General Aviation Security

Status Report- November 26th, 2001

Prepared by Art Kosatka ACP-200 November 26,2001

Briefmg for ACS-1 Paul Busick

SECURITY ISSUES for GENERAL AVIATION

Introduction:

Sec. 132(b) of the Aviation and Transportation Security Act states: General Aviation Program: Within 30 days after the date of enactment of this Act, the Under Secretary of Transportation for Transportation Security shall transmit a report on airspace and other security measures that can be deployed, as necessary, to improve general aviation security to [the Committees].

There has been an extended effort to resolve these issues by an FAA Task Force consisting of Security Policy & Planning, Security Operations, Air Traffic, Flight Standards, Airports, General Counsel, Rule making, and others. The group has met repeatedly with delegations of most of the industry alphabet groups, including NATA, NBAA, AOPA, NASAO, Maryland Dept. of ~'Viation, and representatives of the individual airports, among others, and has continuing contact with other smaller interest groups. Other Federal agencies involved in the discussions include US Secret Service and NSC representatives.

While there have been several interim agreements on various segments of the proposals, implementation of several has been delayed or overtaken by such intervening events as the shut-down of airspace around nuclear sites, which also encompassed numerous GA airports nationwide.

The current DRAFT Air Traffic Services strategy is found in Attachment A, which addresses the details grouped by issues, and Attachment B, which summarizes the same required activities grouped chronologically in a now outdated draft letter to the Deputy Secretary. Most issues contained therein reflect current agreement except those surrounding LEO presence at the six affected Maryland airports. The strategy document also contains several remaining TBD procedural developments by FAA security.

Additional Background:

For purposes of this discussion of general aviation security, the term General Aviation is described essentially as anything that does not include certificate holders under Parts 121, 129, 135, or have Part 108 security programs. This includes

• FAR Part 91 operations • Airports serving non-1 08 carriers and private aircraft • Business Aviation (Mobil Oil, General Motors) • Some operations to and from small airports may or may not be included: • Certain Part 135 air taxi operations • Private aircraft and helicopters • Private pilots and owners • Flight instruction

Irregular or infrequent "orphan" operations: • News and traffic reporting • Pipeline survey • Ban- 2 -ner towing • Photogrammetric survey • Sight seeing • Open air assemblies (more than lOk) • Blimps and airships • Sport or demonstration parachutes Summary:

ECBandTFR:

The 9/11 events caused all general aviation to remain shut down nationwide for a relatively brief period. In a few days, most US airspace was re-opened to general aviation, although FAA created Enhanced Class B (ECB) airspace around 35 major airports and Temporary Flight Restrictions (TFR) zones around BOS, JFK and DCA airports, with additional security constraints imposed for operations within those spaces:

Flight plan file required Pre-established arrive/depart corridors Discrete transponder code No flight training above 6,000 lbs. Two way radio communications A TC clearance

The TFR areas imposed for 25 NM surrounding BOS, JFK, and DCA, have since been reduced to 15NM at BOS and l8NM at JFK and DCA. These three have been the focus of the vast majority of attention and discussion in the intervening weeks; all three remain under tight constraints, with DCA the tightest, and the subject of considerable FAA debate with USSS and NSC, among others.

Note: Sec. 146 of the new legislation (Attachment C) would nullify all ECB 's "and any 1 other notice issued after Sept. 11 h ••• " within 30 days of written request of any aircraft operator. This may have the eventual effect of superceding all task force efforts in opening all GA operations iffinal agreement cannot be reached and implemented soon, and may also have the parallel effect ofgenerating large-scale short-term FAA efforts to respond on behalf of SEC-DOT to multiple individual petitions ifFAA wishes to retain such constraints where necessary.

The legislation specifies only ECBs, but it is not clear if TFRs might be included in the language " ... or any other notice issued after Sept. 1 J'h ... ". The Act is also silent on how this would apply to conflicting USSSI NSC concerns, whether USSS has an over-riding authority, and ifso, how it would be implemented.

GA Industry Perspective:

In general, GA aircraft and the airports that serve them are not regulated parties for security purposes. although there have been discussions suggesting some movement in that directioll,. Indeed, Section 132(b) cited above appears to anticipate continued attention to this issue by Congress. Industry bas been extremely cooperative and understanding of the need for additional security. The associations have been quite active in preparing recommended security "best practices" for all GA communities to follow although perhaps in anticipation of possibly stricter FAA regulation if self-supervision was not successful. AAAE and ATA have instituted a task force to meet in December for security at GA airports; it is not clear the extent to which other GA community will participate or endorse the effort, nor bas FAA participation been requested to date.

The AOPA internet publication (Attachment F, AOPA e-Pilot) also points out that the new legislation carries no security mandates on GA at all, although it alludes to a "study on GA security" which presumably refers to the required report to Congress. It further urges pilots to take advantage of the clause offering relief within the ECB's by writing to DOT Secretary Mineta, address enclosed.

There were additional constraints placed on numerous GA airports and flights when temporary measures were imposed for a 10 NM radius surrounding all US nuclear sites, which halted the general effort to open airspace to GA in mid-process. All the nuclear site restrictions have since been removed due to the lapse of credible threat information, but the re-opening process bas not been reinstated.

It should be noted that one significant complaint about this type of temporary and ill defined flight restriction, aside from the presumed lack of threat, is that they are rarely identified with respect to navaid fixes, so it is extremely difficult for even the best equipped pilots to locate and avoid the "no-fly" zones except possibly for those equipped with GPS, which is by no means universal, nor were such GPS fixes provided in the NOTAM. Another universal complaint from industry is that small aircraft and their load­ carrying capacity are not perceived as a significant threat, nor has there been any credible threat information suggesting they should be treated as one. AOPA threatens to take the issue "to the highest government officials" if the pending plan is not quickly acted upon [Attachment F, AOPA e-Pilot].

Inconsistent Command and Control

It is generally conceded that GA security to date has been pursued in a very fragmented and uncoordinated ad hoc manner, with no one office having either the mandate or the manpower to follow through. When agreement has been reached, the resulting bureaucratic clearances both in FAA and other agencies has been slow in coming, usually with changes requiring further debate, and changes in personnel requiring re­ orientation in previous matters. The entire process has been under way for well over a month; the current draft has been awaiting a response from the Deputy Secretary DOT for well over a week, and efforts to get on his calendar have failed. USSS has been in agreement with full release of the airspace between 18 and 25 NM at DCA for quite some time, but final clearance at DOT has not been granted. Without a clear picture of the political influences involved. or a clear delegation of authority for decision-making and approvals, most efforts have been a best-guess at what might be approveq at higher levels, and then a wait- and-see for feedback and corrections, which are slow at best. ' ·

Lack ofFAA authority and/or a mandate of urgency and priorities has allowed the process in this instance to be driven more at the insistence and much slower pace of USSS and NSC, rather than by FAA security concerns and demands on staff to "get GA flying". FAA security has, throughout the process, been amenable to generally less restrictive measures. Many of the proposals would have created operational constraints on ATC, but have nonetheless been quickly accommodated by A TC with workable, albeit painful short tenn alternatives [arrival and departure corridors, cut-outs for close-in airports and VFR corridor operations, shortage of discrete transponder codes, etc.)

