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Air Transport Association

Carol B- Hallett
President & Chief Executive Officer August 23. 1996

General John Michael Loh (Retired)

Gore Commission
18th & F Streets, N.W.
Room 6208
Washington, D.C. 20405

Dear General Loh:

Thank you once again for taking the time to meet with us for the preliminary
discussion of the Gore Commission's mandate and plans. As I mentioned to the Vice
President in my recent letter, you can be assured of the ATA member airlines' absolute
resolve to work with the Commission to address the matters under review frankly,
accurately and in a forthright fashion and to provide you every benefit of industry expertise
and technical support. These matters are far too important for anyone to do otherwise.

To that end and following up on the commitment we made to you to provide a

listing of immediate and near term measures which might be incorporated into the
Commission's initial report to the President, we have prepared the attached listing of
proposed actions. (Attachment 1.) I am particularly pleased to note that this listing is more
expansive than I had thought possible ~ and that it reflects our members' solid commitment
to the effective resolution of all serious security issues. The ATA airlines are committed to
maintaining an open dialogue with the Commission, and are ready to work with you on any
and all issues which come under review.

In addition to this immediate action plan, we also wanted to take this opportunity to
present for your consideration, and that of the Commission, a conceptual framework for the
future evolution of aviation security management. This framework is fully consistent with
and would advance the immediate and near term actions we are suggesting. This is
presented in the attached "Statement of Aviation Security Principles" upon which we would
welcome your initial thoughts and comments. (Attachment 2.)

Finally, recognizing the difficulties associated with even beginning to manage and
sort through the complex tangle of issues associated with aviation security, we offer for
your consideration a possible analysis structure for the Commission which may be of
assistance. We offer this simply from the "benefit of our experience" perspective which has
made clear to us thai the absence of this type of analytical discipline makes progress
difficult.

Air 1ft
1301 Penraytvinia A««.. NW . Suite 1100 Wuhington.
1202) 626-UU » FAX (2021 626-TI66
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General John Michael Loh (Retired)

August 23, 1996
Page Two

This would involve breaking down the analysis into essentially three component
parts for assessment: First an analysis of the current United States Government process and
underlying strategy (current and historic) for making the threat assessment, and the
establishment of the general criteria for protective measures. This would also involve a
review of how, and when, required information is communicated to the aviation industry
and include recommended changes as necessary. The second part would involve an
assessment of the actual security procedures/systems currently in place in the industry and
the requirements, effectiveness, practicability and timelines for any needed change. Finally,
it would be desirable to explore all possible financing options for the development or
deployment of new security systems, and the associated questions of who should provide
these and how best to manage these systems.

In closing, I did want to present one additional thought for consideration, and that
relates to the danger of unintended and unforeseen consequences which will result from the
imposition of new security requirements. It is a simple fact that as we add complexity and
cost to air transportation, we inevitably influence' consumer behavior, including the likely
diversion of certain traffic to less safe modes of transportation. At the same time, we run
the risk of diverting available resources from other, potentially more important, goals and,
taken to the extreme, even run the risk of fundamentally impeding the ability of our
aviation system to function. To the extent that new security measures are warranted by a
valid threat assessment, of course, there is no debate as to the need to take any action
required Conversely, however, in the absence of such an assessment, more harm than
good can and will result from any requirement to simply pour technology and systems into
responding to an inadequately defined perception of a problem. Please be assured that in
raising this point we are not "arguing costs" but simply trying to focus on the serious public
policy and societal questions at issue and the need to precisely define and understand our
common goals.

Obviously, once again^ we would be pleased to provide you with whatever support
you might require to advance the work of the Commission. I will call you early next week
to discuss how we might be of further assistance.

Sincerely,

Carol B. Hallett
President & Chief Executive Officer
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ATTACHMENT 1

PROPOSED IMMEDIATE AND NEAR-TERM ACTION ITEMS

GORE COMMISSION ON AVIATION SAFETY AND SECURITY

1. IMPROVE ANALYSIS AND INTELLIGENCE PRODUCT

Announce an immediate new emphasis on and a heightened funding priority for all
elements of the intelligence community with regard to counter-terrorism with
particular emphasis on domestic and aviation targets. At the same time, establish
strong, new inter-agency coordination requirements to insure the timely, accurate and
comprehensive communication of detailed intelligence assessment information
necessary to permit the informed participation of the aviation industry in responding
to identified threats.

2. HEIGI FBI ROLE

Cite the planning akeady well advanced by the Federal Bureau of Investigation to
realign its counter-terrorism structure, which includes a particular concern with an
improved focus on aviation terrorism. The Commission is urged to call for the
dedication of specific FBI staff resources to the unique issues relating to aviation
terrorism which, consistent with, current intelligence assessments, require particular
attention.

IMMEDIATE DETECTION DEVICE DEPLOYMENT

Announce that consistent with the President's request, the Commission is calling for
the immediate deployment for comprehensive operational and evaluative testing of
"new technology"* subject to the availability of federal funding. The Commission
could announce, as well, the commitment of the ATA member airlines to work
cooperatively with the federal government to facilitate the deployment at identified,
desirable airport locations, and to work with the government to quantify and
understand the effectiveness and utility of such equipment in an operating
environment It is also strongly suggested that the Commission seek to validate the
experience from such operational and evaluative testing through the involvement of
an outside third party expert or academic institution to help design and implement an
operational and evaluative testing protocol.

