Security Policy Alert: Summary of TSA's Monthly Conference Call for Airport Stakeholders

November 5, 2020

This afternoon, TSA held its monthly conference call for airport stakeholders. The conference call was led by Alan Paterno, TSA's Airport Industry Engagement Manager in the office of Policy, Plans and Engagement (PPE). Following are highlights from today's call:

Update from Policy, Plans and Engagement:

National Alternative Measure 1542-20-03C: TSA partially extended the national alternative measure (AM), continuing regulatory relief for three out of the four measures. The updated AM, which became effective on November 1 and expires on February 28, 2021, allows for badges to be retrieved up to 30 days after issuance, removes the tactile touch requirements for certain inspections and allows the use of expired driver's licenses and identification cards for identification verification. The AM no longer allows the use of expired airport badges.

ID Media Audits: TSA continues to consider regulatory relief for ID media audits due to the impacts of COVID-19 on airport badging operations. Specifically, TSA is considering allowing revalidation stickers to be issued rather than a full badge reissuance if certain unaccountability badge rates are met but a final decision has not been made. On the call, AAAE once again strongly urged TSA to provide airports flexibility under the ID Media Audits requirements.

FBI Brochure on Identity History Summaries (IdHS): TSA explained that in 2019, FBI's Criminal Justice Information Services (CJIS) audited several airports on the CHRC process that is required by TSA. One of the results of this CJIS audit was a finding that the airports visited did not provide adequate written notice to an applicant about the procedures for accessing or amending their FBI record. In response, on October 1, TSA posted on HSIN and FPRD a CJIS brochure that can serve as a resource for individuals who seek to obtain or challenge information found within their FBI record.

TSA regulations require airports to inform applicants about their rights to obtain and, if necessary, correct their FBI records. Specifically, in 49 CFR section 1542.209(h)(1), "before an airport operator makes a final decision to deny unescorted access, the airport operator must advise the individual that their FBI record contains disqualifying information, and the airport operator must provide the individual a copy of the FBI record upon their request." In addition, in 49 CFR section 1542.209(i), "the individual may contact the local authority responsible for the information in the FBI record, or contact the FBI itself to get their information corrected."

The FBI brochure provides guidance to the airport and the individual on how to contact the FBI to challenge information an FBI record. Despite unclear messaging sent earlier to the TSA inspectors, TSA has no requirements surrounding this specific FBI brochure at this time. However, TSA highly recommends that airports make the FBI brochure available to applicants. TSA will be issuing an updated bulletin shortly about the availability of the FBI brochure and will also be making clear to inspectors that its use is recommended but not required.

FY2021 Resource Allocation Plan (RAP21)

Mike Coffman from Security Operations provided a briefing on the TSA's Resource Allocation Plan (RAP) for FY 2021. Given the uncertainty regarding passenger volume and how quickly operations will recover in FY2021, TSA is releasing its RAP in quarterly allocations. This will ensure TSA can react and adjust to today's dynamic COVID-19 operating environment. Each quarter will cover at least 6 months to allow adequate lead time for hiring and training.

Q1 allocations are based on TSA's optimistic projected growth scenario. The allocation is based on 37% passenger volume as compared to the same timeframe last year, with an anticipated return of passenger volumes to 66% by March 2021.

With the shift to quarterly allocations in FY 2021, the busiest 14 days for the upcoming 180 days (Oct 1 - Mar 30th) were used as the basis for staffing requirements. Q1 allocations incorporate updated flight schedules and volume projections with significant growth over current volume levels. Current through-put data was utilized to evaluate current checkpoint configurations and hours of operation. Specifically, for Q1 TSA adjusted its rates and standards to reflect a 20 percent lower through-put rate at the checkpoint to account for social distancing requirements.

Other RAP items of note:

TSA allocated 340 FTE to larger airports to support the Infection Control Monitor position to enforce social distancing and PPE protection at the checkpoint. TSA also added additional FTE due to an updated EDS baggage alarm rate. Lastly, TSA increased its ATLAS allocation and expanded ATLAS to all airports. The Part Time/Full Time ratio remains about the same, with a higher number of part-time employees at smaller airports. Similarly, the National Deployment Office is staffed at the same level as FY 2020.
TSA is closely monitoring the impact of a new Paid Not Worked policy of 12 weeks of parental leave, which is unknown at this time.
Overtime (OT) was reduced significantly for Q1, although TSA expects additional OT will be allocated in Q2 and Q3.
Training allocations are largely unchanged. TSA expects airports with high amounts of downtime to continue to be responsible for training during operational downtime (as well as ATLAS and maintenance).
Maintenance allocations have been improved to account for additional equipment maintenance staffing needs based on the pieces of equipment (X-Ray, EDS, ETD, AIT, WTMD, and CAT) at each airport. The new allocation methodology allots time for maintenance work to all airports and incorporates schedule efficiency adjustments for maintenance work that can potentially be completed during operational downtime.

