The Transportation Security Administration’s notice of public meeting and request for comments on “Aircraft Repair Station Security” (Docket No. TSA-2004-17131) garnered 20 comments by the March 29 deadline. Responses came from individual pilots, small and large maintenance facilities and special interest groups. At stake are potentially very expensive regulations that could affect approximately 650 foreign repair stations certified by the FAA to repair aircraft that enter U.S. airspace, and approximately 4,500 domestic repair facilities. The comment period followed a February 27 public hearing in Arlington, Va.
Most comments were critical of singling out maintenance facilities for increased security measures. “Those of us at small, non-airline airports should contribute to shop security. Maybe we could take turns standing guard at our one-mechanic shops,” one commentator suggested.
“The TSA so far has taken an approach to general aviation security that ‘one size doesn’t fit all.’ I sincerely hope that the agency will apply this reasoning to repair stations as well. Regulation of repair stations at the vast majority of GA airports should be kept to an absolute minimum,” said another.
Bruce Whitehead, chief inspector and director of quality for Omniflight Helicopters, wrote, “Like all aviation-related industry participants, we have suffered economic hardships as a result of the September 11 terrorist attacks, but are committed to safety. However, there are other issues that also need to be considered: economic impact, risk versus return and the creation of new threats from exposed vulnerabilities.”
National Air Transportation Association (NATA) president James Coyne submitted comments, saying, “Any security measures must focus on what is realistic and appropriate for repair stations in this country, most of which are small businesses. We must be sure not to incorporate measures that will do little for security while drastically raising the costs of doing business in the aviation industry. Congressional intent clearly states that this new rulemaking process apply only to foreign repair stations that work on Part 121 air carriers, not domestic repair stations that work on general aviation aircraft.”
James Little, air transport director of the Transport Workers Union of America, AFL-CIO, offered a different perspective: “There is an obvious and accelerating trend toward the outsourcing of aircraft maintenance–particularly heavy overhaul work–to domestic and overseas repair facilities. This has occurred notwithstanding the fact that the domestic passenger industry has recently suffered the most significant contraction in its history. There is no question that this movement of work has been facilitated by the failure of both the Transportation Security Administration (TSA) and the FAA to ensure there is a single standard of security and safety requirements for all FAA-certified repair facilities, regardless of whether they are located overseas or whether they are managed by a carrier or a third party. As matters now stand, a number of security and safety costs imposed since 9/11 on cash-strapped U.S. carriers can be avoided simply by outsourcing work, particularly overseas.”
The TSA will review the comments and input from the meeting and presumably craft a notice of proposed rulemaking, which will subsequently be open to public comment. Under the provisions of the Vision 100 Century of Aviation Reauthorization Act, signed into law on December 12, the TSA has until August 8 this year to “issue a final regulation to ensure the security of foreign and domestic aircraft repair stations.” All comments are available at dms.dot.gov/search/searchFormSimple.cfm. The docket number is 17131.