Lynn A. Beavers

February 9, 2010 Subject: TSA-2004-17131, Aircraft Repair Station Security The proposed rule for Aircraft Repair Station Security is another bureaucratic attempt at doing something without clearly assessing and knowing where the real security problems lie. It’s obvious that TSA doesn’t know or understand aviation. The use of fear (loss of certification) to force compliance is both high handed and counterproductive. If security is going to work it has to be the effort of all aviation professionals and organizations. TSA states that there are approximately 4500 FAA certificated domestic repair facilities. That number probably reflects less than 5% (a guess) of the domestic facilities doing aviation business. TSA’s approach is like putting a band-aid on the only spot on a burn victim that wasn’t burnt. It appears that TSA believes that since the FAA certificates certain organization that it will fix the entire security question. Our company is located on a GA airport and we are the only repair station on the airport. There are several corporate facilities that store and maintain aircraft that weight 12,500 and greater. They set in hangars fueled and ready to fly. I might add that most 12,500 aircraft do not have door locks to secure them. They won’t be affected by this rule. On the other hand we will be tasked with hiring security, establishing security systems, and dealing with additional bureaucratic intrusions while trying to maintain a competitive edge in the market place. It’s incomprehensible that TSA would want to take an industry that has felt the affects of 9/11 and the current economy down turn and task it with a greater burden. We’re already required to supply adequate housing, tooling, experienced personnel and processes just to obtain certification, only to have a bureaucratic night mare heaped on top of it all with the threat of loss of certification. In the 2000’s there was and still is an economic meltdown. This is not a good time to increase aircraft operating cost and expect aviation to survive. Security is a vital element, but TSA needs to get it right when it comes to implementing security regulations to the resources available. It would be more comprehensive to task security to the local airport authority. The cost burden for security would be flowed down to tenants; with each tenant being both involved in security, but bearing a smaller cost for security. Many GA airports have already received visits from TSA and were told that what they had was adequate. The airport where our company is located was told by TSA that their security plan was adequate. One side of the airport is fenced in chain link, with security gates that require controlled pass codes and the other three sides are fenced by barbed wire. It will keep law abiding citizens and cows out but it doesn’t do much to deter terrorist. We need to fix what is broken before we try to fix what isn’t. Lynn Beavers P.O. Box 1284 Sherman, TX 75091