TSA Security Directive 1542-08F info

[bwmatz]

The following was just distributed to ASN Volunteers:



April 22, 2009



Dear ASN volunteer,



AOPA has been following the controversial issue known as "TSA Security Directive 1542-08F" very

closely since it was first announced in December 2008. Like you, we have been extremely frustrated with the information "void" surrounding this change and have been in regular contact with the TSA to try and have the situation remedied. In our most recent meeting, we pressed the TSA to delay implementation of the security directive at Category II, III, and IV airports where general aviation makes up the majority of the activities. Additionally, we urged the TSA to conduct an outreach by Federal Security Directors (FSDs) to provide airports with ideas and alternative measures that will minimize the impact on the general aviation community.

Security Directive 1542-08F was issued by the Airports section of the Transportation Security Administration, Transportation Sector Network Management, Commercial Aviation Division. AOPA immediately objected that no one from the general aviation community was consulted prior to its release. Had we been consulted, we might have been able to mitigate many of the problems that airports, pilots and aircraft owners are experiencing today.

TSA Security Directives (SDs) can be issued without going through the Notice of Proposed Rulemaking (NPRM) process, as we are seeing with this badging requirement. The distribution of the SD is tightly controlled, (because AOPA is not a "regulated party" we have been denied access to the full document) and the TSA's reluctance to provide additional guidance has resulted in a veil of secrecy that has surrounded this SD. This lack of information has led to the rumor mill running rampant and increased the level of frustration for all involved.

To avoid spreading incorrect information among our pilot communities, here are the facts we can share about this SD, which have been verified to the best of our ability:

· Because this SD has been classified "Security Sensitive" it cannot be freely distributed. If you come across the document online, AOPA is advising members that they should not open, download or distribute it because it could lead to a criminal investigation.

· The TSA does not consider ASN volunteers "need to know" individuals per 49 CFR 1542.303(f)(1-2).

· The SD requirements only apply to airports with commercial airline service.

· Pilots will not need a badge issued by every airport they visit.

· Escort procedures for transient pilots are in place, and have been for quite some time. This SD should not change those existing escort procedures according to the airport's security plan.

· While AOPA will continue to seek alternatives and solutions, the June 1, 2009 compliance date remains in effect and we encourage you to contact your airport to take the necessary steps to ensure you will have access.

· It should not hinder your trip into Oshkosh for AirVenture or any other airport with commercial service that you visit.

· The TSA has indicated that they will soon release a new version of the SD, which will be known as 1542-08G. SD-08G will provide some clarifications for the airport administration, but will not include any increase or decrease in scope requirements.

AOPA and other industry organizations are dealing with this SD on numerous fronts, and we understand and value the importance of making sure your Congressional representatives fully understand how this SD will impact general aviation. We encourage you and your fellow pilots to contact your local representatives and explain how Security Directive 1542-08F will affect you and your airport. Because of the recent initiatives by the TSA, there are some members of Congress that combine this issue with the Large Aircraft Security Program (LASP). In your contact, please mention 1542-08F specificically so that members of Congress understand this is a separate (and equally as important) issue.

Areas of concern that you may want to bring to their attention include:

· All general aviation pilots are covered by similar security measures as commercial pilots including vetting. The requirement for an additional check as spelled out in the SD seems redundant.

· The TSA has laid out, in regulation, definitions of sensitive portions of the airport including Security Identification Display Area (SIDA), Secured Area, and Air Operations Area (AOA). Each area has differing requirements based on its sensitivity. This SD does not seem to take this into account.

· Previously, the TSA and FAA have recognized the principle of time and distance when applying security measures at remote sections of the airport. This SD appears to ignore this option.

· This SD also appears to ignore the differences that exist between airports, which may impose unnecessary requirements on many of the smaller airports in the country.

· Ask your elected official to urge the TSA to suspend implementation of the badging requirement at Category II, III, and IV airports until workable alternatives can be developed.