To include Dual Energy/Dual View X-ray, Computerized Tomography X-ray,

Magnetic Resonance X-ray, and Trace Explosive Residue Detection Systems.
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4. IMMEDIATE PROFILING TECHNOLOGY ROLE

As a corollary to Item 3, and as an additional new technology item, announce the

immediate availability of the funding necessary to complete the development of the
software required for automated passenger profiling and the schedule for the
completion of this development cycle. The ATA member airlines are committed to
the full implementation of automated passenger profiling through their respective
reservations systems as quickly as possible, subject to the resolution of as yet
undeterminable hardware, software and process integration concerns. It should also
be specifically and prominently noted that the effective deployment of any effective
screening technology is dependent upon full integration of profiling technology and
techniques in order to focus screening systems on appropriate targets.

5. UTILIZE CANTNE SUPPORT

Announce that until such time as additional technology and procedures come on line,
the Defense Department will be mandated to deploy all available bomb-dog teams
for use at CAT-X airports for the purpose of rapdcjn checking in airport public
space (i.e. baggage check-in and departure lounge) areas.

6. ESTABLISH SCREENING CONTRACTOR CERTIFICATION

Announce a program to mandate that all companies contracting to provide airport

passenger screening will be required to meet and maintain operationally effective
certification and performance standards to be established by the FAA in cooperation
with a highly credible federal law enforcement agency and the airline industry.
Until such time as this certification program is operational, all ATA member airlines
contracting for such services at CAT-X airports will commit to providing an on site,
visible, full time airline supervisor to oversee passenger screening contractor
performance either directly by an individual airline or, as warranted by airport
configuration, on a cooperative basis.

7. EXPANSION OF SCREENER DEVELOPMENT PROGRAMS

In addition to the certification program called for under Item 6, and pending it
becoming operational or the development of other alternatives, the ATA member
airlines commit to working with their screening contractors for the expansion of
checkpoint screener training, retraining and retention programs. This could include,
as determined to be effective and appropriate, award and advancement incentives.
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8. IMPROVED HUMAN FACTORS WORK

Announce expanded human-factors research for checkpoint screeners to help identify
optimal screener traits and characteristics, subject to the identification of an
appropriate institution and available funding to perform this task. Such a program
would be designed to advance the effective combination of a screener personal
profile and equipment integration.

9. ENHANCE NON-AUTOMATED PASSENGER PROFILING

Announce the immediate enhancement of existing, non-automated passenger

profiling techniques through the adoption of a single, improved standard set of
profile questions to be utilized uniformly where required.

10. ENCOURAGE AND INCENTIVIZE NEW TECHNOLOGY

Announce plans to expand Defense Department and other federal government
technology development programs as well as law enforcement research programs to
provide investment incentives for the rapid development of new security screening
technology. Emphasize that any such technology must be developed cooperatively
with industry in order to be of value in an operational setting.

11. UTILIZE FEDERAL AIR MARSHALS EFFECTIVELY

Announce the immediate deployment of Federal Air Marshals at airport locations

determined to warrant special security measures.

•12. ENHANCED SANCTIONS

Announce development of a legislative proposal to establish serious and

proportionate penalties for individuals knowingly and intentionally violating airport
security regulations through the unauthorized or fraudulent display of airport security
identification devices as well as for knowing and intentional violations of airport
security without use of an identification device. Further, such legislation should
provide appropriate federal sanctions for any person presenting false identification
documents in connection with seeking to obtain air transportation.
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ATTACHMENT 2

STATEMENT OF AVIATION SECURITY PRINCIPLES

The United States Government (USG) has the fundamental responsibility for the protection
of its citizens against ail threats — including the threat of aviation terrorism. The USG has
at its sole discretion and within its unique competence, virtually all means available to
counteract the threat of aviation terrorism including diplomacy, intelligence gathering,
economic sanctions, military action, covert action and general law enforcement. Only with
regard to countermeasures, which are deployed by airlines and airports at the direction of
the USG in the aviation environment, is there a sharing of this governmental responsibility.
The ATA member airlines believe that any action taken to enhance or improve this system
of aviation security must be guided by the following principles:

1. The public interest demands an aviation security system which effectively deploys a
mix of technology and procedures as a unified system capable of counteracting all
vulnerabilities confirmed to be threats to United States air carriers and their
passengers as well as those to United States citizens traveling on foreign air carriers.

2. Evolving threats require a continuous and accurate assessment by the most capable
and responsible authorities and the coordinated dissemination of timely and
comprehensive assessments of such threats to those parties responsible for
countermeasures.

3. The evolving nature of the threat requires, by the same token, an adaptable security
system which can be adjusted to meet varying and changing threat levels.

4. No single technology or procedure can be relied upon to provide an effective

security system.

5. Profiling, which permits the focusing of technology and procedures on selected

individuals, is a critical, central component of any effective aviation security system.
Conversely, a system requiring one hundred percent screening or bag match on
domestic services will impose enormous inconvenience on the public by reducing
the efficiency and increasing the costs of domestic air transportation so tremendously
as to reduce its patronage by the public and increase the use of alternative, less safe
travel modes, including automobiles.

6. Experience strongly suggests that any new technology or procedure must bo

developed cooperatively and in a coordinated fashion with parties having a clear
appreciation of the real world operating environment, if such technology or
procedures are to have any realistic prospect for success.

7. An effective aviation security system must provide for the free and unfettered
exchange of ideas and information between government and industry with adequate '
and effective assurances of confidentiality.