However,

The FAA must address this issue! We understand the need for confidentiality in such sensitive matters and believe that much of the discussion should not be for public consumption. that is no excuse for developing regulations in a vacuum without the opportunity for those affected to discuss legitimate problems and concerns behind closed doors.

There are other problems:

cargo facilities?

Should we not also be concerned about Where is the responsibility of an exclusive

use tenant (airline)? How much responsibility for security passes between the airport and non-aviation tenants such as food service, concessions, or maintenance personnel? The rule does

not address these issues.

We must also note that the rule is totally silent on the compatibility of such systems from one airport to another. The very nature of aviation is that anyone is but a few hours from any point on the globe. Yet there is no guidance offered as to whether, for example, the crew of any given airline which stops at seven cities in the course of a day will have to carry seven different access cards today (and seven different ones tomorrow). Nor is there any guidance given as to just how a discharged employee will have his termination announced to the 270 systems at other airports "immediately" a term which the FAA also declines to define. To further compound the problem, airports are receiving equally ambiguous, and often conflicting, guidance from FAA's regional offices. We find it virtually impossible to design a system which has no boundaries, and no guidance.

Forcing 270 airports to spend millions of dollars to install access control systems over a period of 30 months when the FAA is unable to answer many questions concerning interpretation and requirements of their own rule is neither prudent nor the most effective approach to increase security.

Having made our point about the ambiguity of the rule's requirements, we move on to the obvious next step: if we accept that we must do what the rule suggests, vague as it may be, we then face the immediate problem of how to pay for these systems and meet the very short time frame required. Unless Congress and the Federal Government provides additional funding to help airports meet this new requirement, monies will have to be diverted from other important airport safety, security and capacity projects.

FAA has stated that it intends to make available from Airport Improvement Program funds only about $28 million for FY '89, and $38 million for FY '90. This money would come out of already limited discretionary funds (approximately $115 million) at the expense of other important projects. of course, those funds would go only to the few successful grant applicants; other airports must somehow find funding from some other unidentified source. If it is in the national interest to require access control systems at all U.S. airports, then it is certainly the Federal Government's responsibility to provide funding assistance from the available Aviation Trust Fund monies to implement these systems.

Given such a short and unrealistic timeframe for compliance, it is clear that sufficient funding will not be 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.

We strongly urge this Subcommittee to closely monitor and give further guidance to the FAA as it implements the rule. AOCI, ATA and AAAE urged DOT/FAA to first conduct a pilot program and operational testing of automated access control systems to establish the best technology and design, gain operational and monitoring experience, and provide the framework for developing the most effective systems for application at other airports. Unfortunately, DOT/FAA did not heed our concerns. We still believe it is in the best interests of everyone to have a pilot program and operational testing to identify system and

operational problems and develop the most effective systems for various airports before requiring extensive, expensive systems at all airports.

FAA/Airport/Airline Cooperation

Our efforts to combat terrorism requires concerted action and cooperation by the Federal Government, airports and air carriers. However, the current method of FAA levying fines for security violations often 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 deemphasize the punitive attitude toward fining airports and carriers for security violations, and instead work directly with them to remedy the system component that failed during the inspection process. Second, if FAA must continue to levy fines, money received from these fines should 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.

Recommendations for Federal Government Action

AOCI strongly endorses the current FAA security-related research and development program, and we urge this Subcommittee to give its full support to those efforts that enhance aviation security. In addition, we recommend initiation of work on human factors to

We

improve passenger screening, and the development of devices to detect non-metallic weapons, such as plastic handguns. commend the Congress for enacting a law banning plastic weapons; now we need the detection systems to ensure enforcement.

AOCI applauded former FAA Administrator McArtor's decision last December, to accelerate delivery of thermal neutron analysis devices. At FAA's research, engineering and development conference in early December, AOCI and the airline industry had asked FAA to take this step.

We urge this Subcommittee to provide greater emphasis and resources to FAA for the development of vapor detection

technology for the inspection of checked and hand-carried baggage and cargo. FAA has had promising results from tests of vapor detection equipment, which offer enormous benefit in the detection of weapons and explosives as well as interdiction of contraband and illegal drugs. There are certainly some problems with the systems which are not appropriate to discuss in open hearings, but vapor detection and thermal neutron analysis are potentially the most productive efforts FAA could make to enhance air transport security.

AOCI also compliments FAA for commissioning work at BaltimoreWashington International Airport to find areas where security can be improved beyond current levels. This underscores our point that pilot programs can be effective in developing procedural and equipment improvements to reduce security risks, without