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First and foremost, the federal government, led by the FAA, must define the threat against which we are securing our airports. The early 1970's "hijack-to-Cuba" threat which was the initial impetus for passenger x-ray screening, and the disgruntled employee's "internal threat", have been replaced by the threat from international terrorists seeking to make a political statement against a government...generally the United States. Nothing in the FAA's new rule would have in any way prevented the Pan Am 103 disaster, and it is our view that the PSA employee incident on which the rule was based was a once-in-60-year aberration which does not in itself justify a potential multi-billion dollar security system which in all likelihood would not have stopped the tragedy.

Following an identification of the true threats, the federal government should strengthen its program of research and development. We have suggested to the FAA and to several Congressional panels that a federal pilot security program at five airports of varying size, traffic levels, and configuration would help identify the equipment and methodologies which work...and equally important, those which do not work well, in a functioning airport environment. Further, it would allow airports to build their systems based on proven technology which concentrates on "real-world" data for airport security systems and technology.

In virtually every case, commercial airports are owned and operated by a state or local governmental entity, which has neither the budget to comply with the rule, nor the fiscal incentive to engage in what amounts to a federally mandated trial-and-error security R&D program. Therefore, for the control of threats which may be due to problems of access control, AOCI recommends a $12 million, five-airport, 18-month pilot program which would identify, install and test in an operational environment the systems and technology which could enhance airport security in accord with the FAA-required process.

The report accompanying the Appropriations bill last year encouraged the FAA to institute a pilot program to develop a rational approach to airport security. Unfortunately, they did not follow Congress' advice. We urge you to follow up on that proposal. We still believe it is in the best interests of everyone for a pilot program to establish the best technology, for the best and most effective systems, at the most cost-effective price. We also ask you to exercise close oversight of the FAA in its implementation of the rule, to see that the agency addresses the concerns we have raised.

The FY'90 FAA budget for all aviation-related security R&D is $9.1 million. This is inadequate even to complete several needed security R&D projects already underway. AOCI has outlined below the additional amounts necessary to complete these projects under an expanded and accelerated program, along with an estimated time of completion of research, engineering and development for each.

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The breakdown of the AOCI funding proposals are as follows:

o Thermal Neutron Activation (TNA) explosives detection:

$2.6 million to develop a mobile system (26 months); $2.5 million to adapt the system to inspect carry-on bags (26 months);

o Vapor Detection systems:

$4.2 million to develop a passenger walk-through

system, (18 months);
$4.0 million to develop a carry-on bag system
(21 months);

$2.5 million for a checked-baggage system, (22
months);

$1.7 million for a portable system, (25 months).

In addition, there are new concepts being tested by FAA at the Technical Center in Atlantic City which should be explored more rapidly. They include:

$1.6 million for bio-technology research on

micro-organisms which react to explosive vapors (31 months);

$3.3 million for development of gamma ray absorption explosive detection techniques (34 months);

$3.2 million for active millimeter wave inspection

techniques for non-metallic substances, such as drugs, explosives and weapons (30 months);

$1.1 million for bottle-content inspection, to

identify liquid explosives (22 months);

$0.7 million for development of x-ray enhancement
software to correlate separate images
of independently carried items (12 months).

Certain other proposals which deserve added attention and funding include:

$0.75 million for investigation of new x-ray

techniques such as "low Z" imaging to identify specific chemical compounds by their atomic signature;

$1.25 million to develop knowledge-based expert

computer systems to improve identification profiles of high-risk passengers, cargo and baggage;

$2.0 million for human factors research to improve the performance of screener personnel;

$1.50 million for improved developments in bomb-proof baggage lockers in non-sterile areas.

AOCI recognizes that a great deal of security research and development is being pursued by many government agencies, and the possibility for overlap exists. Therefore, we recommend the formation of an ad hoc interagency working group to identify those areas which overlap, and where such duplication is found, to recommend a lead agency to help achieve significant cost and time savings. The group would be made up of FAA, Customs, U.S. Marshals Service, FBI, CIA, DEA, the armed forces, and certain foreign governments.

