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Appendix B
Current TSA GA Security Requirements
The following requirements have been established by TSA as noted by the
Transportation Sector Network Management, Office of General Aviation, and as
reported by AOPA.13 Although the scope of the review did not require that we
evaluate each TSA GA security requirement, we believe that current TSA GA
requirements represent a good strategic approach.
Airspace Waivers
According to TSA records, the Office of Airspace Waivers manages the process and
assists with the review of GA aircraft operators who ask to enter restricted
airspace. Each waiver applicant is required to provide his or her last and first
names, Social Security number, and date and place of birth. This information
allows the Office of Airspace Waivers to vet the applicants for subsequent
approval or denial to fly into restricted airspace. Applications must be filed
for aircraft operating into, out of, within, and flying over the United States.
The process also includes an evaluation of the aircraft, crew, passengers, and
purpose of the flight. The application is then adjudicated and recommended for
approval or denial to the FAA, Office of Air Traffic Services. The FAA shares
the responsibility for managing the waivers with TSA. The FAA asserts the safety
provisions, while TSA manages the security portion of the process. Airspace
waivers help to mitigate the threat of an airborne attack.
Flight School Security Regulations
The Interim Final Rule at 49 CFR 1522.23(d), Flight Training for Aliens and
Other Designated Individuals: Security Awareness Training for Flight School
Employees, requires flight schools to ensure that all of their flight, ground,
and chief instructors, as well as administrative personnel who have direct
contact with students, receive both initial and recurrent security awareness
training. Flight schools may choose to use the TSA security awareness program or
develop their own. If a flight school chooses to develop its own program, the
program must adhere to the standards in the rule.
Current Security Programs
Secure Fixed Base Operator Program
The TSA Secure Fixed Base Operator Program was launched on December 31, 2007,
with industry partner Signature Flight Support, at Anchorage, Alaska, and
Shannon, Ireland. This public-private partnership program allows FBOs to check
passenger and crew identification against manifests or, as of May 18, 2009, the
Electronic Advance Passenger Information System. The latter is a U.S. Customs
and Border Protection web-based application that collects electronic traveler
manifest information from commercial carriers for international flights arriving
in or departing from the United States. The system then passes manifests to
Customs and Border Protection through the Advance Passenger Information System.
According to a TSA official, “working in close coordination with industry
partners, TSA believes that this security initiative will provide additional
security for flights inbound to the United States. The broader application of
such programs will provide robust security while maintaining operational
flexibility for general aviation operators.”
Twelve-Five Standard Security Program
The Twelve-Five Standard Security Program (TFSSP) requires that certain aircraft
operators using aircraft with a maximum takeoff weight of 12,500 pounds or more
execute a security program. Operators were required to
be in compliance with the program effective April 1, 2003.
Private Charter Standard Security Program
The Private Charter Standard Security Program (PCSSP) requires operators to
execute a security program, but adds additional requirements for aircraft
operators who use aircraft with a maximum takeoff weight of more than 100,309
pounds or with a seating configuration for 61 or more passengers. Operators were
required to be in compliance with the program effective April 1, 2003.
This program subjects operators of large charter aircraft to the same processes
that are associated with commercial passenger aviation, including passenger
screening through metal detection devices, x ray systems for carry-on and
checked luggage, and a certified passenger and baggage screening workforce.14
Large Aircraft Security Program
TSA has issued a Notice of Proposed Rulemaking that seeks to amend the TFSSP and
PCSSP and apply new security requirements to all aircraft weighing more than
12,500 pounds. In addition, TSA proposes that airports serving large aircraft
should adopt mandatory security requirements. Among the requirements in the
proposal, the major
provisions for aircraft operators include criminal history record checks and
security threat assessments for flight crew, checking passenger names against
the TSA’s No-Fly and Selectee lists, developing a security
program, and biennial auditing of the security program. Additionally, the
proposal would require approximately 320 airports designated by the Department
of Transportation as “reliever” airports, and airports that regularly serve
scheduled or public charter operations in large aircraft, to adopt a “partial”
airport security program that would include specific training, record retention,
personnel, and notification requirements.
The GA industry asked TSA to extend the period for public comment on the
agency’s Large Aircraft Security Program (LASP) proposal by 60 days. As a result
of the extension, the new deadline for public comment was
February 27, 2009. LASP would require U.S. operators of aircraft exceeding
12,500 pounds takeoff weight to implement a security program much like that for
charter operators of large aircraft, described above in the section on the PCSSP.
The proposed LASP rule would add requirements for large aircraft operators and
some airports receiving those aircraft. In addition, large aircraft operators
would be required to submit to compliance
audits of their security programs using TSA-approved auditors and to verify that
their passengers are not on the No Fly or Selectee portions of the consolidated
terrorist watch list maintained by the federal government through the use of a
TSA-approved watch list provider.15
Many GA organizations vigorously oppose LASP. Melding the TFSSP into the much
more elaborate PCSSP would push existing security efforts for the largest
charter flights down to many smaller aircraft involved in corporate and private
aviation.
