Summary of TSA Monthly Conference Call for Airport Stakeholders

February 1, 2024

Please note this call summary includes clarifying information provided to AAAE by TSA to correct and clarify Rap Back requirements for individuals that hold multiple badges at an airport. Information follows in bold below in both sections that discuss the Rap Back mandate.
 
On February 1, TSA held its monthly conference call for airport stakeholders. The conference call was led by Alan Paterno, TSA's Industry Engagement Manager (IEM) for Airports and General Aviation in the office of Policy, Plans and Engagement (PPE). Paterno will handle industry engagement efforts for both General Aviation and Airports while the agency works to fill his position as IEM for Airports. TSA is also working to fill several PPE positions left open from retirements late last year, including Aviation Division Executive Director, Aviation Division Deputy Director, and Policy Director for Airports.
 
Fiscal Year 2024 DHS Appropriations
 
TSA Assistant Administrator and Chief Financial Officer Holly Mehringer provided an overview of the status of appropriations for DHS and its component agencies, including TSA. TSA is operating under their third continuing resolution which expires on March 8, 2024. The House and Senate have agreed on top-line allocations for both defense and non-defense spending and, just last weekend, agreed upon the allocations for each of the 12 appropriation bills. However, there is still a great deal of uncertainty around the DHS and TSA funding allocation for FY24, especially since DHS funding is tied to a larger debate on a border security supplemental bill.
 
Mehringer highlighted several significant differences between the House and Senate versions of the FY24 DHS appropriation bill, particularly regarding TSA's priority for full funding for their pay parity plan. Specifically, in their FY24 DHS spending bill, the House Appropriations Committee proposed to fund the pay raise for TSOs and included a provision that prohibits the agency from funding pay reforms for other TSA employees. In contrast, the Senate Appropriations Committee fully funded the pay raise for all TSA employees in their FY24 spending bill.
 
Although not discussed on the call, there are significant differences between the House and Senate bills on funding for programs important to airport operators, including exit lane staffing, the law enforcement officer reimbursement program, and state and local canine team funding. AAAE sent letters to House and Senate Appropriations Committee leaders highlighting and requesting full funding for airport priorities.
 
Policy, Plans and Engagement Update
 
Paterno provided an update on several pending policy issues, including:
 
Proposed Airport Security Program Amendment 23-02 on Short Term Baggage Storage in the Sterile and Public Areas of Regulated Airports: Comments on PNA 23-02 were due on January 31, 2024. TSA received 78 comments from 7 entities on issues ranging from physical search of the bags to records retention to issuing the final amendment as an optional template for use by airports with lockers in the sterile and public areas. TSA will now work to adjudicate the comments prior to issuing the ASP amendment as final.
 
Cybersecurity and Airport Fueling: TSA is finalizing an Administrative Order regarding cybersecurity of airport fueling operations. The Order will apply to fueling consortia that manage airport fueling at Category X and I airports covered by the Joint Emergency Amendment on Cybersecurity Performance-Based Measures and will include a combination of cybersecurity requirements included in the EA as well as previous airport regulations on cybersecurity. On Friday, February 2, 2024, at 2:00 p.m. ET, TSA is hosting a virtual engagement session to cover the intent behind the Order and provide a short overview of its content. TSA has invited representatives from each of the fueling consortia as well as covered airport operators, air carriers, AAAE, and other associations. If you are a covered airport (Category X or I) and have not yet received the log-in information, please reach out to AAAE's Colleen Chamberlain for the information. TSA plans an additional engagement session once the Order is issued. The agency is also working to publish a revised Joint National Alternative Measure (NAM) and Frequently Asked Questions (FAQ) document at the same time as Order issuance. The updated Joint NAM will clarify how airports and air carriers will interact with fueling consortia when it comes to the critical systems list and delegated/shared agreement in the Cybersecurity Implementation Plan. The updated FAQs (version 5) will include Order related questions.
 
Rap Back Deadline: TSA reminded airports that all individuals with airport SIDA and/or Sterile Area ID media must be subscribed in the Rap Back program by March 29, 2024. Government employees exempt from the CHRC are not covered by the Rap Back requirement. Airline employees covered by a CHRC/Rap Back certification to the airport must be subscribed by the airline.
 
TSA required all new badge applicants requiring a CHRC to be enrolled in Rap Back as of March 29, 2022. However, it was left to airport discretion how to cover all existing CHRC-covered ID media holders in the 2-yesr period that followed. If an airport plans to submit their remaining eligible badge populations all at once or in a large batch prior to the March 29 deadline, TSA cautions that new Rap Back subscriptions will generate new rap sheets which must be reviewed within 72 hours/3 business days per the Rap Back mandate.
 