Further, there is no national plan in place for re-instituting GA security controls nationwide if another major terrorist event demanded such a move, short of another total shutdown. (Recall a similar "no-plan" condition during the Gulf War period, which resulted in the issuance of confusing and relatively ineffective guidance for the A VSEC measures, which are still in place and require updating.) Indeed, it is not yet clear whether such a one-size-fits-all plan would be appropriate for any non-specific GA-based threat, or whether there is any significant enhancement in security by restricting flight operations of GA aircraft under 12,500 lbs., although there should be ground and operational controls on larger aircraft. [See Attachment G, draft by Jan Brecht-Clark of S-60]

DCATFR

The largest single remaining problem is the situation surrounding DCA; its TFR encompasses 6 GA airports in the State of Maryland. Two of those airports are within approximately 8NM of DCA (and relatively near Andrews AFB), the others are closer to the periphery of the boundary. Ail have been the subject of intense push-back from USSS, and have thus remained shut down (with the exception ofEMS, LEO and military flights which operate under specific waivers).

There have been numerous interim proposals for fuller opening of the airspace that gained various degrees of acceptance among the affected parties and the governmental entities; but due primarily to USSS concerns none have been implemented to date.

The most recent drafts include a mix of proposals from industry associations and participating FAA offices, and recommends a redesigned airspace around DCA, roughly elliptical (15NM x 13NM), and having the effect of removing three affected airports [Suburban, Freeway and Maryland] from the TFR, while the remaining three [Hyde, Potomac and College Park] would require additional exceptional security measures before being allowed to reopen. For based aircraft, these include an inventory of approved airoraft and pilots, physical control of aircraft (locks), verification of pilot identities, inspection of departing aircraft by qualified LEO, specified arrive/depart routings, and off-hour guard patrols. For arriving aircraft, interim stops at designated portal airports would be established for the verification and inspection of any aircraft inbound to the controlled airports. The proposed portals are Montgomery County Airpark (Gaithersburg), Lee Airport (Annapolis), and Maryland Airport (St. Mary's County).

The portal concept was endorsed by the Maryland Aviation Administration, and reluctantly agreed to by the industry groups and the airports themselves, based on MAA's assurances that the State could provide LEOs for a very limited time (2-3 weeks max), and the further assumptions that the program could be put in place immediately at that time (well over a month ago) and that it would be replaced by a "better'' plan at that time. The draft SFAR and the accompanying proposed security program language for portal airports and airports within the TFR are discussed below. (Attachments D & E)

The State of Maryland has now advised it is not able to provide the LEOs, in large part due to other commitments of State police and National Guard. USSS indicates that use ofNational Guard would be acceptable if they are armed and have arrest authority, which authority has now been determined to be the case under USC Title 32 mobilization requirements. Determination is pending from FAA Airports office whether LEO funding might be available from the $1.5 billion federal "bailout" reimbursements for losses suffered due to 9/11. A question remains whether coverage of this kind of fmancial impact (future costs to keep airports open, rather then past losses suffered from their closing) is eligible in that package

Finally, at DCA itself, USSS remains opposed to~ GA flights of any kind unless all measures which apply to FAR 108 operations are also applied to those GA flights: access controls, screening of passengers and baggage, armed LEO/F AM (not private security) on board inbound and outbound.

Additional Requirements

It should be noted that there are other pending requirements of the legislation which may or may not apply to segments of GA security, including I

• Report to Congress on GA security within 30 days; today's report might serve as the basis; • Implementation of a security program within 90 days for charters under 12,500 lbs. Assignment of this task, or the necessary preliminary programs development, is not yet clear (ACP-1 00?); • "Overseeing security at airports", {Sec. 101] which ultimately may or may not include GA airports; • TSA authority for designation of LEO officers comparable to DOJ, which might be used at GA airports; • Biometrics pilot programs, which might serve security purposes at GA facilities, such as remote ID validation, video surveillance; • R&D grants, which might include alternatives procedures and/or technology for GA; • Background checks on GA Airport employees, and possibly pilots, if the anticipated programs are put in place; • AlP eligibility determination for " ... security related activity required by law ... ", which would likely include GA- note the language says "activity", which theoretically could include new construction, upgrades of technology, background checks, guard services, etc.; • Resources to respond to requests for relief from Enhanced Class B restrictions; • Air Traffic Services Strategy Revised 11/2c02001 7:47AM

In the first few days after September 11th, the FAA struggled with many challenges. First and foremost was reopening the airports serving major airlines and getting people flying again. At the same time, we had to do this against the backdrop of unprecedented security risks. We have been largely successful in returning commercial operations to the air, however there is one segment of the aviation community where many restrictions are still imposed - general aviation.

The first general aviation (Part 91) operations were not approved until three days after the terrorist events, when Instrument Flight Rules (IFR) operations only were authorized -the vast majority of Part 91 operations take place under Visual Flight Rules (VFR). Significant additional Part 91 operations were not &ithorized until almost a week later when flight restrictions were lifted for U.S. and Canadian registered Part 91 aircraft, with many exceptions for certain types of operations. It wasn't until October 9 that more progress was made for Part 91 operations, allowing flight training operations for certain weight classes within Enhanced Class B and within the airspace outside of 18 nautical miles of the Washington, DC and New York Temporary Flight Restriction (TFR) areas. In mid-October VFR operations were authorized within 27 Enhanced Class B airspace areas, provided the operator met certain requirements.

To date, the following types of operations have not been allowed to fly within any Enhanced Class B or TFR: traffic watch, news reporting, banner tow, blimps or airships, and sight seeing for hire. There are restrictions in all airspace for flight training operations for aircraft weighing over 12,500 pounds, VFR Part 91 operations within the Boston TFR, and any general aviation activities within the Washington, DC TFR or into Washington Reagan National Airport. Additionally, these types of operations have been banned with only a few waivers granted: foreign registry aircraft (except to exit the country with no intermediate stops), general aviation operations within the New York TFR, and overflights or manufacturer and production test flights for aircraft weighing over 95,000 pounds. Also, guidance to pilots to avoid circling, loitering, or unpredictable flight paths, along with the restriction to avoid "major open assemblies of people" naturally restricts additional types of operations (e.g. demonstration parachute jumps and aerial photography).

