Response to TSA-2004-17131/RINI652-AA38/Aircraft Repair Station Security Proposal

To read the letter the California Pilots Association sent in response to the TSA’s proposed Repair Station Security, known as Docket No. TSA-2004-17131/RINI652-AA38/Aircraft Repair Station Security, click Read More below.

Docket Management System
U.S. Department of Transportation
Room Plaza 401
400 Seventh Street, S.W.
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 has effectively 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


Third time’s the charm?

Posted by Charles Spence GAN · May 24, 2010

WASHINGTON, D.C. — The Transportation Security Administration has been without an administrator since 2007 and the minority leader of the House Transportation and Infrastructure Committee is calling for a reorganization of TSA, saying it is “a bloated, ineffective bureaucracy.”

Rep. John Mica (R-Fla.) recently released a review of a TSA program known as SPOT (Screening Passengers by Observation Techniques) conducted by the Government Accountability Office at Mica’s request. The Congressman said TSA spends hundreds of millions of dollars on SPOT, but has never scientifically validated the list of behaviors underpinning the program and never determined whether the techniques could be applied to counterterrorism or in an airport environment. In fact, the program has failed to identify known terrorists. Since the program’s inception in 2003, 17 known terrorists have traveled through SPOT airports on 23 different occasions. Although 1,100 people have been arrested, none were arrested for terrorism.

“TSA is a bureaucratic nightmare,” Mica declared, noting it has more than 60,000 employees and is top heavy with supervisory and administrative staff. In fact, at the Washington, D.C., headquarters, nearly one out of three employees is a supervisor. Mica has written to Homeland Security Secretary Janet Napolitano expressing the need for an immediate reorganization of TSA.

It is into this quagmire that the next TSA administrator will step — if and when confirmed by the Senate. John Pistole is the third person to be nominated by President Obama for the post. Pistole currently is deputy director of the Federal Bureau of Investigation. Two previous nominees withdrew after revelations of possible misconduct.

General aviation groups have been quiet about the latest nominee. Normally, organizations rush to praise a nominee in hopes of generating goodwill for their causes. But after being burned twice, the attitude now is one of wait and see.

If confirmed, Pistole should be in office in time to make the final decisions on the Large Aircraft Security Program (LASP), which will set security regulations for aircraft weighing 12,500 pounds or more. Decisions on that proposal are expected late this summer.