Aircraft Repair Station Security

Comments of the Air Transport Association of America

IATA and the air transport industry have a long record of working with DHS and its component agencies to implement often-complex procedures to ensure the security of passengers, staff, aircraft and airport operations. We understand that civil aviation remains a target of terrorism for the foreseeable future and that risk based security measures can serve as an effective counter. However, we believe that this NPRM falls short in articulating the threats to repair stations and specifying risk based security measures to combat them. Further, it fails to acknowledge the inherent security value of the far reaching safety regulations already governing the activities within this sector of the industry. Finally, this NPRM also fails to take into consideration the high security standards for repair stations already in place in many countries and does not attempt to harmonize NPRM requirements with them. For these reasons, absent significant changes in this rule, we do not expect the resulting program to make a measureable advance in aviation security.

NOTE: This is a reposting of the original attachment included with our comments of November 20, 2009. We would like to ensure that this formal request appears on this docket. ------------------ On behalf of IATA Member Carriers operating aircraft repair stations both internationally and domestically, IATA hereby requests that the deadline for filing comments in this rulemaking be extended from January 19, 2010 until March 19, 2010. The complexity and scope of this document requires careful consideration by stakeholders and the current comment period does not offer sufficient time to do so. In addition, this document will need to be translated and reviewed by foreign repair station operators abroad. Such an extension would allow stakeholders to continue a thoughtful and deliberative review and result in the TSA receiving a substantial industry cross section of insightful and useful comments.

On behalf of IATA Member Carriers operating aircraft repair stations both internationally and domestically, I hereby request that the deadline for filing comments in this rulemaking be extended from January 19, 2010 until March 19, 2010. The complexity and scope of this document requires careful consideration by stakeholders and the current comment period does not offer sufficient time to do so.