AOPA staff members have been involved in many meetings with the TSA, DHS and other associations who are just as concerned as we are. We also continue to work on Capitol Hill to educate Congress and their staff about SD 1542-8F. AOPA is working with the TSA to develop alternative proposals and procedures that will minimize the impact on general aviation, and will be looking into long-term solutions as well (similar to those that AOPA members have suggested/discussed). Rest assured, we are doing all we can to bring our concerns and impact to the highest level of the TSA and DHS. If you have any questions, do not hesitate to contact the Pilot Information Center at 1-800-USA-AOPA or via email at pilotassist@aopa.org. Our Aviation Technical Specialists are fully briefed on this issue and would be happy to assist you.



Sincerely,

Craig Spence

Vice President, Regulatory Affairs

Aircraft Owners and Pilots Association



Stories AOPA has published on this issue:

http://www.aopa.org/whatsnew/region/200 ... c_sect=gan

http://www.aopa.org/advocacy/articles/2 ... aison.html

http://www.aopa.org/advocacy/articles/2 ... aison.html

http://www.aopa.org/advocacy/articles/2 ... adges.html

http://www.aopa.org/advocacy/articles/2 ... 12tsa.html

http://www.aopa.org/advocacy/articles/2 ... urity.html



Links to writing your elected officials:

Representative: https://writerep.house.gov/writerep/welcome.shtml_

Senator: http://www.senate.gov/general/contact_i ... rs_cfm.cfm_

[joea]

We need to be very pro-active and careful with upcoming legislation. The current administration along with the TSA/DHS and ATF will take more of our rights than ever before if we allow them to do so.

If we do not step up and put our foot down now, we very well may not be "allowed to fly" a private airplane in a few years. They cannot control us once we take off and total control of everything sure seems to be what they want.

Just my 2c worth, but now is a very good time to be a member of and support the AOPA, EAA, NRA and contact your elected representatives and tell them how you feel.

Joe A

[mike newall]

In the UK, most airports that have any commercial services are now just about off limits for us little uns.

Sure, you could fly into Leeds, Luton, Birmingham or Bristol, but you would have landing fees, compulsory handling, be forced to wear yellow jackets etc etc.

Fight now, fight hard or you will all suffer.

I fly from a farmers field, we have flown from there for 25 years, first with a Tiger Moth, now with the Tiger and also a Cub, Maule and when I have one, a 'Ronca. The cops come round every year or so and ask general questions. They are rural cops, quite friendly and just want to ensure that no undesirables are coming in or out. As my friend who owns it is a little further right wing than Attila, I doubt we will have too many problems there then.

We have to be careful though - 3 years ago, the local village council asked questions about my friends' Tiger Moth flying - they thought it may be a threat to national security - we laughed, but all of a sudden you begin to wonder whether they are serious..............

The bedrock of 'fun flying' is what we and Piper, Cessna, Luscombe and other owners do. Do not let these people slide regulations in on grounds which have no current basis of factual evidence.

After all, I want somewhere to have some fun when I am layovers in Sanford and Vegas

'that's a hint for any local 'Ronca flyers by the way'

[twosevenleft]

This subject has so many aspects it's hard to know where to start, but I do think politically charged statements such as "the current administration ..... will take away more of our rights than ever before" are deeply unhelpful. We need to present a united front in defense of our aviation freedoms, not a partisan one.

In 2003 I was working for an FBO in Florida when the head man instigated a policy which limited access to the ramp to employees only, all others had to be escorted. Road vehicles were banned etc. (Yes I did say 2003!!!! Non of this c..p is new.) Shortly thereafter a teenage student pilot at an adjacent FBO took a Cessna 172 and flew it 9/11 style into a Tampa office building, fortunately the building was virtually empty at the time and he killed only himself. I'm not sure what this proves, other than how difficult preventing this sort of thing is.

It seems to me that the real problem is lack of nuance in all this "security". One size does not fit all. At small airports properly securing our aircraft/hangers would seem to me to be sufficient, as the airport/aircraft size increases more formal arrangements are probably necessary. Again this is nothing new, just something that has been handled locally and generally very successfully, has had little impact on light aircraft and thus has passed unnoticed by most of us.

