By aviation security expert David Hook, president, Planehook Aviation Services, LLC
Remember the Large Aircraft Security Program (LASP) that the TSA proposed about this same time last year? Well, this time TSA is proposing something similar, but with a twist. The latest proposal has your aircraft mechanic in the agency’s crosshairs.
“Good security is good business.” That saying holds true for many businesses. Keeping a client’s aircraft protected and secure while it is being repaired or inspected is a good business practice. Good business practices tend to be driven by market forces, not government regulations. Those who practice good business practices are rewarded by earning a growing, loyal client base — in other words, a return-on-investment (ROI). Unfunded security mandates like the latest proposed by TSA are not based upon the business principles of ROI. It’s that simple.
Just prior to Thanksgiving the TSA published its latest security proposal, Aircraft Repair Station Security, Docket Number TSA-2004-17131, in the U.S. Federal Register. And like the LASP, there is a public comment period. But unlike last time the comment period is only 60 days — not 120 days — and closes on Jan. 19, 2010.
This TSA proposal specifically targets aircraft repair stations that are certified by the FAA under 14 CFR Part 145. While some believe these repair stations provide service to the airline industry only, that perception is just not true. Many of these repair stations service aircraft flying under Part 91 and Part 135 as well.
Among the TSA’s proposed security requirements are access control (perimeter fences, gates and locks) and ID badges (Note: The TSA required some of us to comply with a similar ID badge requirement in mid-2009 with Security Directive 08G). So the elements of security that the TSA would mandate, regulate and inspect — beyond the current FAA safety inspections that already take place at these repair stations — would become an additional overhead expense to their operations. These added expenses are part of an unfunded mandate and certain to be passed along to the general aviation consumer.
Pilots and aircraft mechanics work together to keep our aircraft safe and airworthy. One cannot exist without the other. Make no mistake: What hits our mechanics’ wallets will eventually hit ours.
If you would like to read the TSA’s proposal, click here. You can also go to YouTube to watch a video that highlights the main points of the proposal at Aircraft Repair Station Security Proposal or at Aviation and Space TV. You can submit your comments electronically by going to Regulations.gov and clicking on the Submit Comment hyperlink.
David Hook is the president and founder of Planehook Aviation Services, LLC, which specializes in low-cost security for general aviation.