The RAP21 was provided to Federal Security Directors on October 6, who were to share the process and general allocation details with stakeholders. FSDs had until October 31 to ensure airport staffing plans were updated to support RAP21 allocations for the Q1 and those plans were submitted to TSA headquarters. As TSA is updating its RAP21 on a quarterly basis this year, Q2 allocations letters will be sent on December 17, Q3 on March 17 and Q4 in June.

Enrollment Services and Vetting Programs' Update

Nathan Tsoi, Section Chief for Regulatory Affairs and Stakeholder Management in the Vetting Programs Branch, provided information on a number of issues related to airport badging and the vetting of aviation workers.

STAs: TSA has seen an increase in Security Threat Assessment (STA) requests from airports. TSA is working with its adjudication center to ensure a quick turn-around on STAs for badge applicants. TSA encouraged airports to reach out to their Designated Aviation Channeler (DAC) or TSA if they encountered any significant delays or need support on a case-by-case basis.

Rap Back: TSA currently has approximately 618,000 active subscriptions in the Rap Back program with 223 airports and 14 air carriers actively participating. TSA did remind participating airports to closely monitor their Rap Back subscriptions to avoid expirations. TSA consistently sees expirations across the population, with an average about 500 per week. However, they saw a recent spike of upwards of 3,500 in one week. Airports should be processing Rap Back maintenance transactions to either renew or cancel subscriptions prior to expiration. TSA asked that airports ensure that airport badging offices are reviewing their Rap Back renewal notifications (which are sent five days prior to expiration) and taking appropriate actions to renew or cancel.

In response to a question on the call, TSA advised that an airport should cancel the Rap Back subscription if it is due to expire while a badge is suspended and unlikely to be made active before the Rap Back expiration. An airport does have 60 days to un-cancel if the badge needs to be reactivated

Data Management: TSA continues to work on improving its data management and data quality for the Aviation Worker population. TSA recently completed testing with the DACs to support a new feature which will send a notification from TSA to the DACs/airports to indicate that a specified application is marked for deletion by TSA. TSA plans to issue a bulletin in the near future with additional information on the new delete notification feature. You can also contact your DAC for more information.

FBI's Identity History Summary (IdHS) Brochure: As discussed previously on the call, FBI has produced a brochure explaining how individuals can obtain and challenge their identity history summaries (or rap sheets) in writing or electronically. TSA has posted the brochure on both HSIN and FPRD and encourages airports to make it available on request to applicants to inform them of the procedures to request a copy of their IdHS record and challenge its contents if the applicant believes that their record contains inaccurate or incomplete information.

Low-Quality Unclassifiable Fingerprints: Late last month, TSA posted a bulletin on HSIN with tips on how to prevent low-quality unclassifiable fingerprints. TSA has received a number of errors recently related to low-quality unclassifiable fingerprints. The bulletin outlines the reject response codes that the FBI will no longer process a Manual Name Check (MNC) for because the FBI considers these reject responses to be "correctable." Currently, the FBI will only accept a request for manual name check (MNC) for CHRC submissions that return an L0008 reject response. The procedure for submitting the MNC request is described in Appendix G of the Rap Back User Guide.

If an airport or aircraft operator receives one of the below reject codes, the MNC submission will be rejected and the operator should resubmit better-quality fingerprints. TSA suggests that airport operators should utilize the recommendations in the bulletin to obtain good quality prints if they receive one of the below error codes during the fingerprint process. To be clear, airports should collect a higher quality set of prints from the applicant if they receive these reject codes and NOT submit the exact same set of prints.

The FBI will no longer process an MNC request for the reject responses listed below:

L0116 - Fingerprint pattern(s) not discernible
L0117 - Insufficient pattern area(s) recorded for identification purposes.
L0118 - Erroneous or incomplete fingerprint(s) on images: fingers or hands out of sequence, printed twice, missing and no reason given.
L0185 - Rolled and/or plain fingerprint blocks(s) contain multiple images. See finger(s):
L0186 - Rolled and or plain fingerprint images appears to be from multiple subjects. See fingers(s):
L0187 - Plain impressions are not printed simultaneously and/or same hand printed twice in plains. See finger(s):
L0188 - Fingerprint image contains shadowing/gray areas with ridge detail throughout or surrounding the pattern area. See Finger(s):
L0189 - Fingerprint image contains text and/or lines running though the pattern area. See finger(s):
L0191 - Fingerprint images not visible/printed in the plain impression block(s). Unable to determine correct sequence.