Regarding flight access to the larger airports, this is already rationed by the "slot" system and/or price. I can't say it bothers me, I don't want to fly my airknocker down the ILS into JFK or LHR. I do want access to as many small, quiet, airports/airparks/farm strips as possible.

All this leads me to the conclusion that a policy of cooperation, rather than confrontation with the authorities is more likely to successfully serve our needs. I believe the AOPA, EAA recognize this and deserve our full support.

Enough for now.

Joe Platt
46 7AC Champ
66 C-150

[shep]

The current administration along with the TSA/DHS and ATF will take more of our rights than ever before if we allow them to do so.

In reality this directive was first surfaced in December 2008. It is a product of the former administration. It is not clear to me that the current administration is even aware that this is ongoing.

For those who are motivated to notify their elected representatives I will place a copy of a letter we have generated in Yakima, WA. Feel free to copy the text and modify to fit your locality

>
>

> Dear Senator Murray and Representative Hastings;

The Transportation Security Administration is about to enact a Security Directive 1542-08 that will require airline-style background screening and badging of all pilots accessing larger commercial airports. I implore you to review and oversee this action by the Transportation Security Administration. The General Aviation community at McAllister Field, Yakima, WA (YKM) objects to this directive on many levels.

– It is a regulation that most of the General Aviation community feels is being ram rodded through without due process. The actual directive is considered “classified” and as such the details of the regulation are not available to the community for discussion. Yet TSA has set a deadline for compliance by June 1, 2009. This Directive was crafted in a vacuum void of input from the citizens from whom it forces compliance. This mandate comes without normal public comment or Notice To Proposed Rulemaking announcement. It is so secretive that few outside of government have seen the full text of the Security Directive. It fosters disrespect for the TSA and disbelief in their ability to accomplish meaningful improvements to national security

-- It is over reaching and inconsistent. McAllister Field is only staffed from 0600-2200 PST. An outside potential threat that lands at YKM after hours is not monitered at all. In contrast, a private plane owner on the southeast end of the field (1/2 mile from any commercial aircraft parking areas) is required to have a badge at all times and is subject to substantial fines for failure to do so. TSA is not restricting drivers' free access to highways even though Timothy McVeigh accomplished the Oklahoma City bombings using a private vehicle via public streets. We have not heard of any registration or badging reguirements for operators of cars that share the road with trucks over 12,500 pounds gross weight. Additionally, at McAllister Field these ground vehicles routinely get closer to the restricted SIDA area than general aviation aircraft.

-- It impacts the right to free enterprise. McAllister Field is home to several businesses that support the General Aviation community. Cub Crafters manufactures new certified aircraft, provides maintenance and rebuilding support for Piper Cubs. This enterprise now must screen and badge every employee at substantial cost. While the economy is faltering and unemployment is rising, TSA will contribute to the nation's problems by thrusting huge compliance costs on airports, aviators and airport-based businesses. General Aviation pilots will decrease or abandon their legal recreational flying activities, impacting sales of fuel, service, instruction, supplies, and untold support vendors. Jobs will be lost.

The level of paranoia displayed by TSA does not appear to have any documented basis that encourages support and compliance by the General Aviation Community. Yet, TSA has steadly pressed to implement national policy out of what the General Aviation community believes to be unfounded, misdirected phobia. I encourage Congress to halt TSA's June 1, 2009 implementation schedule and charge them to join with industry organizations such as Aircraft Owners and Pilots Association, and National Business Aviation Association, to craft practical, real-world alternatives that will not impose unreasonable burdens on airports, airport based businesses and general aviation pilots.

Respectfully,

[shep]

A critical vote for pilots barely passed the house today.

http://www.eaa.org/news/2009/2009-06-04_vote.asp

My sense is that most pilots do not mind the security but strongly object to how it is being implemented. I feel that flying is an expression of freedom and I sometimes wonder who has taken more of my freedom - Homeland Security or the Terrorists.

Let's not let up. Let your senator's know your feeling on this

[joea]

Shep,

Thanks very much for posting this. Time to get to work again!

Joe A