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LASP NPRM in ATL

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anything to help the airlines out.
 
Is this really that big of a deal?

The NBAA always over shoots on these types of thing.
 
Is this really that big of a deal?

The NBAA always over shoots on these types of thing.

Yeah, its a huge deal. It's as if the TSA was requiring you to do full background check and random drug testing on the High School kid you hired to mow your lawn for the summer.

My operation has been subject to the ridiculous 'TSA Waiver' program for the past several years and this is just an extension of the ridiculousness. Does essentially nothing to enhance safety, but causes significant, potentially crippling burdens on small operators and discourages the use of business aircraft. Just what the Air Transport Association wants. Could be lobbying effort on their part to force a concession on user fees. Hopefully the Legislative branch aholes that have enjoyed the use of corporate aircraft over the years won't forget the favor.

I sent a modified version of the NBAA letter to both my Congressman and Senator (the fate of the other Senator is questionable - IL).
 
What I sent, for what it is worth.

Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
West Building Ground Floor
Room W12-140
Washington, DC 20590-0001
Fax 202-493-2251

RE: RIN 1652-AA53

Dear Sir or Madam:

I have reviewed the rules proposed in RIN 1652-AA53 and I wish to submit a few comments.

I appreciate the need for good security to prevent the loss of innocent life. However, I believe that this rule over reaches the bounds of reasonable security. The hardest hit will be small operators, operating small aircraft for pleasure.

The definition used to determine what aircraft is large, and thus covered by the proposed rule changes, is not the same definition used by the FAA or ICAO for determining the aircraft’s size. The definition used was intended for certification of airmen. A more accurate definition can be found on http://www.flyingineurope.be/Flightplan.htm

H — Heavy (aircraft with a maximum certificated takeoff weight of 136,000 kg/300,000 lb or more).
M — Medium (aircraft with a maximum certificated takeoff weight of less than 136,000 kg/300,000 lb, but more than 7,000 kg/15,500 lb).
L—Light (aircraft with a maximum certificated takeoff weight of 7,000 kg/15,500 lb or less).
As I read the proposed rule, I wonder if the rule isn’t intended for 300,000 lb aircraft and larger.

I am an Aircraft Manager for a small Medium-Light aircraft (16,000 lbs). Our company is so small; I am the Aircraft Manager, Chief Pilot, Bookkeeper and Dispatcher. I am the only employee. Under the proposed rule change, I will have to hire an aviation lawyer, bookkeeper and a third party auditor to comply with the rules. This will more than triple our annual salary budget.

Keep in mind; our passengers consist of the aircraft’s owner, his wife and eight friends. Our need for a security program is minimal at most. Our situation is not unique. There are thousands of small aircraft that fit into the large aircraft definition used in this proposed rule. Most, will operate under a similar situation to ours.

The facts are, this proposed rule will be cost prohibitive to thousands of General Aviation operators. May I suggest adjusting the rule to cover the ICAO definition for Heavy aircraft? Heavy aircraft (300,000 lbs or more) are far more likely to fly passengers that are not well known to the pilots or the owners. This is the area that is in the greatest need for new security requirements.

Below, I will attach pictures for several different aircraft that will be covered by the plan. All of these aircraft have a seating capacity of 18 passengers or less.
 
Last edited:
Erik Jensen, Branch
Chief—Policy, Plans & Stakeholder
Affairs, Office of General Aviation,
TSNM, TSA–28, Transportation
Security Administration, 601 South
12th Street, Arlington, VA 22202–4220;
telephone (571) 227–2401;
facsimile (571) 227–2920;​
e-mail
[email protected]
 
I attended this. Well over 100 aviation professionals attended and many spoke to the panel. The 100% consensus from the speakers and attendees was that this LASP NPRM will be the end of part 91 corporate operations. Tens of thousands of people will lose their jobs...

I am saying that if you currently work in corporate aviation and you do not think that you will LOSE YOUR JOB as a result of this NPRM, you do not understand it or its implications.

READ IT! UNDERSTAND IT! GET INVOLVED!
 
I attended this. Well over 100 aviation professionals attended and many spoke to the panel. The 100% consensus from the speakers and attendees was that this LASP NPRM will be the end of part 91 corporate operations. Tens of thousands of people will lose their jobs...

I am saying that if you currently work in corporate aviation and you do not think that you will LOSE YOUR JOB as a result of this NPRM, you do not understand it or its implications.

READ IT! UNDERSTAND IT! GET INVOLVED!

I will not lose my job if this happens. My department has already complied with what the LASP will impose by completing the DCA access program. If this happens (and I hope it doesn't) we will just hire a Security Coordinator and keep on flying.
 
I will not lose my job if this happens. My department has already complied with what the LASP will impose by completing the DCA access program. If this happens (and I hope it doesn't) we will just hire a Security Coordinator and keep on flying.

I'm very glad for you!! Could you explain how tens of thousands of other people in this industry who lose their jobs is going to be good for you? What airports will you land at when most if not all small airports close because they can not afford to meet the requirements? Have you read the NPRM and do you understand it? Clearly you do not, or you would not make such a statement...
 
I'm very glad for you!! Could you explain how tens of thousands of other people in this industry who lose their jobs is going to be good for you? What airports will you land at when most if not all small airports close because they can not afford to meet the requirements? Have you read the NPRM and do you understand it? Clearly you do not, or you would not make such a statement...

I am aware of what will happen if this program is implemented. I hope it doesn't happen, but it is fearmongering to say everyone will lose their job if/when it happens. Many of us have been preparing for something like this for years.

Don't blame the TSA, they are just doing what Congress told them to do. You should focus your efforts on getting Congress and the President to ammend the law that established this process.
 

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