On October 2, 2008, the Transportation Security Administration ("TSA") issued a 260-page notice of proposed rulemaking ("NPRM") entitled "Large Aircraft Security Program, Other Operator Security Program, and Airport Operator Security Program." This NPRM proposes to require all aircraft operations using aircraft with a maximum certificated takeoff weight of more than 12,500 pounds to adopt a TSA approved security plan. According to the TSA, if enacted, the amount of operators required to operate under a security program would increase from approximately 650 to approximately 10,000.