DHS/CBP 19 -DHS CBP’s Air and Marine Operations Surveillance System (AMOSS) System of Records

...The broad scope of monitoring and tracking activity described in the SORN lacks safeguards for the civil liberties and privacy of general aviation pilots. For instance, 6 U.S.C. 202, cited by DHS/CBP as authority for the proposed system, was added to the U.S. Code in the Homeland Security Act of 2002, a law enacted mindful of the importance of "perserving individual rights and liberties" and the need to "improve national security without compromising established constitutional principles." H.R.Rep. 107-609 (Homeland Security Act of 2002). Congress specifically noted that "public oversight will be necessary." Yet the purpose of this SORN seems to be to prevent any such oversight. Since AMOSS is already in existence, it appears that what is "new" about the system of records is the proposition to exempt it from Privacy Act disclosure requirements, therby preventing any public oversight...(see 2 attachments).

In response to the original publications in the Federal Register noticing Department of Homeland Security's intent to create a system of records and to exempt those records from the Privacy Act, the Aircraft Owners and Pilots Association (AOPA), representing the interests of nearly 400,000 pilots and aircraft owners nationwide, requested an extension to the comment period to allow for an opportunity for appropriate comments to be prepared and submitted for the Agency's consideration before going forward as proposed in Docket No. DHS-2013-0021. We have not received a response to our request, and we understand that the 16-day federal government shutdown most likely impacted your ability to respond to our request in this regard. Since last week, and the re-opening of the government, we have attempted several times to contact your office to ask about the status of the docket, but we were not able to reach anyone. All of our calls went to voicemail, and we have not yet received any return calls. Therefore, we are reaffirming our request that an extension to the comment period in Docket No. DHS-2013-0021 be granted so that interested parties may have enough time to fairly prepare comments in response to your proposals. AOPA objects to any creation and implementation of a system of records, and a Privacy Act exemption applicable to those records, on the basis that taking any such action at this time would violate the protections and processes of the Administrative Procedures Act...(see attached).

The Aircraft Owners and Pilots Association (AOPA), representing the interests of nearly 400,000 pilots and aircraft owners nationwide, respectfully requests a 90-day extension of the comment period on the September 23, 2013 proposal to implement exemptions to a new Department of Homeland Security/U.S. Customs and Border protection-019 Air and Marine (AMOSS) System of Records.

Filed on regulations.gov — full text not in the inline record.