Here is the comment that I just submitted to the feds (better late than never!). (Disclaimer: It's not my finest work.):
I would like to direct my comments for Docket No.
TSA-2013-0004 towards two areas of the AIT rule. First, I object on privacy
grounds, and, second, I object on safety grounds to the implementation of AIT
screening. My recommendation is that the AIT screening program be stopped
immediately.
In part IB of the NPRM (Summary of Major Provisions), it
says, “AIT currently provides the best available opportunity to detect
non-metallic anomalies concealed under clothing without touching the
passenger…” followed by, “TSA implemented stringent safeguards to protect the
privacy of passengers undergoing AIT screening when AIT units were initially
deployed and enhanced privacy further by upgrading it millimeter wave AIT units
with ATR software.” As a modest woman who also chooses to raise her children to
be modest, I strongly feel that these two statements are contradictory and can
not be reconciled. If you are viewing anything under my clothing, or the
clothing of my daughter or son, then you are not protecting my privacy. It does
not matter to me that the area under my clothing is not seen directly with the
naked eye of an individual that I can see, or if a machine is viewing the area
under my clothing and transmitting that image either to an individual in
another room or to a software program that interprets the image.
This goes to a very fundamental aspect of humanity and, in
particular, to a prevalent strain of modesty in America culture bridging across
people of various faiths, ethnicities, and backgrounds. Humans wear clothes not
only for decorative reasons, but also, and, in some cases, especially, in order
to be modest. Anything under the clothes is intentionally hidden, not intended
to be viewed by man or machine without express consent (that is, uncoerced
undressing). It is, in practice, impossible to take protect passenger privacy
while simultaneously forcibly viewing anything that is under passengers’
clothes.
