Beware of unintended consequences. That's the warning AOPA sent to the Transportation Security Administration. The TSA is proposing new air cargo security regulations that AOPA says could have adverse - albeit apparently unintended - effects on general aviation, making it harder for GA pilots and passengers to access their aircraft at some airports.
"AOPA is concerned that the rules, as drafted, could be interpreted to mean that the general aviation ramps at air carrier airports would have to be included in the airport 'security identification display area' (SIDA)," said Andy Cebula, AOPA senior vice president of Government and Technical Affairs. "That means pilots would be subject to a criminal history check and need an airport-issued security ID to get to their aircraft."
In its comments on the proposed regulations, AOPA said that the emphasis of existing airport design and approved security programs has been on physically separating air carrier and scheduled air cargo operations from general aviation. At almost all air carrier airports, the GA ramp was designed to be outside the SIDA.
"General aviation areas are unique because individuals needing access to aircraft are generally not employees of companies based at the airport, but individual pilots," AOPA told TSA. The distance between the GA and air carrier areas provides a sufficient layer of security. "This has proven to be an effective and efficient manner to control access at airports and manage operations," AOPA said.
In those cases where the GA ramp is used to load and unload cargo from smaller aircraft, AOPA recommended that TSA adopt the "operational area of the aircraft" principle. Unauthorized people would be prohibited near the aircraft and cargo-handling area, without restricting pilots' access to the rest of the ramp.
In addition, the rule would require non-air carrier airports that conduct cargo operations to impose access limitations in the vicinity of cargo aircraft, potentially requiring law enforcement presence. At these primarily general aviation airports, that requirement will be costly and could restrict ramp access for numerous general aviation operators. AOPA recommended that TSA clarify that only the area directly around the cargo aircraft - and not the entire ramp - needs to be restricted while the aircraft is being loaded and unloaded. AOPA also recommended flexibility to allow airports and cargo operators to use personnel other than law enforcement to oversee the cargo operation.
"We strongly believe that TSA must consider the impacts to general aviation operators at both TSA 1542 airports (with scheduled air carrier operations) and non-air carrier airports," Cebula said. "It is imperative that TSA allow flexibility to ensure that airports and operators are permitted to address the unique security needs of their facilities without unjustly hindering general aviation."
January 12, 2005