Wednesday, November 5, 2008

TSA: Finishing Up Where The Luftschutz Left Off


I've been a fan of The Collings Foundation ever since they parked their B-17 bomber at our local airstrip. Thanks to them I, and legions of history geeks like me, have been able to walk the catwalk between the bomb bays on a B-24 Liberator, stare down the sites of a .50 caliber machine gun from the waistgunner position on a Flying Fortress, and hear the trademark whup-whup-whup of a Vietnam-era Huey helicopter. Now, the very existence of this noble group of living historians is threatened by a piece of backdoor legislation.

I received the following in the organizations newsletter. Any help would be appreciated:
Tuesday November 4th, 2008

Critical Information!
TSA Proposed Legislation
Bottom line: If this TSA Legislation passes, it will be the end of the Wings
of Freedom tour and programs similar.
We need your support. This is time sensitive. Please read below:

TSA Proposed Legislation Represents Potentially Significant Regulation of Private Aircraft Operations

RE: Docket Number TSA 2008-0021, Large Aircraft Security Program, Other Aircraft Operator Security Program and Airport Operator Security Program

On October 30, 2008, the TSA issued a Notice of Proposed Rule Making (NPRM) with only a 60 day comment period (which includes several holidays and a period when, typically, Washington becomes a “Ghost Town”) calling for sweeping new security requirements on the operation of all aircraft exceeding 12,500 pounds. The Collings Foundation’s preliminary assessment of the proposal is that this legislation would be so cumbersome, far reaching, and virtually impossible to comply with, that our flying of historic aircraft would not be possible.

Because of the onerous requirements and encroachment on personal freedoms suggested in the NPRM, three major aircraft associations, AOPA, EAA and NBAA, have called for extending the comment period to120-days, plus public hearings to evaluate the impact and interpretation of the proposed ruling.

Industry estimates are that over 15,000 aircraft, 10,000 operators and 300 airports will be impacted by the 67-page proposal. New concepts of third party auditors, security program training and approval, and third party watch list checking firms with timely approvals-- which would allow the general aviation community to comply with these regulations do not exist, thereby resulting in a real Catch 22.

Furthermore, there seem to be no discussions of the cost vs. benefits of this huge Federal Program, and who would pay for it other than “the General Aviation Community.” As it is proposed, TSA-2008-0021 would have an enormous impact on general aviation, plus violation of Constitutional Rights issues.

As to its effect on the Collings Foundation, our assessment is that, as proposed, it would be fatal to the Wings of Freedom Tour and our ability to take these historic aircraft around the country and share them with millions of Americans annually. Please note that with some concern for political correctness please use “historic aircraft” rather than “bombers” or “warbirds” in your communications and correspondence.

The bottom line is that we need your help both short-term and long-term. Short-term, we need you to support the aviation communities’ request to extend the comment period by a minimum of at least 60 days. The current deadline for comments is December 29, 2008.

Official Response: You may submit comments, identified by the TSA docket number TSA 2008-0021 to the Federal Docket Management System, a government-wide electronic docket management system, using any and/or all of the following methods:

* By Mail, In Person or Fax to the Docket Management Facility, US Dept. of Transportation, 1200 New Jersey Ave SE, West Building Ground Floor, Room W12-140, Washington DC 20590-0001. Fax 202-493-2251.

* Electronically through the Federal eRulemaking portal at Follow the online instructions for submitting comments.

* Higher Level Responses. If any of the Aviation Committee members of either the House or Senate, are your representatives, the same appeal for extension could be even more effective. For a list of Transportation/Aviation Committee members in the House of Representatives and Senate, click the appropriate link below:

House of Representatives: click here.

Senate: click here.

D. Contacting your Senator or Representative: You can reach your Senator or Representative by calling 202-224-3121 and asking for your Congressman. Upon being connected to the office, ask for the legislative assistant in charge of transportation issues. You won’t get to speak to your Senator or Representative directly, but their aides for the respective areas are the right channels to get action.

E. Your Comments may also be sent to:

1. The Honorable Edward “Kip” Hawley, Assistant Secretary, Transportation Security Administration, 601 South 12 th Street, Arlington, VA 22202-4220.

2. Branch Chief-Policy, Plans & Stakeholder Affairs, Office of General Aviation, TSNM (TSA-28), Transportation Security Administration, 601 South 12 th Street, Arlington, VA 22202-4220.

Please join in with us now to get this comment period extended. In the longer term, we’ll be updating you further on the interpretation of this proposal, discussions regarding how this might impact us and what we can do about it. Thank you very much for your support.
Please take 5 minutes and contact the above representatives! Your support is what counts!

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