TSA Extends Comment Period for Repair Station Security Program

The Transportation Security Administration (TSA) is extending the comment period on the notice of proposed rulemaking (NPRM) regarding the Aircraft Repair Station Security Program. The comment period will now end on Feb. 19, instead of Jan. 19.

Why should you care? Because what affects your mechanic is going to affect your bottom line.

Don’t lose your chance to submit a comment, click here now.
Once at the page click on Docket ID: TSA-2004-17131 located near the top of the page.

To read the CALPILOTS response to this ill advised NPRM click read more.


Docket Management System
U.S. Department of Transportation
Room Plaza 401400 Seventh Street,
Washington, D.C. 20590-0001

Docket No. TSA-2004-17131/RINI652-AA38/Aircraft Repair Station Security

On behalf of our statewide membership, the California Pilots Association would like to respond to TSA’s latest proposal, TSA-2004-17131/RINI652-AA38/Aircraft Repair Station Security.

First, we have to ask why TSA would want to use such a broad brush and include general aviation in yet another massive government bureaucratic program such as this one.

For whatever reason, government does not seem capable of emulating the private sector in common sense problem resolution by asking the simple question “What is the problem we are trying to solve?” This is obvious with the implementation of LASP, and the SD 8Fprogram, both of which in our opinion, are unwarranted.

While we understand that there might be issues with air carriers outsourcing maintenance work to foreign lands, and even a few large charter operations, we do not see the requirement to include general aviation in this sweeping bureaucracy security net for general aviation maintenance in the United States.

Frankly, in our opinion TSA should be working with the FAA to resolve these issues instead of attempting to grow its own bureaucracy. The FAA is better equipped and actually has some personnel who still understand aviation. We believe that the resources associated with this proposal should be given to the FAA which is aviation trained and can do a better job, instead of on TSA which effectively has zero understanding of aviation operations, much less general aviation.

For the record, we feel that it is important to define bureaucracy. A bureaucracy is a government agency which has forgotten that it works for its stakeholders – it has instead evolved to believe that its stakeholders work for it. This is the basic issue that all large government agencies pose to the public, and it is clear that TSA fits that model.

We believe that it is the intent of some in the government to provide a value added capability for stakeholders to respond to these proposals. In case any government overseers wonder why so few people and organizations respond, the answer is simple, most do not believe that the provided input will actually be considered in the final outcome – especially when it comes to the TSA.


Edward Rosiak – President
California Pilots Association