What follows is the FAA's strategy to authorize additional general aviation operations, while allowing for national security interests. These proposals have been coordinated and approved by FAA Security, National Security Council, Homeland Security, the Secret Service, and the Department of Defense. Issue: Class B Airspace

There are 27 major metropolitan areas encompassed by Enhanced Class B airspace that we believe could return to normal Class B airspace. Class B airspace requires aircraft to have a two-way radio capable of communications with Air Traffic Control (ATC), and to be equipped with an operating transponder with altitude reporting capability. This transponder enables the air traffic controller to observe the aircraft's position, speed and altitude at all times while operating in these areas. In addition, all aircraft must obtain an ATC clearance before operating in Class B airspace.

Currently, operators in Enhanced Class B must also monitor guard frequency (121.5 or 243.0) at all times. Also, Enhanced Class B airspace rules prohibit the following types of operations: news reporting and traffic watch, blimp/airship operations, sightseeing for hire or compensation, and banner tow operations. Flight training operations are limited to single and multi-engine non-turbojet powered aircraft weighing 6000 pounds or less.

Strategy to Restore

+ The week of November 26,2001 restore 27 Enhanced Class B airspace areas to Class B airspace, and allow those operations that were specifically restricted from operating within Enhanced Class B Airspace.

Class B Airspace Areas:

Houston, Texas Kansas City, Missouri Memphis, Tennessee New Orleans, Louisiana St. Louis, Missouri Cleveland, Ohio Dallas-Fort Worth, Texas Honolulu, Hawaii Minneapolis, Minnesota Phoenix, Arizona Charlotte, North Carolina Cincinnati, Ohio Covington, Kentucky Salt Lake City, Utah Tampa, Florida Atlanta, Georgia Los Angeles, California Las Vegas, Nevada Miami, Florida San Francisco, California Denver, Colorado Pittsburgh, Pennsylvania Philadelphia, Pennsylvania San Diego, California Detroit, Michigan Orlando, Florida Chicago, lllinois

The benefit of returning the airspace to Class B would be that 27 cities go back to pre-September 11 operations- returning to normal (with only a few minor exceptions).

2 Issue: TFR airspace between the 18 and 25 nautical mile (NM) in New York, and Washington, DC and between the 15 and 25 nautical mile (NM) in Boston

Currently, no Part 91 or Part 137 operations are authoriz~ within 18NM ofthe DCA or JFK VOR, or within 15NM of the BOS VOR.

Between 18 NM and 25 NM (or 15NM and 25NM for Boston), Part 91 and 137 operations have been limited to: • fustrument Flight Rules (IFR) with flight plans filed at least one hour in advance. When operating IFR, the operator is required to follow a specific route and altitude as prescribed by ATC, and to remain in two-way communications at all times. It also requires an operating transponder so that ATC can track the aircraft's progress and note any deviations from route or altitude. • The only Visual Flight Rules (VFR) operations permitted are flight training operations for single and multi-engine non-turbojet'powered aircraft weighing 4000 pounds or less. Flight training means training received from a certified flight instructor.

Strategy to Restore

The proposed changes would allow general aviation to fly up to 18NM from downtown Washington, DC, and New York and 15NM from downtown Boston. It would allow VFR operations and additional flight training previously not authorized at five airports in Washington, DC (Lee Airport, Montgomery County Airpark, Tipton Airport, Davis Airport, and Washington Dulles futemational Airport), three airports in New York (Linden, Teterboro, and Republic Airports) and three airports in Boston (Laurence G. Hanscom Field, and Beverly and Norwood Memorial Airports).

+ The week of November 26, 2001 TFR airspace between the 18 and 25 NM in New York, and Washington, DC and between the IS and 25 NM in Boston reverts to Class B airspace.

Class B airspace, which overlies thirty major metropolitan areas, requires the aircraft to have a two-way radio capable of communications with Air Traffic Control (ATC), and to be equipped with an operating transponder with altitude reporting capability. This transponder enables the air traffic controller to observe the aircraft's position, speed and altitude at all times while operating in these areas. In addition, all aircraft must obtain an ATC clearance before operating in Class B airspace.

We believe this is acceptable because Class B airspace rules already require all aircraft to have an operating transponder with mode C capability and permission to enter. All aircraft within Class B airspace will be tracked. The upper lateral limits of Class B airspace extend at least thirty miles from each site.

3 Issue: Washington, DC, New York and Boston TFR's

When the Washington, DC TFR is reduced from 25NM to 18 NM there will still be six public-use airports within the Washington, DC TFR (Maryland, Suburban, Freeway, College Park and Washington Executive/Hyde Airports, and Potomac Airpark) where Part 91 and Part 137 (agricultural) operations are totally banned from operating. This proposal would allow general aviation operations (with restrictions) at these remaining airports.

Strategy to Restore Washington, DC

+ The week of December 3, 2001, The Washington, DC TFR is reduced from 18NM to 15 statute miles from the DCA VOR.

For Part 91, Part 137 and Part 135 operations at College Pw;k Airport, Washington Executive/Hyde Airport and Potomac Airpark the following would apply:

Phase 1 The week of December 3, 2001 (or when the State ofMaryland advises they are able to implement the following surface security procedures): Home-based aircraft will be allowed to operate at the airport under the following restrictions, and after the airport proprietor provides the FAA with a list of aircraft numbers and authorized owner/operators.

(Special Federal Aviation Regulation (SFAR) to be published) Departure Procedures:

);:> Air Traffic Procedures: o A flight plan must be filed with Leesburg AFSS. o ATC clearance required. o Exiting the TFR limited to established departure route/corridor. o Discrete transponder code required. o Two-way communications required.

);:> Surface Security Procedures: o An armed Law Enforcement Officer at the site to cross­ reference airmen certificate, medical certificate, government issued photo identification and aircraft owner/operator list. o Cabin and baggage inspection to determine no threats on board the aircraft. (Inspection must be performed immediately prior to departure.) o Limited operational hours.

4 o A roving security patrol or disablement of the runway (example: parked vehicles on the runway) during non­ operational hours.

Arrival Procedures:

~ All arriving aircraft will be required to enter the TFR through "portal airports" to be named by the State of Maryland.

~ Those aircraft that depart from either College Park, Washington Executive/Hyde or Potomac and remain with ATC for the entire duration of their flight will not be required to land at the portal airports prior to entering the TFR (may not land outside the TFR).

~ For all other arrivals • Air Traffic Procedures: , o A flight plan must be filed with Leesburg AFSS. o ATC clearance required. o Entering the TFR limited to established arrival route/corridor. o Discrete transponder code required. o Two-way communications required.

• Surface Security Procedures: o An armed Law Enforcement Officer at the site to cross­ reference airmen certificate, medical certificate, government issued photo identification and aircraft owner/operator list. o Cabin and baggage inspection to determine no threats on board the aircraft. (Inspection must be performed immediately prior to departure.)

Phase 2 The week of December 10, 2001 (or 7 days after implementing Phase 1): All aircraft will be allowed to operate at the airport, provided the above departure and arrival procedures are met.