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The federal government must accelerate R&D work in these areas to expedite the development of sensible and effective systems and technology for aviation security.

These projects require an additional $10.3 million for FT "90, [plus $22.6 million spread over FT 91-92]. A FT'90 total of $22.3 million in newly appropriated funds is needed for security RED. This additional amount includes $12 million for a five-airport access control pilot program. We believe this

need, as important as it is, should not be met by diminishing the amounts for the other FAA R,EtD we have identified. Maw funds are needed.

The rule estimates a total cost for access control systems at all 270 airports to be just under $170 million over ten years. However, AOCI's and industry estimates reveal the actual costs may be ten times that amount, because the FAA has looked only at initial equipment costs, while ignoring such costs as retrofitting terminal facilities with compatible door frames, doors, hardware, new wiring and conduit, and CCTV monitor systems and wiring at remote perimeter sites. Other peripheral, but expensive problems to be solved include asbestos abatement requirements at older facilities, and compatibility with state and local fire and safety regulations which might require these newly-locked doors to be easily opened in case of emergency.

Thus, if we accept that we must do what the rule suggests, vague as it may be, we must divert the money immediately from some other effort in order to meet the very short time frame required by the rule. In such a short time, will there be sufficient funding available? Will the market have a sufficient quantity of appropriate technology available, and if not, will -the price of the limited number of systems available be bid up to meet deadlines? Perhaps airports will be forced instead to design their systems around available, but lower quality and/or less reliable, equipment, as well as inexperienced contractors to install and/or maintain the systems. This will hardly enhance security.

The FAA has stated that it intends to make available to assist airports in implementing the rule $28 million for FY89, and $38 million for FY90, as set-asides from existing discretionary AIP funds. Given that those funds total only about $100 million each year for all capacity, safety and security grants, about a third of all such funds must now be shunted to paying for security systems which, due to the uncertainty of the requirements, are unlikely to do the intended job. And, of course, those funds go only to a few successful grant applicants; other airports must raise the rest of the money must from some other unidentified source.

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INNOVATIVE AIRPORT FINANCING TOOLS

We need funding to implement these projects. The Airport Improvement Program (AIP) is clearly inadequate to meet these needs. At present, the traditional airport funding sources— AIP grants and tax-exempt bonds—provide about $1 billion less annually than airports need to finance long-term planned projects. But in recognizing the federal budget dilemma, AOCI has developed a new funding initiative which could provide substantially greater funds for airports with minimal, if any, impact on the federal budget deficit. This initiative has been endorsed by our member airports across the country, and we hope Congress will give it serious consideration.

Our proposal is to create a Federal Airport Revolving Loan Fund to provide loans from the Trust Fund surplus for airport capacity, security, safety and noise projects. These loans would provide an additional $1 billion annually for airports to supplement AIP funding and provide a reliable source of funds for many important projects, including security. Most important, the RLF would eventually become a self-sufficient source of funds on which airports could rely for years to come. This would be done by channeling the repayments of such loans into an off-budget account which would then provide a separate, self-supporting source of loan money for airport development.

AOCI believes that the current method of levying fines for security violations creates an adversarial relationship between FAA and the airports and air carriers, to the detriment of security. We are not opposed to fines per se; they may add to the level of awareness at each facility that the government cares about the quality of the service being offered, and intends to continue monitoring.

We believe, however, that FAA could improve this situation in two ways: one, FAA could de-emphasize.the punitive attitude toward fining airports and carriers for security violations, and instead work directly with them to "fix" the system component that failed during the inspection process. Second, if FAA must continue to levy fines, money received from these fines could be applied to air carrier and/or airport security either directly, through grants for security-enhancement projects, or through more FAA security-related research and development. These options would enhance security teamwork, rather than increasing antagonism and reducing funds available to airports and airlines to bolster security.

FURTHER MEASDRE8 FOR FAA TO PURSUE

Pending the application of universal security standards, FAA should impose the same security requirements on foreign carriers serving the United States that it already imposes on U.S. carriers. FAA's ultimate goal, obviously, should be to

FINES

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