| Below are comments submitted by NRA in response to the Department of Transportation`s request for public comment on authorizing pilots to carry firearms in flight. |
February 13, 2002
Public Docket Office
Department of Transportation
400 seventh Street, SW
Room PL-401
Washington, DC 20590-001
RE: Comment of Docket No. FAA-2001-111229
Dear Sir or Madam:
On behalf of the National Rifle Association of America, Inc., I am writing to respond to several of the questions posed in the notice concerning pilots carrying firearms into the cockpit of aircraft providing of interstate air transportation.
1. Whether pilots and other flight crew members should carry firearms or less-than-lethal weapons, and if so whether it should be on a voluntary basis.
Response: Pilots should be permitted, and encouraged, but not mandated, to carry mid-range caliber (.38/.40/.45 caliber/9mm) handguns of their choice while in the cockpit. Other flight crew members should be permitted, but not mandated, to carry less lethal devices if the devices are concealed on their persons.
2. Whether and how the weapons should be stored on the aircraft or carried on board.
Response: Pilots, co-pilots, and flight engineers who choose to carry handguns in the cockpit should keep the handguns with them at all times while going to and from the cockpit and within immediate reach while in the cockpit, either on their persons or in a secure, but accessible, location in the cockpit. Handguns should not be stored in the aircraft for two reasons: one, if they are stored, they may be accessed by someone other than the pilot; and two, a pilot should be trained with a specific handgun so that he becomes familiar and comfortable with its use; having it with him when he is flying will help him develop familiarity and provide him the opportunity to practice when not flying.
5. The types and numbers of firearms that should be carried on aircraft for use by qualified pilots and the types of ammunition.
Response: Each pilot, co-pilot, and flight engineer should be authorized to carry one or two mid-range caliber (.38/.40/.45 caliber/9 mm) handguns, as he chooses. The handguns may be either revolvers or semi-automatics, as selected by the pilot, although the pilot should be authorized to carry only the specific handgun(s) loaded with the same ammunition with which he has completed training and qualified. The ammunition must be of a type that is readily commercially available (so that pilots may practice regularly) and uses a bullet which rapidly dissipates its energy, which could be either a pre-fragmented or frangible bullet (e.g., Glaser Safety) or a soft-nosed bullet designed to expand rapidly.
6. The amount and type of weapons training that we should require, including whether there should be initial and recurrent training.
Response: Pilots should receive, as part of their air carrier sponsored training, the same training given to the sky marshals and at FAA expense. For a pilot without prior experience with firearms, such training (which is widely available) would generally not exceed five (5) days; for a pilot with prior experience, the training could take as little as one (1) or two (2) days. Pilots should also receive recurrent training on the same schedule as the sky marshals or, at a minimum, semi-annually. Air carriers’ operating certificates should be conditioned on a policy of permitting pilots to attend firearms training and pilots must be paid. The time associated with firearms training should be treated in the same fashion as flight training.
7. How the less-than-lethal weapons and firearms should be carried, stored, maintained (if necessary), and accessed on the aircraft.
Response: See # 2 with respect to carrying and storage on the aircraft. As to storage off the aircraft, the FAA must provide lock boxes at each airline’s Operation Center so that if pilots are unable to take their firearms off the airport premises, there will be a secure place of storage. With respect to maintenance, as the handguns would be owned by the pilots, the pilots should be responsible for maintenance of their own handguns.
8. Whether the qualifications for using less-than-lethal weapons for firearms should be integrated into the existing systems for establishing and maintaining airman qualifications, such as pilot certificates and ratings.
Response: Qualifications for carrying firearms should not be integrated into the existing systems for establishing and maintaining airman qualifications as pilots should only carry firearms on a voluntary basis.
In closing, the NRA would urge that hearings be held at which experts in the fields of firearms and ammunition and firearms training could testify and be available to respond to specific technical questions.
Sincerely yours,
Christopher A. Conte
Legislative Counsel
NRA/ILA
February 19, 2002
Public Docket Office
Department of Transportation
400 Seventh Street, SW
Room PL-401
Washington, DC 20590-001
RE: Supplemental Comment of Docket No. FAA-2001-111229
This follows our prior comments submitted on the above item. By substitution we offer the attached copy of our prior comments which merely corrects some typographical errors only. In addendum, we offer the following observation on administrative options for implementation.
Supplemental Comment-Deputizing Pilots
Although not directly addressed by the request for comment, it is NRA’s belief that facilitating the implementation of allowing commercial airline pilots to be armed has an administrative as well as technical and practical component. To that end, we recommend pilots who have been trained and certified under FAA guidelines to be armed, should also be deputized as Federal Sky Marshals. This step alone would provide the following benefits:
1. Provide direct FAA supervision and control of pilots acting in the capacity as armed guardians of their flights;
2. Allow pilots access to training and equipment otherwise exclusively reserved to Sky Marshals;
3. Alleviate liability concerns of the airlines and, perhaps more importantly their insurers, regarding the arming of pilots in their role as Sky Marshals;
4. Allow for the optimum coordination of career and deputy Sky Marshals to cover more flights;
5. Extend the Sky Marshal Program at the lowest possible cost to FAA and airlines.
We hope these suggestions are helpful. If we can be of any further assistance, please do not hesitate to contact us.
Very truly yours,
Christopher A. Conte
Legislative Counsel
NRA/ILA
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