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.