Phase3 Date to be determined: Surface security procedures will be eliminated provided sufficient long-term security measures (as determined by FAA security) are in place.

Note 1: No practice operations in the traffic pattern will be allowed at College Park.

Note 2: Secret Service will determine when ramp freezes are necessary to protect presidential or state movements at Washington Executive/Hyde and Potomac. This will be communicated through Andrews ATCT.

5 The benefit of opening these airports is clear. Airport operators and services that are on the brink of bankruptcy will be allowed to re-open their businesses. Aircraft that have 1 been sitting idle since September ll h will return to the air. Our security interests believe that a 15 statute mile TFR, along with the surface security and procedural restrictions imposed on operations within are sufficient to maintain national security and to protect the interests of the Capitol area underlying the TFR.

Strategy to Restore New York and Boston

Currently, no Part 91 or Part 137 operations are authorized within 18NM of the JFK VOR or within 15NM of the BOS VOR.

+ The week of November 27,2001 New York and Boston TFR's will revert to Class B airspace. New York will retain a INM, 3000' AGL and below TFR around the accident site.

In New York, a 1NM TFR over ground zero will protect the continuing recovery and restoration efforts, while freeing additional general aviation operations under Class B rules. Currently, the FAA has issued approximately 60 waivers for helicopter operations in this area.

The Boston area will also return to a state of normalcy under Class B rules.

6 Issue: Foreign Registry Aircraft

Currently, foreign registered aircraft must obtain a waiver to operate within the U.S. from point to point, after they have provided a signed security affirmation form. The FAA has issued approximately 250 waivers to U.S. owned foreign registry aircraft since September 11, 2001.

Also, only U.S. registered Part 91 operators are authorized to conduct IFR operations from U.S. airports to and from each of the countries listed below. Pilots must operate in accordance with IFR from departure to destination, make no intermediate stops, and comply with U.S. Custom's notifications and requirements to land at U.S. airports designated as ports of entry.

Post maintenance, manufacturer production and acceptance flight test operations are currently authorized for foreign registry aircraft with a maximum certified gross takeoff weight of 95,000 pounds or less.

Strategy to Restore

+ The following to occur during the week of November 26, 2001: o Approve operations on U.S. owned foreign registry aircraft if signed security form on file with the FAA.

o Approve all foreign registry operations to and from all Caribbean Islands (including Puerto Rico) and Central and South America if signed security form on file with the FAA.

+ The following to occur during the week of December 3, 2001:

o Approve foreign registry Part 91 aircraft access into the CONUS from Japan, Canada, Mexico, the Bahamas, England, Scotland, Wales, Northern Ireland and the Republic of Ireland, all Caribbean Islands, South America and Central America if signed security form on file with the FAA.

o Approve manufacturer and production test flights for aircraft of any weight, including entry into the United States for the same purpose, if the production company has a signed security form on file with the FAA.

+ The following to occur by December 15, 2001.

o FAA security will develop procedures to authorize all foreign registry operations.

7 For a variety of business reasons, numerous U.S. corporations have foreign registered aircraft. These aircraft would be allowed to operate without the cumbersome waiver process currently in place. Also, many foreign registry aircraft operators have their aircraft serviced in the U.S. These aircraft would also be allowed to operate without the waiver process currently in place after a one-time security affirmation and review.

With the signed security form, it can be assured that the owner/operator has taken the appropriate security measures; it also provides the operator's name, identification number, and any passengers' names and identification numbers.

For manufacturer and production test flights, this would authorize those type operations for foreign registered aircraft weighing more than 95,000 pounds. Several U.S. companies need to perform maintenance and test flights for new aircraft that have been sold to another country- and thus, become foreign registry but have never left U.S. soil and are operated by U.S. operators.

8 Issue: Washington National Airport

Strategy to Restore

+ Phase II operational at this time.

+ In coordination with the Secretary of Transportation begin implementation of Phase III operations on January l, 2002. Phase III should include consideration for FAR Part 135 (Charter) operations with a level of security equivalent to the FAR Part 121 (Air Carrier) operating in Phase I and Phase II.

+ (Date to be determined) Develop Phase IV strategies in coordination with the Secretary of Transportation. Phase IV should include consideration for FAR Part 91 (General Aviation) operations with a level of security equivalent to the FAR Part 121 (Air Carrier) operating in Phase I and Phase II.

After executing this strategy, these are the operations that will still be restricted from flying:

Part 129 Foreign Air Carrier- overflights for aircraft weighing over 95,000 pounds, although FAA security may authorize exceptions.

Part 91 Foreign registry- VFR operations within the US (with only a few exceptions).

Part 91 Foreign registry- overflights for aircraft weighing more than 95,000 LB.

Part 91 Foreign registry- (and foreign owned and operated) VFRIIFR operations within the US exce.pt to depart IFR with no intermediate stops.

Part 91 any registry., IFRIVFR operations within 15 statute miles of the DCA VOR (except for operations as prescribed above for College Park Airport).

All aircraft operations -within 3NM radius/ 3000' AGL and below over any major professional or collegiate sporting event or any other major open air assembly of people, unless authorized by ATC for arrival/departure operations (this prohibits helicopters/blimps/ banner tow from operating around major sporting events and NASCAR races.)

All aircraft should avoid the airspace above or in close proximity to nuclear and other power plants, dams, refineries, industrial complexes or similar facilities. Circling not authorized. This includes company, government and service requested aircraft.

9 (Attachment B)

Subject: INFORMATION: General Aviation Strategy Date: November 19,2001

From: Acting Associate Administrator for Air Traffic Reply to Attn. of: Services

To: Deputy Secretary

The following is the proposal to restore general aviation. On November 20,2001:

~ Restore 27 Enhanced Class B airspace areas to Class B airspace, and allow all operations that were previously authorized in Class B A.\rspace. ~ The.Washington, DC, New York and Boston Temporary Flight Restrictions (TFR) Areas outside of 18 nautical miles reverts to Class B airspace, and allows all operations that were previously authorized in Class B Airspace. ~ Approve foreign registry aircraft operations if a signed security form is on file with the FAA, also approve all foreign registry operations to and from the Caribbean Islands (including Puerto Rico) and Central and South America.

On November 27,2001:

~ Reduce the Washington, DC TFR from 18 nautical miles to 15 statute miles from the DCA VOR. ~ Restore the New York and Boston TFR's to Class B airspace. New York will retain a one nautical mile, 3000 feet (above ground level) and below TFR around the accident site. ~ Approve foreign registry Part 91 (general aviation) aircraft access into the United States from Japan, Canada, Mexico, the Bahamas, England, Scotland, Wales, Northern Ireland and the Republic of Ireland, all Caribbean Islands, South America and Central America. Also, approve all manufacturer and production test flights, including entry into the United States for the same purpose, if the production company has a signed security form on file with the FAA.