On the call, TSA provided incorrect information that a Rap Back subscription was required for each SIDA and sterile ID media issued, stating as an example that an individual with three separate airport ID media (such as for separate employers at the airport) would need three separate Rap Back subscriptions. Based on follow-up from AAAE and questions from our airport members to the Transportation Security Clearinghouse, TSA has clarified that an active Rap Back subscription is required for SIDA and sterile area ID media. In other words, any person with an active SIDA or sterile area badge must have an active Rap Back subscription for the entire duration of being an active SIDA or sterile area badge holder (whether they have 1 badge or 10). 
 
Aviation Worker Screening
 
TSA is preparing to publish a new version of its Aviation Worker Screening Tool (Version 3). The tool serves two functions: 1) it calculates the number of hours of screening that is required based on the number of access points and secure Area ID holders and 2) it provides a randomized schedule for optional use by airport operators. The improvements being made will not affect the weekly hourly screening requirement calculation. The improvements will correct some issues related to the random scheduling function of the tool so that more credible results are produced. The updated tool is expected to be released in the coming weeks and once published it will be broadly communicated by TSA and available on HSIN.
 
TSA also plans to post excerpts from its ATLAS Procedures as promised. The ATLAS excerpts will include procedures for use of hand-held metal detectors, ETD, pat-downs, etc. These example procedures are for reference and intended to facilitate airport development of aviation worker screening procedures and training.  They are not required in any way. TSA plans to post the document to HSIN in February and cautioned airports to limit sharing of the SSI document to airport security leadership with a need to know.
 
Registered Traveler
 
Anne Walbridge, TSA's Traveler Populations Branch Manager, provided an update on the Register Traveler (RT) program and the progress that RT service provider Clear has made in meeting TSA requirements for enhanced identification verification. Clear has implemented a new enrollment process that meets TSA requirements and incorporates NIST's identification verification standards. As of January 30, all Clear participants must be enrolled (or re-enrolled) using the enhanced enrollment process or must present physical identification to the Traveler Document Checker (TDC). Based on Clear's progress with its new enrollment process, TSA has lowered the random rate for TSA TDC checks of Clear participants as of today. The random rate is now 20 percent per airport per day.
 
Based on a question from AAAE, TSA reported that they are working on an update to the RT Airport Security Program (ASP) template for another round of notice and comment. TSA acknowledged that certain requirements in the current RT ASP amendment, such as the personalized quiz for identify verification, are no longer required by TSA.
 
TRANSLATE Act Requirements
 
Jose Bonilla from TSA's Office of Civil Rights & Liberties provided an update on efforts to comply with the TRANSLATE Act, which requires TSA to implement a plan to ensure that TSA material disseminated in major airports is better understood by people accessing such airports, including by foreign language speakers and people with vision or hearing impairments.
 
Bonilla indicated that TSA efforts to comply with the TRANSLATE Act are part of a larger initiative to focus on the customer experience. TSA is currently finalizing its Customer Experience Roadmap, which was developed in coordination with industry stakeholders, and plans to publish it within 30 to 60 days. TSA is also updating its TSA Cares website to make it more user-friendly. Use of TSA Cares has increased 134% over the last three years and TSA continues to coordinate closely with airports and air carriers as needed.
 
TSA recently piloted a translation device known as Pocket Talk at 10 airports nationwide. According to TSA, the device provides an agile technology capability to help with translation at the checkpoint and throughout the airport environment to facilitate clear communication with passengers and airport employees. TSA will be piloting additional app-based technologies in the coming months. TSA is also developing messaging and signage in additional languages and making it available as needed at various airports.
 
Enrollment Service and Vetting Programs (ESVP) Update
 
Network Issues: TSA experienced a full network outage on January 30 around 1:00 p.m. ET that lasted approximately two hours and prevented the submission of STAs to TSA. The outage was due to a server patching at the DHS level that impacted several DHS and TSA systems and was not anticipated. These outages are rare, but TSA continues to work with the DACs on outage procedures and communications for any future unplanned outages.
 
Security Threat Assessment (STA) Update: STAs continue to process within 14 to 21 days. TSA has noticed an increase in enrollments since the start of the new year and are preparing for an anticipated enrollment surge with the Spring Break travel season quickly approaching.
 
TSA reminded airports that if an applicant has different naming conventions on identity documents TSA wants the naming convention from the List A document as the primary name and all other naming conventions on all identity documents should be submitted as aliases.
 
For applicants with Permanent Resident Cards (PRC), the Place of Birth (Country) cannot be the United States. Please refer to TSA's STA ‘Best Practice' Guide or send any questions to your Designated Aviation Channeler (DAC) or the TSA's Aviation Workers Inbox. 
 
