Let's take a look at these new rules that become effective on 20 October UNLESS
we do something about.
Comments on the interim final rule are due by October 20, 2004, and may be
filed electronically at http://dms.dot.gov. Comments must be identified by
TSA's docket number: TSA-2004-19147.

How many flight instructors have you had training with? Would you like each one
of them to have a copy of your birth certificate for 5 years as proof that you
are a US citizen? And by the way a US birth certificate does not show
citizenship but it certainly does show birthday, place of birth, full name of
parents and of course the maiden name of your mother. Is that something that
you would like every single instructor that you have ever had an appointment
with to have for 5 years. Quite a risk for identity theft I'd say.

But let's say that ALL US citizens are willing to prove their citizenship to
any instructor and don't mind copy of the birth certificate being kept by the
instructor for 5 years. Since the many are so willing to sacrifice for
punishment of the few, the next applicability is of course the US resident
alien who has a pilot certificate and bought an SR22.

Now this US resident alien calls me at 2 pm and would like to do some
night/instrument/avionics software work since he's concerned that he is very
close to out of currency for night landings, and he would like his avioncis
software skill level to be better.

Of course this is the part where some of you feel this rule is sound judgment.
I meet with the US resident alien in the lobby of whatever FBO. But we can't
hop in the airplane as there are according to you and the TSA some minor
insignificant things to take care of first.

I of course have to make a copy his passport, visa, his resident alien card,
copy of his previous training documentation, training documentation for what
the recurrent training is this evening (i guess I'll make a copy of FAR 61, 91,
43, TSO 129, Avidyne Entegra and Emax5000 and Garmin 430 pilots guides), and
after I've made copies of all these documents, I have to take a picture of him
standing in the FBO lobby when he arrives for his appointment. Sounds like a
mug shot with the salient booking desk.

So now I have approximately 100 pages of documentation that I made copies with
the new color copier that TSA is going to buy for me, and took a photograph of
this US resident alien with the cannon 5 megapixel digital camera again that
the TSA is going to buy for me, and email/fax/voice it all to the TSA with the
fax machine/laptop that the TSA is of course going to buy for me.

And after all this material/photo/voice notification is sent to the TSA about
this US resident alien who wants to get some night currency out of the way, and
the US resident alien had such a good time learning from me plus this very
unique experience right there in the FBO lobby, he decides that he would like
another appointment tomorrow evening which of course means I have to do the
same thing all over again.

I"m flabbergasted that many of you have read these rules and could not see how
unworkable they are, and that is even before we get to the privacy issues of
ALL US citizen pilots, and how many violations of 4th, 14th amendments just for
the due process alone.

To say nothing of the indignity/maltreatment of the client who has US resident
alien status, and worse of all the TSA shoving all the
responsibility/accountability of this rule onto the flight instructors. I would
not want to be treated that way, and I don't want the TSA telling me I have to
treat people that way.

This rule will plain & simple make every US resident alien pilot give up his
aircraft. It makes the training appointments (supposed to be fun) something
that is dreaded more than being arrested for DUI.

Please explain why you are perfectly willing to go along with all aspects of
this new rule, especially the part of forking over a copy of your birth
certificate to every instructor that you might do business with. And of course
if TSA interprets that this rule is constitutional in the handling of US
resident aliens, what plans does it have for ALL US pilots, citizen or
otherwise?

My several phone calls yesterday with the TSA such as Dion Casey (571-227-2663)
and Mike Derrick (571-227-1198) all had one thing in common. They kept on
telling me that I really should not worry how this will effect my flying
because it is applicable only to non-US citizen pilots. And it really does not
make a difference how inconvenient it would be for a US resident alien to do
some night recurrency work, they don't deserve pilot privileges anyway.

This from the agency that envisioned CAPPS to do a credit history check on
every passenger and to keep record of the
passenger/ticket/purchase/address/social security number/phone number/flight
for 50 years.

(d) Category 4—Recurrent training for all aircraft. Prior to beginning
recurrent training for a candidate, a flight school must—

(1) Notify TSA that the candidate has requested such recurrent training; and

(2) Submit to TSA, in a form and manner acceptable to TSA:

(i) The candidate's full name, including any aliases used by the candidate or
variations in the spelling of the candidate's name;

(ii) Any unique student identification number issued to the candidate by the
Department of Justice or TSA;

(iii) A copy of the candidate's current, unexpired passport and visa;

(iv) The candidate's current U.S. pilot certificate, certificate number, and
type rating(s);

(v) The type of training for which the candidate is applying;

(vi) The date of the candidate's prior recurrent training, if any, and a copy
of the training form documenting that recurrent training;

(vii) The candidate's requested dates of training; and

(viii) A photograph of the candidate taken when the candidate arrives at the
flight school for flight training.


Paul K. Sanchez, CFII-MEI, CSIP
305-389-1742



paul k. sanchez, cfii-mei
on eagles’ wings
10643 shore drive
boca raton, florida 33428-5645
305-389-1742 wireless
561-852-6779 home/fax