December 15, 2001:

li> FAA security will develop procedures to authorize all foreign registry operations.

Steven J. Brown

Attachment Air Traffic Services Strategy Attachment C

Sec. 146 AIRCRAFT OPERATIONS IN ENCHANCED CLASS B AIRSPACE

"Upon request of an opemtor of an aircraft affected by the restrictions imposed under Notice to Airmen FDC 1.0618 issued by the FAA, or any other notice issued after September 11, 2001, and prior to the date of enactment of this Act that restricts the ability of United States registered aircmft to conduct opemtions under Part 91 of Title 14, Code of Fedeml Regulations, in enhanced Class B airspace (as dfined by such notice), such restrictions shall cease to be in effect for the affected class of opemtor beginning on the 301h day following the reqeust, unless the Secretary ofTmnsportation publishes a Notice in the Federal Register before such 301h day re-imposing the restriction and explaining the reasons for the restriction." •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••

' • Note that this language is specific to ECB, not TFR, although TFR might be deemed to be included in the phrase" .... or any other notice issued ....". That determination is not yet made, nor is it clear the level of authority required to do so. • Thus, this language would release the 18-25 NM mnge outside the TFR, but not necessarily the TFR itself • It is already known that AOPA and other associations are generating write-in campaigns for release of the restrictions. DOT will likely task FAA (TSA?) staff resources to respond to each such request • It is not clear whether specific 191-protected threat information would be required, or ifthe phrase "security reasons" is a sufficient response. Attachment D (See also following Attachments El-2-3, for draft program and NOTAM language)

Special Federal Aviation Regulations CSFAR)

The FAA is currently drafting an SFAR which would prescribe enhanced security procedures to be implemented at non-military airports located within the DCA TFR. When the revised TFR is implemented these procedures would apply to operations conducted at Hyde, Potomac, and College Park airports. This SF AR could also be used to require security procedures at heliports within the TFR. It would not affect operations at heliports used for public aircraft operations and heliports used for the purpose of medical transport.

The SFAR only addresses operations in the TFR as they are related to the other airports located within the TFR. The SFAR does not specifically address current "orphan operations" nor does it address operations at DCA airport itself. The draft is written in the context of previous, but still unapproved agreements regarding LEO coverage and other procedural recommendations; it must be amended to reflect any additional changes and approvals before it can be issued.

Although the FAA can place limitations on aircraft operations in the TFR via NOTAM, it cannot require the operators to enact these security programs without regulatory action.' This SF AR must therefore be issued prior to operations recommencing at the affected airports if the FAA intends to require that ground security procedures be implemented.

The specific security procedures to be implemented at the airports [drafts attached] would be contained in security procedures approved for each airport operator. The security procedures would be required to:

( 1) Provide for the presence of a person with law enforcement authority at the airport when departures are permitted;

(2) Contain procedures for the identification of pilots and passengers of each aircraft by a person with law enforcement authority prior to each aircraft's departure from the airport;

(3) Contain procedures for the inspection of each aircraft and all property to be transported in the aircraft by a person with law enforcement authority prior to each aircraft's departure from the airport;

( 4) Contain procedures to confirm that the identity of each pilot and passenger in an aircraft arriving at the airport has been verified by a person with law enforcement authority prior to the aircraft's arrival;

(5) Contain procedures to confirm that each aircraft arriving at the airport and all property transported in the aircraft has been inspected by a person with law enforcement authority prior to the aircraft's arrival;

(6) Designate those airports where the procedures specified in paragraphs (4) and (5) of this SFAR will be carried out (These would be the "portal airports.");

(7) Contain airport arrival and departure route descriptions, air traffic control clearance procedures, communications procedures, and procedures for transponder use;

(8) Contain procedures to provide for the security of the airport and aircraft at the airport when departures are not permitted; and

(9) Contain any additional procedures the Administrator determines necessary to provide for the security of aircraft operations conducted to or from the airport (This is the "catch all" provision that could be used to require additional security procedures at heliports closer to the assets we want to protect.) Operators of heliports at which operations are conducted primarily for the purpose of medical transport and at which aircraft conducting such operations are routinely based would not be required to comply with paragraphs (I) through (7) but would be required to comply with paragraphs (8) and (9) (e.g. Washington Hospital Center, where helicopters are based). The operator would also have to adopt and carry out procedures to provide for the security of the heliport and any aircraft at the heliport when departures are permitted.

All affected airport operators would have to:

( 1) Submit security procedures for approval;

(2) Not make, or cause to be made, any fraudulent or intentionally false statement in any submission or record required under the SFAR;

(3) Maintain a complete copy of the approved security procedures at the airport;

( 4) Maintain a record of each aircraft inspected and those pilots and passengers whose identities were verified in accordance with the approved security procedures for a period specified by the Administrator;

(5) Maintain a record for a period of90 days of each law enforcement action taken in furtherance of theSFAR;

( 6) Restrict the distribution, disclosure and availability of all sensitive security information, as defmed in part 191 of this chapter, that may be contained in the approved security procedures to persons with a need to know;

(7) Make a document containing the approved security procedures available for inspection upon request of the Administrator;

(8) Provide evidence of compliance with the provisions of its approved security procedures on request by the Administrator; and

(9) Permit the Administrator to make any inspection or tests, to include copying any records, to determine compliance with the security procedures required by the SFAR.

Each person operating an aircraft to or from an airport to which the SFAR would apply would be required to operate that aircraft in accordance the airport's approved security procedures. This would not however apply when:

(a) The operation is a public aircraft operation; or (b) The operation is being conducted for the purpose of medical transport or to position an aircraft to conduct medical transport.

Each person with law enforcement authority used to comply with approved security procedures would be required to: (a) Be identifiable by appropriate indicia of authority while on duty at the airport; (b) Be armed with a ftrearm and authorized to use it while on duty at the airport; and (c) Have completed a training program acceptable to the Administrator.

Persons with law enforcement authority could be National Guard soldiers in State status mobilized under title 32 of the United States Code. They would however, be required to have arrest authority.

The Administrator could also issue waivers to any of the requirements of the SFAR if she finds that such action is in the public interest, provides the level of security required by this SFAR, and the operation can be conducted safely under the terms of the waiver.

------AttachmentE-1 DRAFT PROGRAM LANGUAGE

Note: the three following documents are in rough draft form, and cannot be completed until the SFAR itself is completed with appropriate language resolving such outstanding issues as LEO coverage and other specific requirements for portal airports, such as in/out corridors, home base clearance procedures, procedures for submittal of security programs, clearances and background checks for LEO and FBO personnel, how the ASP's will be processed and approved within FAA, etc.

