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.
