Mr. Mike Dahl
Manager, Standards Office
Small Airplane Directorate
Federal Aviation Administration
901 Locust, Room 301
Kansas City, MO 64106
Dear Mr. Dahl:
On behalf of more than 380,000 pilots and aircraft owners, the Aircraft Owners and Pilots Association (AOPA) submits the following comments regarding enhancing the security of small civil aircraft. AOPA has been very active in the development of enhanced security measures for general aviation and openly embraces any concept that will provide legitimate security enhancements without inhibiting the utility or economy of general aviation operations.
Flight operations in small general aviation airplanes (aircraft under 12,500 pounds) are typically conducted within a very tight flight envelope, and most small general aviation aircraft are saddled with very small operational load limitations. Despite these limitations, aircraft under 12,500 pounds are currently being operated in a myriad of commercial activities with great success. Today, it is not uncommon to have one aircraft fulfill multiple missions in a single day, often serving as a trainer for dual flight instruction and later as a chartered freighter or a local sightseeing flight. It's this diversity of mission capability that is the lifeblood of small general aviation business. Without aircraft capable of serving multiple flight roles, many small general aviation businesses would be unable to turn a profit.
Security measures such as cockpit dividers will severely curtail the operational capability of small general aviation airplanes. The additional weight of such a divider would most likely diminish the load-carrying capacity of most small general aviation airplanes by a significant percentage. Such a barrier may also pose significant safety problems by potentially impeding cockpit and aircraft egress in the event of an emergency.
Proposals such as removing additional seats with direct access to flight controls also pose significant problems for small general aviation airplanes. Reducing access to flight controls to only the pilot seat severely reduces the mission capability of small general aviation airplanes. Removing the co-pilot seat eliminates the possibility for a small airplane be used for dual flight instruction and significantly reduces the aircraft's passenger-carrying capacity. Both of these limitations have a dramatic negative impact on the revenue-generating potential of a small airplane.
Further, security modifications such as cockpit segregation and seat removal will require FAA certification such as the issuance of a supplemental type certificate. Past experience has proven that such certification is most often very expensive, making retrofit of most modifications a very costly and time-consuming process.
It is also important to note that the average small general aviation airplane weighs no more than a passenger car or SUV. Unlike Transport category aircraft that can weigh tens of thousands of pounds and can travel several hundred miles per hour, small general aviation airplanes simply do not possess the potential energy necessary to be considered a significant threat to persons or property. Thus AOPA sees little benefit in implementing security measures that will most likely be very costly and severely hinder the operational capabilities of small airplanes.
AOPA, in concert with several other general aviation organizations, advanced a series of recommendations on general aviation security to federal officials. These proposals included a comprehensive list of ideas for addressing general aviation security of aircraft, passengers, pilots, and airports. Included in this list was that the FAA pilot certificate be modified to include a photograph of the pilot using a format that is difficult to counterfeit, and that the existing registry of active U.S. pilots should be reviewed to ensure these individuals are not on any federal watch lists of potential terrorists.
AOPA continues in this proactive role to address general aviation security concerns and stands ready to assist the FAA in developing realistic and viable enhancements to small airplane security.
Director, Regulatory and Certification Policy
March 5, 2002