L SECURITY PROCEDURES AT AIRPORTS WITHIN THE WASHINGTON, DC TFR Except Regan National Airport 1. An armed LEO must be on site during hours of operation to inspect airman certificate, medical certificate, and government issued photo identification. This is solely for pilot identification purposes. 2. The armed LEO will perform a cursory inspection of the aircraft (exterior & interior) and any baggage to ensure that there are no explosives or other dangerous materials on board. This is not intended to require detailed inspections, such as the removal of inspection plates, wheel pants, or other aircraft parts. However, such an inspection is not precluded if deemed appropriate by the inspecting personnel. 3. ID and aircraft inspection must be performed immediately prior to departure, with no intervening opportunity during which persons could introduce explosives or dangerous materials to the aircraft or baggage. 4. During non-operating hours, a roving patrol or armed LEO must be present at each airport within the Washington, DC TFR designated by the Administrator, and must have two-way communication equipment to contact both local law enforcement and air traffic control (ATC), where appropriate. 5. All aircraft must be physically secured when not in use. This includes, but is not limited to, prop locks, throttle locks, wheel locks, locked tie-down chains (not ropes), locked hangars, etc. This does not include removal of easily replaced engine parts such as spark plugs or wires. Such restraints should not be removed until standard pre-flight inspection has been accomplished and aircraft is ready for departure, subject to pre-departure inspection. 6. The airport hours of operation will be determined by the airport operator with approval from ATC. The airport operator must notify ATC prior to making any changes to its established operating hours. 7. Aircraft are permitted to move under their own power only during the airport's designated operating hours with inspection personnel present. Aircraft movements outside the airport's operating hours must be via towing or by pre-arranged coordination with FAA and inspection personnel. 8. The Operator must provide immediate written confumation of receipt of these procedures to FAA at xxxxx. NOTE: Airport operators have the ability to submit alternate security procedures for FAA approval. Attachment E-2 DRAFT PROGRAM LANGUAGE 11. SECURITY PROCEDURES AT PORTAL AIRPORTS FOR THE WASHINGTON. DC TFR

These are airport security procedures for aircraft seeking to enter the Washington. DC TFR. and/or to land at designated airnorts within the TFR, except Ronald Reagan National Ait:port: I. Portal airports will be determined by the State aviation authorities in conjunction with FAA, for the purpose of providing inspection, communications and clearance services and will be responsible for those services outlined herein prior to aircraft departing that airport for entry into the TFR. . .·

2. An armed LEO must be on site during hours of operation to inspect airman certificate, medical certificate, and government issued photo identification. This is solely for pilot identification (ID) purposes. 3. The armed LEO will perform a cursory inspection of the aircraft(exterior & interior) and any baggage to ensure that there are no explosives or other dangeroUs materials on board the aircraft. This is not intended to require detailed inspections, such as the removal of inspection plates, wheel pants, or other aircraft parts. However, such an inspection is not precluded if deemed appropriate by the inspecting personneL 4. ID and aircraft inspection must be performed immediately prior to departure, with no intervening opportunity during which persons could introduce explosives or dangerous materials to the aircraft or baggage. 5. Once a departing aircraft has obtained an ATC release time, the portal airport or its designated armed LEO inspector must notify ATC prior to departure that the required inspection has been completed and the aircraft is ready to enter the TFR. 6. The Operator must provide immediate written confrrrnation of receipt of these procedures to FAA atX:XXX:X.

NOTE: Airport operators have the ability to submit alternate security procedures for FAA approval. Attachment E-3 DRAFTNOTAMLANGUAGE

To: U.S. NOTAM Office Operations Manager: FAA Civil Aviation Security (ACS) requests worldwide dissemination of a NOTAM pertaining to SFAR XX security procedures for aircraft operations to and from Washington Executive/Hyde Field Airport, Potomac Airfield, and College Park Airport and for operations to, from, and within the Washington DC TFR, effective immediately. The NOTAM should read as follows:

I. In accordance with SFAR XX, beginning (insert next day after release), the following procedures are applicable to all aircraft operators conducting aircraft operations to and from Washington Executive/Hyde Field Airport, Potomac Airfield, and College Park Airport and within the Washington DC TFR. A. Flight Operations from Washington Executive/Hyde Field Airport. Potomac Airfield, and College Park Airport. The Operator must: 1. Ensure the aircraft is equipped with a two-way radio capable of communicating with air traffic control (ATC) on a frequency assigned by ATC, and an operational altitude encoding transponder that meets the performance and environmental requirements specified in 14 CFR 91.215(a). 2. Obtain an ATC clearance prior to departure, whether IFR or VFR, and conduct the entire flight in accordance with that ATC clearance. No flight may deviate from its ATe-established departure route/corridor without prior ATC clearance. 3. Contact the airport operator prior to departure to ensure all required security measures have been applied to the flight. 4. Immediately notify airport authorities or local law enforcement of suspicious items, activities, or persons at the airport.

B. Flight Operations to Washington Executive/Hyde Field Airport. Potomac Airfield, and College Park Airport. 1. All aircraft entering the Washington DC TFR are required to land at one of the following designated portal airports to go through inspection procedures. (a) ABC airport (geographic locater information, navaid radial intersection, LaULong, etc.) (b) DEF airport (geographic locater information, navaid radial intersection, LaULong, etc.) (c) GHI airport (geographic locater information, navaid radial intersection, LaULong, etc.) 2. Aircraft that have departed from an airport within the Washington DC TFR and have remained under continuous ATC control, andhave not landed elsewhere, may re-enter the TFR with ATC clearance without undergoing portal airport inspection procedures. 3. Each Operator must ensure that their aircraft is equipped with a two-way radio capable of communicating with ATC on a frequency assigned by ATC, and an operational transponder that meets the performance and environmental requirements specified in 14 CFR 91.215(a). 4. Each Operator must obtain an ATC clearance prior to departure, whether IFR or VFR, and conduct the entire flight in accordance with an ATC clearance, No flight may deviate from their ATC established departure route/corridor without prior ATC clearance. ~------~------.

Attachment F: AOPA e-Pilot dated Friday, Nov. 23,2001 (emphasis added)

FAA AIRSPACE PLAN REMAINS STALLED

Even though the federal government returns to work today following Thanksgiving, AOPA doubts that security officials will act on a plan to remove the remaining restrictions on operations in enhanced Class B airspace and to reopen closed airports. "If there is no breakthrough soon, I pledge to take this to the highest government officials," said AOPA President Phil Boyer. "The FAA has a solid, viable plan for reopening the airports and airspace, developed in consultation with AOPA and other aviation groups. That plan has been pending for more than a week now." Department of Transportation and national security officials have yet to give final approval. "Perhaps there is a perception among these officials that, since most flying has been restored, there is no urgency to resolving these remaining matters," Boyer added. "We want to impress upon our country's leadership that, for pilots in the Boston, New York City, and Washington, D.C. areas, for the business owners at the closed airports, and for specialty operators in all enhanced Class B airspace, this is a critical issue that must be solved now."

