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While security is a high priority item, it only receives about five percent of the FAA's total R&D budget. More resources must be made available.

We are fully behind the current effort to refine and further develop the thermal neutron analysis system to alert authorities to plastic explosives, and there may be other significant projects with the potential of responding to threats against aviation, and their development must also be adequately funded.

FAA must continue to assess the vulnerability of international and domestic airports to current threats. This essential first step allows both the FAA and the airport operator to determine what measures are required to effectively respond.

Mr. Chairman, airport executives will be the first to applaud efforts which add real improvements to aviation security. But we are most concerned about the recent rule requiring the top 269 airports to install access control systems at all areas leading to aircraft operating areas. In other words, every door in an airport which has access to the aircraft parking area must be controlled, undoubtedly by some form of computerized system.

AAAE is generally supportive of the concept, but there are several unanswered questions. First and most importantly, we wonder whether the millions of dollars that will be spent over the next few years to install these systems could not be used on more appropriate measures, like explosive detection devices.

Airports are not against spending millions of dollars and focusing our attention to improve security. We simply want to use those funds for the highest quality product possible.

Secondly, there is a concern about the compatibility of these systems. If this new regulation is to provide meaningful security improvements, it must assure standardization of technology and compatibility of systems among airports and between airports and airlines. Without commonality, air crews which require access through protected doors at hundreds of airports might need different security access cards at each city.

Other horror stories regarding fire codes, cargo areas, joint use military bases, and airports with large non-commercial activities are easily imagined.

The Federal government needs to take the lead in providing basic guidelines which do not disqualify vendors from bidding, but which will permit the airport owner to have a greater degree of comfort in the effectiveness of the end product.

Some have suggested the development of a machine similar to the automatic teller which permits the use of a number of cards both in and out of the host bank.

FAA must re-evaluate its recent policy decision, which in effect will force airports into roles of surrogate regulators of their tenants. Any effective security system must force the individual airport tenants to accept the ultimate responsibility and accountability for the security of exclusively leased areas.

To make a third party, such as the airport operator, responsible for violations in areas they cannot monitor and cannot control is naive and unreasonable.

The U.S. Congress must provide dedicated funding for these systems outside of the regular airport improvement program. The in

dustry estimates that computerized systems as are mandated by the new rule could cost the taxpayers as much as $900 million in capital costs over the next ten years. That same money would buy over 1,000 TNA systems, an average of five for every U.S. airport covered by the rule.

If only entitlement or discretionary funds are used to pay for these systems, it will force airports to forego other equally important security, safety, or capacity improvements now in their capital improvement programs.

We also urge the FAA to build in additional time for system plan approval and implementation. The current plan does not adequately provide for a realistic evaluation of these systems. The limited domestic airport experience in this area, coupled with limited resources of expertise, requires an orderly and practical work plan. Finally, Mr. Chairman, AAAE suggests that DOT and FAA revisit the rule particularly with regard to conducting a pilot program at several high risk airports. Problems with compatibility, installation, and responsibility can be addressed at that time.

Groups such as AAAE, ATA, AOCI, and others have requested a meeting with Secretary Skinner. That session should be scheduled as soon as possible.

AAAE stands ready to work with the Congress, the FAA, the airlines, and other users to devise and install systems and procedures to provide effective improvements to our aviation security program. We must use common sense and expend our resources where they will be the most effective in deterring those intent on harming the traveling public.

Thank you again for providing us the opportunity to express our views on this important subject.

[The statement follows:]

STATEMENT OF THE AMERICAN ASSOCIATION OF AIRPORT EXECUTIVES

Good Morning Mr. Chairman and members of the subcommittee. I am Michael J. Kutchins, director of aviation for the city of San Antonio, Texas, and a past president of the American Association of Airport Executives (AAAE). On behalf of the AAAE board and our membership, I would like to thank you for this opportunity to testify on aviation security.

AAAE is the largest professional organization for airport executives, representing over 1,400 airport management personnel responsible for the planning, management and operation of 650 airports in the U.S. Our membership is truly representative of airport management. It is neither "big airport" nor "small airport" oriented, since it includes the executives of large and medium size airports as well as hundreds of managers from smaller facilities, many of which are used exclusively by general aviation or regional airports.

Our words today may give little comfort to the victims' families of Pan Am Flight 103, but we sincerely offer our condolences.

We commend you and your colleagues for holding this hearing. The tragedy of Pan Am Flight 103 deserves the attention of the U.S. Congress, the administration and the aviation industry. Safe and secure transport of air travelers must be the top priority of everyone, including us, the airport managers. To fail to act in response to such a tragedy would be a dishonor to the victims, their families and a breach of faith with all Americans who fly by air.

First, AAAE commends Transportation Secretary Skinner for his recent announcements to enhance the effectiveness of our security measures at home and across the globe. We also applaud Ray Salazar, the Federal Aviation Administration's (FAA) security chief, and his staff for their important contributions to improving security. Even though we do not agree with FAA all of the time on security issues, Ray and his people are always willing to listen to our concerns.

