The deadline for commenting on the Transportation Security Administration (TSA) plan to reopen Ronald Reagan Washington National Airport (DCA) to some general aviation operations ended on September 19, with just over a dozen responses from the industry.

The National Air Transportation Association (NATA) criticized an inconsistency in the rules that permits private aircraft operators to conduct flights in certain aircraft while prohibiting air charter operators from using the same aircraft on DCA flights.

Under the TSA’s interpretation of the rule, NATA said, operators already under a Twelve-Five Standard Security Plan and TSA-defined “corporate operators” can apply for DCA access. But the TSA specifically excludes Part 135 operators of aircraft that do not fall under the Twelve-Five program, essentially limiting DCA access to Part 135 aircraft that weigh more than 12,500 pounds.

NBAA recommended that the TSA allow aircraft operators to store prohibited items in a lockable location within the aircraft or in a lockable location not accessible in flight, with the armed security officer (ASO)  carrying the key during flights in and out of DCA.

Noting that the ASO nomination process has resulted in a low number of individuals participating in the program, NBAA recommended that the TSA change the requirement for a nomination by an FBO or aircraft operator to allow a sufficient number of individuals to participate in the program.

The association also asked that as operations approach the daily slot limit of 48 between 7 a.m. and 7 p.m., the TSA expand the number of daily slots up to the general aviation daily slot limit approved by the FAA for DCA and increase the hours of operation to coincide with those of the airport.

The Helicopter Association International (HAI) said the ban on general aviation aircraft operations at DCA has had a serious economic effect on the helicopter industry. Before 9/11, HAI said, there were between 1,800 and 3,000 helicopter operations into and out of DCA annually, virtually all of them passenger flights. “The loss of these flights has been economically devastating to many helicopter operations,” the association said.

While it called the restrictions and regulations outlined in the interim final rule “overly restrictive and burdensome,” HAI has been assured that the TSA will consider modifications to the initial requirements as the program matures. The association suggested that the agency conduct a full-scale review six months after GA operations resume at DCA and consider expanding the list of gateway airports or eliminating the requirements for an armed security officer on board GA aircraft.

More GatewayAirports Needed

The Metropolitan Washington Airports Authority also suggested that the number of gateway airports be expanded to include Washington Dulles International Airport and Baltimore-Washington International Airport. The airports authority recommended that all flight crews be briefed on arrival and departure procedures for DCA, how to avoid the prohibited areas around the White House and the Capitol and review the Reagan National TFRs, ADIZ and Norad visual warning signal program procedures.

The Greater Washington Business Aviation Association objected to having an armed law-enforcement officer on board the aircraft. It also called for the TSA to designate more airports as gateways. In addition to Dulles and Baltimore-Washington International, the group recommended Leesburg (Va.) Executive Airport and Manassas (Va.) Regional Airport.

An Unfair Burden

Although most of the commenters praised the TSA’s interim final rule as at least a good first step, one company did not. Gifford Laboratories said it has been proactive about adopting and using security measures, participating in the International Standard for Business Aircraft Operations (IS-BAO), NBAA security programs and working toward qualifying for a TSA Access Certificate.

“We are saddened that this terrible rule is even put before the American people, and we do not plan to participate,” Gifford said. “It forces the carriage of weapons aboard small business aircraft and places a totally unacceptable and unreasonable burden upon small business owners.”

The company requested that the rules be revised to eliminate the need for law-enforcement officers and gateway airports, both of which present a time and financial cost that small business cannot bear.