SECURITY LAW CONTAINS NO GA MANDATE

President Bush signed into law Monday aviation security legislation that contains no security mandate for general aviation. AOPA Legislative Affairs worked extensively with the House­ Senate aviation security conferees and their aides to modify Sen. Herb Kohl's amendment that would have mandated security restrictions on all GA aircraft. Instead, the bill requires a study on GA security and requires aliens or other individuals specified by the transportation secretary to undergo a background check before receiving training for aircraft with a maximum certified takeoff weight of 12,500 pounds or more. For a summary, see www.aopa.org/whatsnew/la-security.html .

... AND THERE IS RELIEF FOR OPERATORS IN ECB

The aviation security legislation allows operators of aircraft affected by the enhanced Class B (ECB) airspace restrictions imposed after September 11 to seek relief from the transportation secretary. Relief will automatically be granted 30 days after the request unless an official "notice" is published in the Federal Register before the thirtieth day, restoring restrictions and explaining the reasoning. (The original House bill specified 10 days. That was changed to 30 days in conference committee as legislators reconciled differences between the House and Senate bills.) Unfortunately, this provision does not apply to temporary flight restriction (TFR) areas, including New York City; Washington, D.C.; and Boston--separate efforts are under way for these areas. "While the FAA is working diligently to remove the restrictions, we are pleased Congress responded by establishing this process for public accountability," said AOPA President Phil Boyer. WHO IS ELIGIBLE?

Affected operations such as airborne news reporting, banner towing, airborne traffic spotting, VFR instruction in aircraft heavier than certain weights, blimp/airship operations, and Part 91 sightseeing will all benefit by submitting requests to the federal government immediately. Requests should explain the type of operation, the reason the relief is needed, and the length of time it is needed (including indefinitely). Contact: Secretary Norman Y. Mineta, Department of Transportation, 400 Seventh Street, s.w., Washington, D.C. 20590.

CHICAGO ASKS FOR VFR RESTRICTIONS TO 'CALM FEARS'

The City of Chicago is again trying to restrict VFR flight to "calm citizen fears." But AOPA is pushing for a more reasoned, rational approach. At the request of the city, AOPA, the FAA regional administrator, and air traffic representatives recently met with Tom Walker, city aviation commissioner. Walker explained that, while no credible threat exists, citizens have contacted his office to express fears about aircraft overflights. He stressed that the city did not want to unnecessarily restrict GA, but at the same time he feels an obligation to address public perceptions and concerns. The city requested that the FAA establish mandatory VFR corridors that route aircraft away from city assets. Instead AOPA representatives recommended a public outreach and education campaign to provide insight into aircraft operations. This effort would stress that these aircraft are operating safely, legally, and under constant surveillance by air traffic control. AOPA will meet with officials again next week. See www.aopa.org/whatsnew/newsitems/2001/0l-4-160x.html.

MEIGS TO STAY OPEN DURING CONVENTION

AOPA has learned that its efforts to reverse a request to close Chicago's Meigs Field during an upcoming convention have been successful. Thanks to comments from AOPA members, the Radiological Society of North America (RSNA) realized that the convention site, McCormick Place, was not in any danger from aircraft. The mayor's office subsequently decided to keep the lakefront airport open. "Once again, a strong and unified national AOPA membership has made the difference between public policy based on logic and evidence and one based on irrational fear. AOPA commends RSNA for its openness to the views of its pilot members and for reaching an enlightened decision," said AOPA President Phil Boyer. AOP A Online - Issue Brief: Security Provisions Affecting GA Page 1 of3

••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• .... WHAT'SNEW

IHOllE I TABLE OF CONTENTS I fiiliJ Issue Brief IABOUT AOPA I I JOIN OR RENEWI I I WHAM NEW I Key GA Provisions of Aviation Security Law I ADVOCAC¥ I Novemb~r 2001 lAOPA PILOT MAGAZINEI ICERTIFIED PRODUCTS I eraFET¥FOUNDATI3 The aviation security bill (S. 1447) signed into law on November 19, PRESIDENT'S PAGE I 2001 makes significant changes in the federal government's role in managing aviation security, including establishing a new office in the LEARN TO FL¥ I Department of Transportation to oversee security. The legislation also AVIATION CLASSIFIEDS I contains the following GA related provisions: SEARCH I

lARPT SUPPORT NETVIICI • GA Security Study--Within 30 days after the enactment of this act, the Undersecretary of Transportation for Transportation Security I PRESS CENTER I shall transmit a report on airspace and other security measures that can be deployed, as necessary, to improve GA security to the

~QQQQQQQ~··· appropriate Congressional committees, in both classified and ~il";!;Sl:~.l ...~.~~~~ redacted forms. (Sec. 132(b))

• Aircraft Operations in Enhanced Class B airspace-Upon request by an operator of an aircraft affected by restrictions imposed under a NOTAM or any other notice issued after September 11,2001, those restrictions shall be lifted within 30 days, unless the Secretary of Transportation reissues the restrictions.(Sec. 146) (The original House bill specified 10 days. That was changed to 30 days in conference committee as legislators reconciled differences between the House and Senate bills.)

• Amendments to Airmen Registry Authority--Expands the purview http://www.aopa.org/whatsnew/la-security.html 11/26/2001 AOPA Online· Issue Brief: Security Provisions Affecting GA Page 2 of3

of a provision in current aviation law regarding issuing ainnen certificates to include acts of terrorism to make the ainnan registry l40P~N.P' ..... more effective to combat terrorism. IMIIIIIER PROfiiLE

--The Administrator is authorized and directed to work with State and local authorities, and other Federal agencies, to assist in the identification of individuals applying for or holding ainnen certificates.(Sec. 129)

• Flight School Security--No person subject to regulation under Subchapter II of chapter 449 of title 49, USC, may provide training in the operation of any aircraft having a maximwn certificated takeoff weight of 12,500 lbs. or more to an alien (as defined in section 101(a) (3) of the Immigration and Nationality Act) or to any other individual specified by the Under Secretary ofTransportation for Transportation Security unless the trainee is approved by the Attorney General. Also includes language about interruption of training and international cooperation. (Sec. 113)

• Increased Funding Flexibility for Aviation Security--Amends the definition of airport development to include: in fiscal year 2002, any additional security related activity required by law or by the Secretary of Transportation after 9/11/01, and before 10/1102; any activity, including operations activities, of an airport that is not a primary airport if that airport is located within the confmes of ECB airspace (Enhanced Class B) and the activity was carried out when any restriction in the NOTAM is in effect. (Sec. 119)

• Charter Security Program--Requires the Under Secretary of Transportation for Transportation Security, within 90 days to develop a plan to implement an aviation security program for charter air carriers with a maximwn certificated takeoff weight of 12,500 pounds or more. (Sec.l32(a))

• Improved Airport Perimeter Access Security--Although this provision is directed primarily at airports with air carrier service, it is broad in scope and could affect GA areas of airports receiving airline service. It directs airports to improve security controls used to control access. (Sec. 106) http://www.aopa.org/whatsnew/la-security .html 11/26/2001 AOP A Online - Issue Brief: Security Provisions Affecting GA Page lof3

• Flight Service Station employees--The Administrator of the Federal Aviation Administration will continue negotiating in good faith with flight service station employees of the Administration with a goal of reaching agreement on a contract as soon as possible. (Sec. 123(a))

op Updated Monday, November 19,2001 5:56:30 PM Public section: !:i_QJTI§ I I.abi~Qf_~on!l!nts 1About AOPA 1Join or renew I What's new I Advocacy 1 AQPA PiloL maga~~ 1kfillified_QJoducts 1Air Safety Foundation 1President's page (learn to fly 1 Q!!§_sified ads 1Searcl!