Mr. Chairman, when our aviation security system works as it should, very little attention is paid by the media and the general public to security measures. Indeed, those that are visible to the public are often regarded as an inconvenience. But in the unfortunate instance when security is breached, "Monday morning quarterbacks"-the so-called security experts-emerge from the woodwork to criticize the system.

FAA said recently, "The increase in criminal activities targeted at aviation, the sophistication of techniques and technologies employed in these illegal activities and the potentially deadly and costly consequences of aviation security violations, have strengthened the importance of civil aviation security as a major mission area of the FAA." We could not agree more. AAAE and its members have always been active participants in the efforts to improve security at our Nation's airports. The airports and airlines take security very seriously and will continue to cooperate with FAA on implementing programs that will improve security procedures.

It is virtually impossible, however, to perceive and prevent every threat to our aviation system. If someone is intent on violating security procedures, he will find a way to succeed. It is impossible to design an air transportation system capable of processing over 450 million passengers a year-let alone all the visitors that accompany each passenger to the airport-and give 100 percent assurance that nothing will every happen. The only way to unequivocally guarantee an impenetrable security system is to shut the air transportation system down. In a democratic society that guarantees the freedom of movement, we must find security measures that do not unreasonably impinge on that right.

We can't ground all the airplanes, so what do we do? Realistically, the most that can be done is to design and implement procedures and systems that will meet the real security threat, not some improbable "what if" fantasy.

A pro-active approach to designing systems that solve tomorrow's security problems must include a major and aggressive research and development (R&D) program by the Federal Government. Yet, the current R&D budget for security is only about 5 percent of the FAA's total R&D budget. More R&D funding for FAA security programs must be made available by Congress if we are to make any progress. For instance, we are fully behind the current R&D effort to further develop effective explosive detection devices, such as the thermal neutron analysis, that will alert authorities to plastic explosives contained in checked luggage and carry on bags, and those carried on board by a passenger. This is a very worthwhile project, one that we believe appropriately addresses the most pressing threats in the security arena. There may be other significant projects that have the potential of responding to threats against aviation, and funding should be made available so that these areas can be examined as well.

FAA must continue to conduct studies to assess the vulnerability of international and U.S. airports to current threats. This essential first step allows both FAA and the airport operator to assess properly just what measures are required to deal with perceived threats effectively. This also allows FAA, in close cooperation with the airports and airlines, to determine the best way to employ "state of the art” technologies and operational procedures in the most economically viable and responsive manner. You simply put your resources where they will do the most good.

Mr. Chairman, airport executives will be first to stand up and applaud efforts that will add real improvements to aviation security. However, we are most concerned about the recent rule requiring the top 269 U.S. airports to install computerized access doorsystems at all areas leading to aircraft operating areas. In other words, every door at an airport which employees use to gain access to the aircraft ramp areas, must be converted to a computerized, locked door that only opens to control card entry. AAAE is generally supportive of the concept, but there are several unanswered questions that we believe will eventually undermine the intent and effectiveness of the present regulation.

First, and most importantly, we wonder whether the millions of dollars that will be spent over the next few years to install these systems could not be used on more appropriate measures, such as explosive detection devices. In our society, everything has a price tag. Public officials are no longer in the position of spending unlimited tax monies on every conceivable security or safety program. Choices must be made. This rule is no different. Mr. Chairman, please be assured that airport executives are not against spending millions of dollars and focusing our attention to improve security. It is simply a matter of the priority for limited funds, and limited expert time, available to the industry.

Second, there is the concern about the compatibility of these computerized security systems. If this new regulation is to provide meaningful security improvements, it must assure standardization of the access technology and compatibility of systems

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among airports and between airports and airlines. Without commonality, each airport could select a totally different card-reading or keypad system. As a result, airline crews would have to carry a different identification card for each airport they pass through, making these systems entirely inefficient and quite possibly unsecure. The Federal Government needs to take the lead in providing a basic operating system that does not disqualify vendors from bidding on these systems but will allow these computers to speak to each other in the same language. We are not computer experts, but question why we can not develop a compatible system similar to the ATM bank machine which allows one to use the same card for every ATM bank machine location. Compatibility is a major deficiency in this rule.

Third, FAA must reevaluate a recent policy decision that, in effect will force airports into roles of surrogate regulators of the various tenants operating on airports, even military installations on airports. Any effective security system must force individual tenants of an airport-airlines, fixed base operators, air cargo companiesto be ultimately responsible and accountable for the security of their exclusive areas. To make a third party, such as the airport operator, responsible for violations in areas they cannot monitor and control 24 hours a day is naive and unreasonable. Anything less will create more problems than it will solve.

