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NBAA Submits Comments On TSA's LASP Proposal

The Battle May Just Be Beginning

National Business Aviation Association (NBAA) President and CEO Ed Bolen submitted comments Friday that clearly articulate the serious concerns raised by the Transportation Security Administration's highly controversial Large Aircraft Security Program (LASP). NBAA's comments were submitted to the federal government's public docket on the final day for public comment on the LASP.

"As NBAA has noted since the LASP was introduced last October, this proposal completely misses the mark," said Bolen. "The TSA needs to understand that in preparing the LASP, the agency has attempted to overlay a security regime for the big airlines onto tens of thousands of businesses all across the country. If left unchanged, the plan would overwhelm these small businesses in a time of economic crisis without providing a clear security benefit."

NBAA's comments added to those submitted by more than 4,000 businesses, associations and individuals, all of which raise a variety of criticisms about the TSA's proposal. NBAA's 30-page document details the myriad ways the proposal would harm the GA industry. The main concerns include:

  • The 12,500-lb.Weight Threshold: NBAA's comments note that the TSA has chosen a weight threshold for its proposal without providing a data-driven, risk-based analysis. "A 12,500-pound airplane could fit nose to tail across the inside of an airliner, which averages about 300,000 pounds" Bolen said. "The TSA's ‘Large Aircraft Security Program' would apply to some very small aircraft."
  • The Prohibited Items List: The proposal contains a list of more than 80 "prohibited items." "Unfortunately, many of these items are routinely carried aboard business aircraft – everyday tools, for example – because they are central to NBAA Members' business needs or are products produced by the company," Bolen said. NBAA's comments recommend that the TSA establish procedures to control access to "restricted item(s)" while on board the aircraft.
  • Third-Party Watch List Service Providers and Auditors: Security experts have long understood that outsourced security programs can produce more risks than benefits, and that the most effective approach to security is through a closed system. The TSA's call for third-party security auditors overlooks such findings. "Private aircraft operate within a very secure system today, many involving sophisticated processes," Bolen said. NBAA's comments oppose use of third-party watch list service providers.
  • Federal Air Marshals: NBAA is deeply concerned with the TSA's proposal to require some aircraft to carry a federal air marshal (FAM) on board. "These aircraft are privately owned and operated by businesses," Bolen said. NBAA's comments maintain that the TSA has no authority to mandate the transport of law enforcement officers in any private vehicle.

NBAA's comments also renew the Association's call, first made last January, for a rulemaking committee that would allow for a productive dialogue to take place between government and industry stakeholders on the development of reasonable security policies.

"The business aviation community has a long and demonstrated history of partnership with government in developing effective yet workable security measures for the industry," Bolen said. "A rulemaking committee would provide a forum for stakeholder information sharing and the development of sensible and implementable measures."

Bolen also thanked NBAA Members for making their voices heard on the LASP. "The business aviation community has truly done an outstanding job of getting our message to the TSA about our concerns with the agency's plan," Bolen said. "Through the comments submitted to the public docket, the messages sent through Contact Congress, the participation in the TSA hearings and other measures, our industry acted when called upon and sounded a forceful, nationwide alarm about our grave concerns about the proposal. There is still much work to be done, and we will continue to count on our Members' support. But we appreciate their continuing dedication to this issue, and to sensible security policies."

FMI: www.nbaa.org/lasp

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