Rules for the Aviation Community
Washington Reagan National Airport Access Standard Security Program
TSA Interim Final Rule, 49 CFR (Parts 1520, 1540, and 1562), developed in
coordination with other DHS agencies and the Department of Defense, takes into
consideration the special security needs of Washington Reagan National Airport (DCA).
Under the TSA security plan, 48 GA flights per day are allowed in and out of
Washington Reagan National Airport. All GA aircraft are required to meet the
security measures set forth in the Washington Reagan National Airport Access
Standard Security Program. To meet security measures, TSA is to conduct a series
of steps, which include an inspection of crew, passengers, accessible and
checked property, and the aircraft. Passenger and crew manifests are to be
submitted 24 hours in advance of each flight. TSA is to execute enhanced
background checks for all passengers and fingerprint-based criminal history
records check for flight crew. There is to be an armed security officer on board
each flight. All Washington Reagan National Airport Access Standard Security
Program flights must depart from an approved gateway airport (an airport
authorized by TSA to “send” GA flights to DCA). According to TSA, there are 21
approved gateway airports.
Maryland-Three Program
The Maryland-Three Program allows properly vetted private pilots to fly to,
from, or between the three GA airports within the National Capital Region. These
airports are College Park Airport, Potomac Airfield, and Hyde Executive Field,
and all are located within the Washington, DC Metropolitan FRZ.
GA Community Several Security Advisories
According to TSA officials, TSA has provided the GA community advisories to
execute security requirements. TSA encourages GA aircraft and airport owners and
operators to consider securing unattended aircraft to prevent unauthorized use
and verify the identification of crew and passengers prior to departure. TSA
also advises the GA community to verify that baggage and cargo are known to the
persons on board. Where identification systems exist, TSA requests the GA
community to encourage employees to wear proper identification and challenge
persons not wearing proper identification. At one GA facility in Chicago,
airport security officials punish employees who do not properly display their
airport identification. The penalties range from a verbal warning to dismissal.
It is also stressed that they be aware of and report persons whose
identification appears altered or inconsistent.
TSA stresses to the GA community that it must direct increased vigilance to
unknown pilots or clients for aircraft or helicopter rental or charters, as well
as to unknown service and delivery personnel. TSA emphasizes that the GA
community must be aware of and report the following: individuals impersonating
pilots, security personnel, emergency medical technicians,
or other uniformed airport personnel using vehicles to gain access to aviation
facilities or aircraft; aircraft with unusual or unauthorized modifications;
persons loitering in the vicinity of aircraft or air operations areas, persons
loading unusual or unauthorized payload onto aircraft, or persons who exhibit
odd behavior.
Security Initiatives
General Aviation Hotline and Airport Watch
TSA has developed and implemented a GA Hotline, 866-GA-SECURE (1-866-427-3287),
in partnership with the National Response Center. The hotline serves as a
centralized reporting system for GA pilots, airport operators, and maintenance
technicians to report suspicious activity at their airfield.
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The hotline was
developed in coordination with AOPA to complement the AOPA Airport Watch
program “Lock Up, Look Out” (Figure 9). According to an AOPA official,
this program enlists the support of approximately 550,000 GA pilots to
watch for and report suspicious activities that might have security
implications. According to an AOPA official, AOPA has distributed
Airport Watch materials to 5,400 public- use GA airports, several pilot
groups, and thousands of individual pilots. The program provides special
materials, including a video to train pilots to be alert for suspicious
people or activities on the airport. Members of the working group reviewed numerous GA airport security recommendations and industry best practices. The result of this effort was the Report of the Aviation Security Advisory Committee Working Group on Aviation Airports Security, available at http://www.tsa.gov/assets/pdf/ASAC_Working_Group_11-2003.pdf. |
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On November 17, 2003, the Aviation Security Advisory Committee formally transmitted the report’s recommendations to TSA. TSA used this report as a baseline from which to create the “Security Guidelines for General Aviation Airports.” These federally endorsed guidelines are used to enhance security at GA facilities throughout the Nation by addressing aviation security concepts, technology, and enhancements.
TSA Access Certification
TSA launched a pilot project in cooperation with the National Business Aviation
Association at Teterboro Airport and Morristown Municipal Airport in New Jersey
and White Plains Airport in New York. The initiative was to provide a “proof of
concept” to validate a National Business Aviation Association-proposed security
protocol, which led to the TSA Access Certification and a corporate waiver for
certain types of operations, such as international flights to and from the
United States. Phase I of the pilot program was completed on June 30, 2003.
Phase II was completed on December 31, 2003.
Recommended Security Action Items for Fixed Base Operators
These Security Action Items were created for FBOs. Most of these measures
complement the guidance in the May 2004 Security Guidelines for General Aviation
Airports. TSA has confirmed the value of these measures during discussions,
outreach sessions, and security reviews with partners representing FBOs. The
security action items are presented in six categories: (1) general security
measures, (2) FBO security coordinator, (3) FBO training outline, (4) aircraft
security, (5) transient pilots, and (6) reporting suspicious activity.
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