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Mr. FITZGERALD. I think there has always been some dispute on the numbers. When FAA estimates that the average access doors are 128 and we wound up with 1,500, you obviously are viewing the problem from such different perspectives.

Mr. OBERSTAR. Are you saying that the FAA based its rulemaking on a grossly smaller number of doors?

Mr. FITZGERALD. I think that they just miscalculated the number of doors that they felt would have to be included in any kind of a program. When we went out and actually investigated the airports, we found many, many more doors.

I think there was a dispute right from the beginning on the physical problems that we would all be facing, and I think Mr. Jackson's testimony summarized the fact that all of the aviation groups were together in their position that this rule should not go forward as it was originally proposed because we needed time to measure the implications and to see where the differences really were in our two positions.

Mr. OBERSTAR. I think my colleagues from New York would want to pursue further the matter of counting doors. But it is a matter of concern, because this very same issue is one that was identified by the Federal Aviation Administration in its international survey of foreign airports as a point of security lapse, and a recommendation was made by the FAA and the Department of Transportation to the other participants in the ICAO conference that more security be provided for doors in the airports. If that isn't being done, then you have a number of people who can obtain access to what should be secured positions or points in the air operations area.

Mr. FITZGERALD. I think that same problem would exist overseas if they used the same criteria, so I think you are absolutely correct in the difficulties involved in trying to secure the doors.

Mr. OBERSTAR. Yes, but the foreign operators don't seem to consider the threat as serious a matter-that is, controlled access doors-as the United States does.

Mr. FITZGERALD. Well, I would have to consider the security today generally to be adequate, but it can be improved. I think where you have a major airport, like Kennedy International Airport, we certainly are committed to doing that. I think when you start viewing the entire country, however, and 270 airports, you do a disservice by treating them all the same way without somehow trying to understand the level of the threat at the various levels of airports.

Mr. OBERSTAR. Certainly, at maximum safety the threat of terrorism can literally shut down all American airports. Even if you tried to restrain yourself to do only those steps that prevent the obvious, you could so hamstring American airports that they would not be operative. I can understand that, so again we are looking at balance.

Haven't airport operators and the airlines been able to agree with the FAA on which are critical access doors and which ones are not?

Mr. FITZGERALD. I would say no.

Mr. OBERSTAR. Is there no standardized approach to this?

Mr. FITZGERALD. We have been talking about this rule for some time, and I don't think we've really made a lot of progress in terms

of trying to get at all of the definitions and what is meant. Even now, with the rule having been issued, we have so many questions on definitions that would impact on the number of doors to be covered that it is still very, very confusing, and that's what concerns us. We certainly are committed to the idea of improving access doors, but we are troubled by the extent of this rule.

Mr. OBERSTAR. Of course, it was not the question of a door in the case of PanAm.

Mr. FITZGERALD. Not at all.

Mr. OBERSTAR. It was a legitimate, open point of entry through the ordinary conduct of business, putting baggage and passengers on board the aircraft, that was the conduit for that destructive device. And apparently that was so in other cases as well. But you do have-and I will conclude, as I am exhausting my time, which I want to reserve for others as well-you do have some 47,000 persons who work on the airport premises. That's a massive undertaking. That's more than some cities, the people who just work there who have access and who need security clearance to access that airport.

Mr. FITZGERALD. And who need the opportunity to be productive. Every time you put a barrier in their way you must pay a price, not only in the capital investment but in lost productivity of people being unable to reach their work locations. That concerns us greatly.

Mr. OBERSTAR. I have seen some very, very secure systems, such as computer reservation systems of certain airlines, where the security is extraordinary. There are numerous kinds-fingerprints, weight identification, eye retina scanning systems. There are at least three or four steps that must be pursued before one person can gain access. That's the ultimate in security. At that rate, we would probably have 15 people a day getting into an airport.