Rap Back: Again, TSA reminded airports that the Rap Back mandate is set for full implementation on March 29, 2024. TSA provided the following information, which will also be included in an Aviation Worker bulletin that will be distributed soon.
 
Individuals enrolled in Rap Back from March 2022 and on must be subscribed into Rap Back under the Submitting Organization Number (SON, or Agency Code) tied to that organization only. Any Criminal History Records Check (CHRC)/Rap Back subscription submission must use the Submitting Organization Number (SON or Agency Code) associated with the submitter's organization. Specifically, airport operators are no longer permitted to submit CHRC/Rap Back subscriptions on behalf of an aircraft operator. Please refer to TSA Policy Clarification Notice (PCN) 2022-Multi-Program-002 or the Rap Back User Guide for guidelines on preventing "CHRC-by-Proxy" submissions. Fingerprints that have been retained by the FBI since 2016 are eligible to be reused for "new" CHRC/Rap Back subscriptions. 
 
Airports should ensure that each SIDA/STERILE employee has at least one (1) active Rap Back subscription (verified in FPRD), as least one (1) active badge, and their current STA. Airports who require subsequent/additional subscriptions for each employer/ID media can subscribe an individual multiple times, but they must review each instance of CHRI within the 3-business day timeframe. Multiple CHRCs require multiple Rap Back subscriptions; multiple badges do not – please see clarification from TSA in the notes below. Airports that accept CHRC certification letters for air carrier employees can use the "Rap Back Verify" feature in FPRD to check the status and existence of a Rap Back subscription. Airports must ensure that certification letters are present and available for review by TSA Compliance. 
 
By March 29, 2024, all covered individuals must be subscribed into Rap Back. Failure to do so will be treated as a compliance violation. 
 
CORRECTION: On the call, TSA incorrectly answered a question from an airport operator involving the need for multiple Rap Back subscriptions for multiple credentials. TSA failed to ask for further clarification on if the airport's local security program required a separate CHRC for each employer (which was a common practice at some airports prior to Rap Back). There is no TSA requirement to have more than a single Rap Back subscription for each covered individual, unless an airport's ASP mandates it. As this would require the review of multiple instances of CHRI, the existence of multiple subscriptions is likely not in the best interest of an airport operator's time or benefit. TSA apologizes for the confusion. 
 
Safe Skies Update
 
Jessica Grizzle from Safe Skies provided the following update:
 
PARAS 0059 Enhanced Scheduling Tool for Aviation Worker Screening is available by request to jessica.grizzle@sskies.org. The Excel tool allows users to specify airport opening and closing times, screening duration parameters (minimum time, maximum time, and time increment), number of weekly schedules to create, number of screening teams to schedule, a nominal travel and setup time. Access points and screening teams can be given descriptive names, and each can have a unique operational schedule. The tool's output is comprised of (a) individual team schedules for each screening team for each week and (b) an overall schedule for each week that shows all screening teams. Note that under current TSA policy, FSD approval of the schedule is required if using this tool.  Also note that this tool is separate and distinct from the tool being updated by TSA.
 
PARAS 0060 Strategies for Developing an Aviation Worker Screening Program has been awarded to LAM LHA – Neil Trethewey, Principal Investigator. Considering the condensed project timeline, outreach to schedule interviews and focus groups will begin immediately. Please contact jessica.grizzle@sskies.org with questions or to indicate your interest in participating.
Safe Skies recently issued the following ASSIST reports:
•SSDA—24-001 Athena Weapons Detection Aviation Worker Screening System – San Diego International Airport
•SSDA—24-002 Thruvision WalkTHRU Aviation Worker Screening System – San Diego International Airport

anna.hamilton@sskies.org or navigate to the Safe Skies Conference area on HSIN to download them. 
 
TSA Compliance Enforcement on STA Data Corrections
 
AAAE raised a significant concern on the call regarding TSA's heavy-handed approach regarding data submission and data corrections for Security Threat Assessments. We have heard from several airports that have been issued LOIs or Warning Notices for unintentional data errors and data corrections that were made prior to STA approval and/or badge issuance. TSA Compliance only briefly addressed the issue, stating they were working with TSA's Intelligence and Analysis office on data and vetting discrepancies. TSA clarified that ESVP is not driving the compliance initiative; ESVP remains focused on working collaboratively with airports on outreach, training and sharing of best practices. TSA stated that the issue is being worked and discussed internally. Airports on the call encouraged TSA to take an outcome-focused approach and urged closer collaboration and communication with airports. AAAE plans to continue to work with TSA for greater transparency on the issue.