On December 12, 2003, the President signed into law the Vision 100—Century of Aviation Reauthorization Act. Section 611 of the Act requires TSA to “issue final regulations to ensure the security of foreign and domestic aircraft repair stations” within 240 days (by August 8, 2004).

On February 27, 2004, the TSA held a public meeting concerning repair station security, and asked the questions below. Written responses to the questions were due by March 29, 2004 to the DOT Docket Management System (docket TSA-2004-17131). TSA said that it will later propose security rules.

Exposing vulnerabilities

The Association believes that some of TSA’s questions could publicly expose repair station vulnerabilities, if any, and is deeply concerned that TSA did not afford an entirely confidential comment procedure. Both the TSA meeting and the Docket Management System are open to the public. TSA stated that it will not post confidential information to the public docket, but did not elaborate on this assurance.

TSA questions

1. What security measures are currently in place at foreign and domestic aircraft repair stations? Do you use access control, perimeter security, or identification media? What kind of employee background checks, if any, are conducted on employees prior to hiring, or periodically?

2. What security vulnerabilities do you believe currently exist at foreign and domestic repair stations?

3. What minimum standards should be in place to prevent unauthorized access, tampering, and other security breaches at foreign and domestic aircraft repair stations?

4. What does your current security system cost?

5. Should TSA regulations be tailored to the type of rating the repair station holds, number of employees, proximity to an airport, number of repairs completed, or other characteristics? If so, please explain how that could be accomplished.

6. Should aircraft operators play a role in ensuring that repair facilities maintain a secure workplace? If so, what should aircraft operators do to enhance repair station security?

7. Have you experienced security breaches at your facility? If so, what measures were instituted to prevent recurrence?