Fourth, the U.S. Congress must provide dedicated funding for these access systems outside the regular airport improvement program. The industry estimates that these computerized systems could cost the taxpayers as much as $900 million, excluding general maintenance, over the next 10 years. (That same amount of money would buy approximately 1,100 thermal neutron analysis systems, an average of five systems for every U.S. airport covered by this rule.) In fact, the costs could soar over $1 billion because the final rule encompasses all buildings at an airport, not just the terminal facility, as proposed in the original NPRM. Entitlement or discretionary funds used to pay for these systems will force airports to forego other equally important security or safety improvements at their facilities. There must be dedicated funding so that we do not sacrifice other critical safety projects at our Nation's airports.

And, fifth, even though FAA built in some additional time for system plan approval and implementation at smaller airports, the overall time requirements contained in the final regulation are not adequate to provide for a realistic evaluation of these systems. The limited domestic airport experience in this area, coupled with the limited sources of expertise, requires an orderly and practical work plan. As it stands now, many airports, because of the tight timeframes and their own budget procedures and constraints, will install wrong systems that eventually will have to be replaced at a considerable cost to the taxpayers. A more realistic timeframe will avoid having to "reinvent the wheel".

What is the practical impact of the rule as it now stands? Simply stated, an operational nightmare. For example, in hundreds of communities, the airport is operated on a 24-hour basis, even though the fixed based operator (FBO) is closed some of that time. This means that if a general aviation aircraft flies into one of these airports during periods when the FBO is closed, once the pilot and his or her passengers, such as you, Mr. Chairman, exits the plane, he or she is in violation of the airport's security program unless they have an airport-issued ID.

Air ambulances and other life-saving missions which regularly operate 24 hours a day also would be unable to enter and exit the airport when time is of the essence unless they have a valid ID. When FAA was questioned on this subject, the response was that general aviation areas of the airport should be physically separated from the rest of the airport by a perimeter fence or some other obstacle to prevent unauthorized access. This seems all well and good until you inquire about the best way to taxi an aircraft through a 10-foot-hight barbed wire fence.

Finally, at airports where the National Guard or another active duty military base operates, each and every military member that enters the base would be required to be badged by the Airport in order to receive unescorted access to the base. As you know, Mr. Chairman, security at an air force base with front line fighters or aircraft far exceeds and FAA requirement. Under this regulation, however, these military personnel would still have to have an airport ID, even though they will be nowhere near commercial aircraft.

Mr. Chairman and members of the subcommittee, AAAE stands ready to work with Congress, the airlines, other users and the FAA to devise and install systems and procedures that will provide real-not cosmetic-improvements to our aviation security program. Anything less would be a disservice to the traveling public. But in our fervor to address security issues, we must use common sense and expend our resources where they will be the most effective in deterring those who are intent on

doing harm to the traveling public. Thank you again for providing us with this opportunity to express our views on the important issue of security.

Senator FORD. Thank you, Mr. Kutchins.

Mr. Lally, let me see if I have you straight. After reading your statement prior to this hearing I asked Secretary Skinner about your assertion that there was only ten percent of FAA's security positioned in areas where 90 percent of the terrorist acts occurred. Secretary Skinner indicated that he did not want to give the number nor the location, but gave the impression that that would be beefed up even beyond where it is now.

Does the attitude and direction of the Secretary seem to fit with your concern?

Mr. LALLY. I think the direction does, Mr. Chairman. I feel, though, that perhaps the implementation will not go far enough.

I think what we need in view of the threat is an adequate permanent assignment, perhaps starting on a temporary duty basis, of FAA security experts at high risk airports served by U.S. carriers. There are 45 such high risk airports in Europe, in the Middle East, and Far East at the present time.

I believe that those are the same airports that are subject to FAA's foreign airport assessment program. If these airports are high risk, then they are entitled to such foreign assessments on a more frequent basis.

If the presence of the FAA inspectors were made permanent, those assessments would become permanent, and at the same time those FAA people could perform primary duties of assisting U.S. carriers in maintaining adequate security programs within those host airports and of also working closely with the host governments to make sure that all security at the airport is orchestrated effectively.

Senator FORD. How many members at these 45 high risk airports of the FAA security would you think would be adequate?

Mr. LALLY. We have not done an estimate of that, sir. But an estimate could be done and I would be happy to try to submit one. Senator FORD. Well, you were very emphatic about it is not adequate, and yet you do not know what adequate is. It may be in the eye of the beholder.

Mr. LALLY. Well, I stand to be corrected on this, but I would say of those 45 airports there are not more than a couple that have any FAA assignment presence.

Senator FORD. That means that there is practically nil at most of them then. Is what you are saying to this Senator?

Mr. LALLY. For purposes of the functions I was describing. There are FAA inspectors that traverse those airports and go in and out. We are really espousing an expanded role for the FAA inspector, to expand beyond compliance inspections to perform positive and continuing coordinated, cooperative functions of assisting the carriers on a full-time basis.

Senator FORD. Your statement indicated that you felt like the Federal government should pay for the TNA's. Am I correct in that?

Mr. LALLY. Yes, sir.

Senator FORD. What will be the alternatives if the funds from the aviation trust fund are not made available?

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