My reading of the regs is that you do need a tsp.
The regs aren't too bad to get around (not great but seen worse
) There's the Transport Security Act 2004 and the Transport security Regulations 2005. Google them for the comlaw website and download.
The revelant regs describe a prescribed air service as an air service that Uses a jet. The act says that an air service is using an aircraft to transport pax or goods.
Yes, telling DOTARS where to so might not be your best move.