Short of that kind of security at its extreme, for a very legitimate purpose and needed-and, of course, there aren't as many people who need access under those conditions to a secure placehow do you prevent a mechanic, for example, bringing a mechanic's tool box onto the premises that might not have tools but instead might have plastic explosives that can be placed on board an aircraft?

Mr. FITZGERALD. I would say that threat that has never been an area which we were concerned about. That doesn't mean that we might not be concerned about it in the future, but both in the background checks that we do now on airport and airline employees, the kind of supervision that is provided in aeronautical areas, the kind of airlines security systems that they have in place, I feel comfortable that we are doing enough already to keep the likelihood of that at such a small amount that I really feel we need to devote our resources into other areas where there is a much greater threat.

Mr. OBERSTAR. I thank you. My time has expired.

The Chair recognizes the gentleman from New York, Mr. Molinari.

Mr. MOLINARI. Thank you, Mr. Chairman.

I think some very good points have been made by this panel in questioning the feasibility of the rule. These are intriguing questions, listening to those of you who are experts and run airports.

I would like to ask this question. With limited resources, what do you recommend as an alternative which would be a better use of money than these computerized access card systems?

Mr. JACKSON. I'd like to address that if I may, sir.

Mr. MOLINARI. Please, Mr. Jackson.

Mr. JACKSON. We are not saying that the computerized card access system is not a good use for the security aspect of an airport. My airport has had it since 1972. It is an outstanding management tool, but it is very different for every airport. We are all built different. It's just like no two people look exactly alike; no two airports are built alike.

Mr. MOLINARI. Okay. Excuse me if I interrupt. So you're saying that at your airport it is functional, is reasonable, and should be implemented, but not for other airports.

My question then is to the other airports where they wouldn't have the same physical makeup. What would be a better alternative?

Mr. JACKSON. There are a number of systems in use throughout the country. Some do have card access. Šome just have identification badges which must be shown to an individual before they pass through a gate going onto the airside. Some must be funneled through their company operations and use their cards to punch in on a time clock. There are many different methods used to keep individuals out who are not supposed to be in, and to make sure that those people who work inside the AOA are permitted access to that area.

A card access system is just an automated system to do that same sort of thing.

Mr. MOLINARI. I guess I would like to pick up where the Chairman left off. I think his question was, is it your impression that when the FAA proposed this rule they weren't aware of the fact that there are as many access doors at some of the airports that we in fact have?

Mr. JACKSON. Absolutely. They have no conception of the number of doors, or the problems which you may have with certain doors which also have to be fire-life safety doors. They must be openable from the inside but not from the outside. They must be alarmed. The physical cost of $18,000 per door includes all of these costs, plus a base to take care of the major computer that runs the whole system.

As I mentioned, each airport is built differently and the number of doors with access to the AOA is entirely different and must be considered, and was not.

Mr. MOLINARI. Let me turn to New York if I may, Mr. Fitzgerald.

We heard it was 1,500 at Kennedy, 1,000 at Newark, and 750 at LaGuardia. During the hearing process have you brought these figures out? Did you testify at the hearing, or someone on your behalf?

Mr. FITZGERALD. I did not personally testify, but all of these figures were brought out.

Mr. MOLINARI. Have you sat down with the FAA officials to discuss the unique problems that-

Mr. FITZGERALD. Many times. But I think that perhaps they may have been influenced by international events requiring some kind of reaction, and I think there is probably agreement among airport operators that in fact you do need an access system, that in fact it is not a bad thing to have. I think the level of sophistication and the application of technology that they are proposing has different impacts on different airports.

Mr. MOLINARI. All right, then we get back to the question I asked previously. What do you recommend?

Mr. FITZGERALD. I would recommend that we go with our pilot program and, based on the four airports that are selected-you could select large airports and small airports, and I think that you could develop a system such that at the end of the test period it would have application to all 279 airports. And then, I think, you would be able to make a sensible recommendation on commitment of resources for all of the airports. Right now I just think we're moving too quickly and not knowing exactly where we are going. Mr. MOLINARI. But it's possible, if you put in this pilot program that you suggest, that after a test maybe it would make sense to adopt this program that is not the subject of the rulemaking?