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http://www .aopa.orglwhatsnewlla·security.html 11126/2001 Attachment G Homeland Security Working Group on: Nuclear Power Plants and Restricted Air Space Response to Deputy's Committee Questions on General Aviation

I. What array of possible aviation restrictions might be appropriate to use during a heightened level of alert? ·

Commercial (Part l 08 and Foreign Part 129) operators at regulated (Part l 07) airports in the United States have been at a heightened state of alert and subject to additional security restrictions since the September 11th attack. Additional security measures, up to and including the prohibition of flight operations can be implemented immediately if necessary. General Aviation (GA) operations were not directly subject to any of the same heightened security measures at the time of the attack, unless they were operating in the security identification display area (SIDA) of a part 107 airport. Concerns with security risks from GA aircraft since September 11th were initially addressed only through the total prohibition of flight operations at selected airports.

The FAA recently issued Special Federal Aviation Regulation (SFAR 91), in anticipation ofthe possible need for enhanced security measures for pilots operating under part 91 and General Aviation ( GA) aircraft. SFAR 91 immediately (October 6, 200 l) required added security procedures for all planes enplaning and deplaning from/into a sterile area of an airport and allows the Administrator to initiate additional security procedures through Notices to Airmen (NOTAMs) tailored to meet various threats that could apply to any or all GA operations.

To that end, the FAA drafted two NOTAMS that when implemented would immediately require additional security measures for aircraft with gross take off weights of 12,500 up to 95,000 lbs and for those above 95,000 lbs. All of the security requirements for those aircraft at 95,000 lbs and above can also be required for all sizes of aircraft, even single-engine propeller driven aircraft, if those aircraft pose a threat to a particular target.

NOTAMS have NOT been drafted for aircraft under 12,500 lbs, with the assumption that the threat from aircraft under this weight and size is limited and if present, can initially be addressed by prohibiting flight operations by those smaller aircraft. FAA analysis indicates that the smaller aircraft do not have the weight, speed, fuel payload and range to present a significant threat or risk of being a terrorist target or of being used effectively as a weapon. This would mean that unless specifically identified as a threat, they would propose that these aircraft would be allowed to operate without flight restrictions. Small single engine aircraft under 12,500 pounds represent about 80% of all GA aircraft. Significant portions of these aircraft populate non-regulated public access and private airports.

If a threat is identified in which a small aircraft could be used to attack the target, then the general aviation aircraft located in that vicinity/or larger surrounding area of the target may be grounded (such as in the restricted spaces around nuclear power plants). The measures outlined for the larger GA aircraft can be systematically implemented to tlllow resumption of flight. Due to the number of private and non-regulated airports, it may be difficult to implement these secUrity measures in a timely fashion and with complete initial success, which might mean some portion of the small, sil).gle-engine GA aircraft operations would remain restricted.

If there is a threat and risk from larger aircraft, the FAA can issue NOTAMS under the authority outlined in SFAR 91. As currently drafted, the NOTAM for all GA aircraft at 12,500 to 95,000 lbs gross takeoff weight, regardless of whether they are at a regulated airport or not, would require operators to: a. Designate a security coordinator for security-related activities and communications with the FAA who must be the pilot in command unless another is designated in writing to the FAA by the owner/operator. b. File a complete instrument flight rules (IFR) or visual flight rules (VFR) flight plan prior to departure. This must include a certification that upon departure clearance, all security procedures applicable to operations under SF AR 91 were carried out. c. Ensure the identities of individuals who appear to be 18 years of age or older and not personally known to the pilot in command or vouched for by a person known to the pilot in command, are verified by two fonns of identification. If verification cannot be made, they must not be allowed aboard. d. Ensure the aircraft is equipped with an operational two-way radio and transponder. e. Ensure the flight does not deviate from a filed flight plan without A TC clearance. f. Notify Airport Security Coordinators or local authorities of suspicious items, activities or persons

All operators of aircraft over 95,000 lbs gross takeoff weight, regardless of whether they are at a regulated airport or not, will be required to:

a. Inspect all persons and accessible property using screeners that meet FAA training and qualification requirements (or notify the FAA Regional Civil Aviation Security Division office for detailed instructions). b. Ensure the following items are not allowed into the cabin of the aircraft I. Explosives, incendiaries and deadly and dangerous weapons 2. Knives of any length 3. Cutting instruments of every kind 4. Ice picks and straight razors c. Conduct a thorough physical search of the empty interior of the aircraft d. Conduct a visual inspection of all accessible exterior areas and compartments of the aircraft e. Search the empty cargo hold f. Provide the crew with local law enforcement contact information for each airport of operation g. Provide immediate written confi.I'Illation of receipt of the required procedures.

The FAA is also scheduling meetings with associations representing non-regulated airports and aircraft operators to identify what additionally can be done to both enhance security and allow the continuation of operations if a heightened level of alert occurs.

2. Could a strong package of ground measures like identification checks and cargo reviews be developed and implemented?

Yes, for larger GA aircraft and those operating from larger public use airports with an infrastructure that would support enhanced security measures. Conversations with corporate business jet owners and fractional ownership firms have indicated that by virtue of the value of the larger aircraft and the services they require for operation, they are more likely to be based at a site with more significant ground security measures in place that would also support added security measures. Implementation of additional measures would, for the most part, not be difficult and are being put in place for added security in some areas already. There are of course exceptions that would have to be examined and alternatives negotiated.

Added measures at very small public access and private airports and airstrips would be more difficult. Those sites and operations will more likely require more restrictions if there is a specific credible threat identified. The FAA will pursue discussions with General Aviation trade associations representing these groups to identify measures that can effectively be put into place.

Additionally, the FAA will pursue the development and issuance of an FAA Advisory Circular alerting GA pilots to the need for a heightened security posture and how to implement these measures. The FAA is also exploring how to make security awareness a part of the mandatory bi-annual flight review training program.

Prepared by: Jan Brecht-Clark, 366-6541