individual FAA-certificated flight instructors to receive initial and annual security awareness training, AOPA said in the comments. Because the annual training intervals do not mesh with the effective two-year duration of a flight instructor certificate, the renewal requirements are difficult to reconcile. Spence urged DHS to amend the security-awareness training rule “to be satisfied at an FAA-approved flight instructor refresher course,” in effect extending the time limit to two years.
In another recommendation, AOPA urged DHS to scrutinize the security implications of the FAA’s proposed restriction of pilots’ ability to use the Block Aircraft Registration Request program. AOPA opposed the FAA’s proposal in comments filed April 1 with the Department of Transportation.
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