Mr. FITZGERALD. It might make sense, but I think that if we had some more time we would at least answer some questions on technology. Right now we're not even sure of the proper technology to use to implement the various requirements of the rule.

So I really think it's a question of time and it's a question of trying really to adapt the system to meet the needs of the various types of airports across the United States, and then we can all commit with a sense that we're not wasting money, that a few years from now we might have to go back in and change all over again.

Mr. LALLY. If I could add to that-

Mr. MOLINARI. Yes, Mr. Lally, go ahead.

Mr. LALLY. From the standpoint of the airlines, the airlines share the concerns of the airport operators with respect to this rule, even though the rule is directed to the airport operators and not the airlines. The airlines did join with the rest of the aviation community in petitioning FAA and DOT for an approach different from the one that has taken place, namely, the pilot project.

One of the principal concerns of the airlines in addition to the cost and the operational impacts is that there is no provision stated by the Federal Government for compatibility, compatibility among airports and compatibility between airports and tenant organizations.

Now, we have a system requirement in place now that impacts every airport that comprises the National Air Transportation System, 269 airports, every airport served by a scheduled air carrier. When we undertake an impact like that without considering the desirability or lack of desirability or degree of compatibility expected, then I think we're moving a little bit too fast. I think the issue of compatibility, so that we don't have a totally fragmented National Air Transportation System when it comes to access controls, is a real danger here.

So we agree that there needs to be further study, and the airlines are willing to participate in that study effort.

Mr. MOLINARI. That's interesting. Do you think there may be a reason for not wanting compatibility throughout the system? In other words, if somebody has an access card and they are free to use it anywhere in the country, is that desirable?

Mr. LALLY. No, I don't think that's the reason. I have not heard that stated as a reason for not treating compatibility.

The problem that the airlines face, to take an extreme example, is that an airline flight crew may serve 12 airports in one day and may end up having to have 12 different types of access control cards to serve those airports, to arrive and depart. With the program going the way it is, directed to 269 airports without some guidance as to compatibility, that risk exists. Advice as to compatibility would seem to us to minimize that risk and provide for some degree of consistency.

Mr. MOLINARI. I guess what the panel is saying is that collectively you believe there is an overreaction on the part of the FAA to whatever problem is out there today. Is that a fair statement? I see most of you nodding yes.

Mr. KOLTER. Would the gentleman yield on that point?
Mr. MOLINARI. I'd be glad to yield.

Mr. KOLTER. I listened intently to your most interesting testimony relative to lack of uniformity, and I can understand that. Now we're talking about compatibility, which is something totally different. Yet you say that if you had a pilot program for a given period of time over four airports, that uniformity and compatibility could be worked out. Is that what you're trying to say?

Mr. FITZGERALD. I would say that I think we would better understand the issues, because I don't think today that we understand them in light of the technology that is available to manage those issues. At the end of the pilot program we could very well face the same problem we face now, but I don't really believe that. I think we need to find a technology that will answer everyone's questions. We don't have that answer today.

I think the danger exists that we could select a system in response to this rule, and a year from now find out that we committed the resources to buy a computer system that doesn't have the ability to meet these other issues that will come up to us in the future. That's the concern.

Mr. KOLTER. So you think that perhaps somewhere in the future we can conclude that there will be something invented, something that we could use, which could be an answer to our problem here? You know what the problem is here and now. I don't see what further study would do. The problem is here. I can't see further study. I don't understand what you're trying to do here.

Mr. FITZGERALD. I think it's a matter of having compatibility as only one single issue, and I think there are so many issues that relate to how areas on the airport-for instance, a cargo area—are supposed to be controlled. That is really undefined today. How is a general aviation area-many of the airports in this country today have a majority of general aviation flights-supposed to be managed? When you have an airport with 500 members of a flying club who come in to use the facilities on weekends, should the airport

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