National Safe Skies Alliance Update

Jessica Grizzle from Safe Skies provided an update on the organization's recent activity.

New PARAS Guidance
Two new guidance documents have been issued and are available on the Safe Skies' website here.

PARAS 0022 Active Shooter Mitigation and Recovery Strategies
PARAS 0029 CHRCs and Vetting Aviation Workers Guidebook (Update to PARAS 0001)

Awarded PARAS Projects

PARAS 0032 Enhancing Security of Cargo Operations at Airports was awarded to Arup - Jane Goslett, Principal Investigator.
PARAS 0036 Airport Credentialing Efficiency Toolkit was awarded to The JW Group - Enrique Melendez, Principal Investigator.
PARAS 0037 Planning and Operational Security Guidance for Construction Projects at Airports was awarded to Garver - Nathan Polsgrove, Principal Investigator.

New PARAS Projects
The Safe Skies Oversight Committee recently allocated FY2021 funding to the projects listed below and they are currently seeking panel members for each. Short project descriptions can be found here.

0038 IDMS Selection and Implementation
0039 Security Practices for Airside Vehicle Entry Gates
0040 Pandemic Response and Recovery for Airport Security Operations
0041 Security Considerations for Urban Air Mobility Operations at Airports
0042 Force Multiplier and Response Strategies for Airport Law Enforcement
0043 Security Operations Center Planning and Design
0044 Strategies for Aviation Security Stakeholder Information Sharing
Project panel tasks are facilitated by the PARAS Program Manager and include drafting the RFP, reviewing proposals to select a contractor, monitoring project research, and reviewing deliverables. While Safe Skies is eager to resume in-person meetings as soon as possible, panels will meet virtually until it is deemed safe to do otherwise.

More information on becoming a Project Panel member can be found here. Panel applications and questions should be directed to jessica.grizzle@sskies.org.

New ASSIST Report
ASSIST PTF: Evaluation Report - Senstar Symphonyâ„¢ 7 Video Analytics System has been issued and can be found in the Safe Skies folder on HISN.

Credential Authentication Technology (CAT) Deployment

TSA's Acquisitions and Program Management provided a brief update on the current deployment schedule for Credential Authentication Technology (CAT). There are currently 689 CAT machines deployed to 86 locations, including airports, TSIF and the TSA Academy. TSA is currently deploying an addition 501 machines to 80 airports across the country (Cat X, I, II and III) and anticipates completion by the second week of January 2021. Full Operational Capacity (FOC) for the CAT program is 1,520 units, which TSA aims to achieve by the first quarter of FY 2022.

Intelligence Update

Ted Stonley from TSA's Intelligence and Analysis provided an update to a report issued in May on UAS Threats to Transportation in the Homeland that covered UAS incidents reported to TSA between January 2018 and March 2020. As an update, TSA provided the following UAS incident reporting data highlights.
From January 2018 through September 2020, there were 718 UAS incidents reported to TSA's Transportation Security Operations Center (TSOC) related to aviation. UAS incidents involving aviation have increased year-over-year, from one in 2018, 183 in 2019, and 534 between January and September 2020.

Of the 718 aviation related incidents, TSA characterized 602 as sightings of UAS activity outside the perimeter of airports. Pilots reported many of these sightings while on approach for landing, or just after takeoff. The remaining 116, or 16.1% of incidents identified UAS activity, directly affect the safe operation of aircraft, both in flight and on the ground. Fifty-seven or 49.1% of these incidents were related to safe flight operations, and pilots characterized these incidents as either requiring evasive action or nearly missing a UAS, or as collisions or possible collisions with a UAS. The remainder of incidents affected the safe operation of airports, including numerous reports of UAS' either operating, or being recovered within the airport perimeter, or UAS sightings that affected airport or flight operations.

A comparison of UAS incidents between 2019 and the first nine months of 2020 highlights two significant changes. First, the number of UAS sightings outside the perimeter of an airport from January-September 2020 are almost quadruple (3.77 times) the number of sightings for all of 2019, increasing from 126 to 476. Second, the number of incidents directly affecting safe airport operations have increased. As of September 2020, incidents involving UAS' either operating, or being recovered within the airport perimeter were over 2.5 times greater than 2019 levels.

Next TSA Conference Call
The next TSA conference call for airport stakeholders is scheduled for Thursday, December 3 at 1:00 p.m. ET. The following week, AAAE will host the 20th Annual AAAE Aviation Security Summit on December 8-9 as a virtual conference. TSA Administrator David Pekoske is confirmed as the keynote speaker. To see the full agenda and to register, please visit the conference website.