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TSA Proposal for Large Aircraft Security Program Applicable to General Aviation Aircraft

The comment period to the Transportation Security Administration’s  Notice of Proposed Rulemaking has ended.   TSA has proposed that a Large Aircraft Security Program be implemented covering general aviation aircraft in excess of 12,500 pounds MTOW.   Highlights of the proposal are as follows:

–Each general aviation operator (including corporate and private operators) would be required to adopt a large aircraft security program based upon the current program that applies to operators providing scheduled or charter services.  The LASP would be provided by TSA.

—  A biennial audit by a TSA-approved auditor would be required of an operator’s compliance with the security program and TSA regulations.

—  Matching of passengers against watch lists  would be required before a flight can depart.  Operators would need to use a TSA-approved watchlist service provider to conduct the matching.

—  Criminal History Records Checks and Security Threat Assessments on flight crewmembers

— The use of Federal air marshalls if required by TSA

— Compliance with the prohibited items list

— Compliance with Security Directives (not currently required of general aviation operators)

— Designation of an Aircraft Operator Security Coordinator, In-Flight Security Coordinator or Ground Security Coordinator (as planned, one person cannot serve in more than 2 roles per flight)

— Security training for flight crewmembers and covered employees

— Development and maintenance of contingency plans to respond to threats

The LASP proposal will impose significant additional cost and bureaucracy to an already embattled industry.  Several comments were filed in response to the NPRM.  The National Business Aviation Association’s comment letter gives a comprehensive analysis of the applicability of the proposals to general aviation operators and offers less intrusive alternatives to those proposed by TSA.    The following link is to the full text of the NBAA letter:  NBAA LASP Comment Letter.

General Aviation Security

Even if you believe that your operations are secure, it is worth having an independent security expert evaluate your operations.  Even the most basic of procedures can assist with identifying exposure.  For example:

— Employee/Vendor Screening and Credentialing

— Security Threat Assessments

— Review of operations center policies and procedures

— Review of intrusion detection and perimeter security systems

— CCTV and Security Systems Integration

—  Review of access control systems

— Threat assessments associated with international travel

Although we do not endorse any particular provider, we are pleased to refer our clients to security professionals appropriate to their particular needs.

About Lapayowker Jet Counsel, P.A..:

Based in Fort Lauderdale, Fla., the law firm of Lapayowker Jet Counsel, P.A.. focuses its practice on private and corporate aviation transactions worldwide, including throughout the United States, South America, the European Union, Asia and the Middle East. The firm regularly assists clients with a variety of issues related to aviation, including the sale, purchase, regulatory analyses, financing and management of corporate aircraft.

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