Request a minimum 120 days comment period on TSA's GA proposal security.

  • by: Mary Helen Taft
  • recipient:  Department of Homeland Security, Transportation Security Administration

In a new proposal released October 30, 2008, the Department of Homeland Security, Transportation Security Administration (TSA) proposes to expand airline-style security measures to private operations of aircraft weighing more than 12,500 pounds in general aviation.


TSA already has mandated security programs for the air carrier and commercial operator segments of the aviation industry including scheduled passenger operations, private charters, public charters, and all-cargo operations in large aircraft through the twelve-five program, the partial program, and the private charter program. With limited exceptions, TSA has not required security programs for large aircraft in general aviation. Large GA aircraft are most often operated by corporate entities, and some large GA aircraft are operated by individuals.


Among the additional provisions in the proposal would be the requirements that operators assign a security director to oversee flight operations, obtain TSA approval for a security program addressing every operation of the aircraft, submit fingerprints of all flight-crew members, seek government approval of each passenger for each flight, and pay for a third party to audit compliance with the new rules, with results sent to the agency.


These new provision places a substantial and unwarranted financial burden on general aviation and also raises questions in the areas of interstate commerce, government authority, civil liberties, and Constitutional rights.


There is only a sixty day period during which the TSA is accepting comments from the public on the usefulness and appropriateness of its proposal. Proposals that incur such serious consequences need more than sixty days for public study and comment. Unless the current comment period is extended, it will expire on December 29, 2008.  Given the serious potential impact of this proposed change, this petition respectfully requests that the Transportation Security Administration allow a minimum of 120 days for the public and its representatives to properly respond to this proposed TSA legislation for non-commercial operations of aircraft above 12,500 lbs.

Note: In addition to signing this petition, please go to www.regulations.gov, use the docket number, TSA 2008 0021, and formally request a comment period of a minimum of 120 days.

Docket Management Facility


U.S. Department of Transportation


1200 New Jersey Avenue, SE.


West Building Ground, Floor, Room W12-u2013140


Washington, DC
Please reference docket number, TSA 2008 0021. In the new proposal released October 30, 2008, the Department of Homeland Security, Transportation Security Administration (TSA) proposes to expand airline-style security measures to private (Part 91) operations of aircraft weighing more than 12,500 pounds in general aviation.



TSA already has mandated security programs for the air carrier and commercial operator segments of the aviation industry including scheduled passenger operations, private charters, public charters, and all-cargo operations in large aircraft through the twelve-five program, the partial program, and the private charter program. With limited exceptions, TSA has not required security programs for large aircraft in general aviation. Large GA aircraft are most often operated by corporate entities, and some large GA aircraft are operated by individuals.



Among the additional provisions in the proposal would be the requirements that operators assign a security director to oversee flight operations, obtain TSA approval for a security program addressing every operation of the aircraft, submit fingerprints of all flight-crew members, seek government approval of each passenger for each flight, and pay for a third party to audit compliance with the new rules, with results sent to the agency.



These new provision places a substantial and unwarranted financial burden on general aviation and also raises questions in the areas of interstate commerce, government authority, civil liberties, and Constitutional rights.

There is only a sixty day period during which the TSA is accepting comments from the public on the usefulness and appropriateness of its proposal. Proposals that incur such serious consequences need more than sixty days for public study and comment. Unless the current comment period is extended, it will expire on December 29, 2008.  Given the serious potential impact of this proposed change, we the undersigned respectfully request that the Transportation Security Administration allow a minimum of 120 days for the public and its representatives to properly respond to this proposed TSA legislation for non-commercial operations of aircraft above 12,500 lbs.
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