Summary of TSA's Monthly Conference Call for Airport Stakeholders

April 4, 2024

On April 4, 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). On the call, TSA introduced two new members of the TSA PPE leadership team: Rob Rottman, Executive Director of PPE's Aviation Division, and Jackie Bester, Deputy Executive Director, Aviation Division.
 
Rottman previously served as the Director for Plans and Engagement since 2020.  He has over 25 years of government and private sector expertise in the transportation field.  Rob started with TSA in 2002 and has held a variety of senior executive service positions at the Federal Aviation Administration (FAA), TSA, and Department of Homeland Security developing national and international transportation policies and programs. He also served as the White House's National Security Council Director of Aviation and Surface Transportation Security across two Administrations. 
 
Bester has been with TSA since its inception in 2002, steadily advancing from a Supervisory TSO to various key roles including Transportation Security Manager, TSI, PSI, Supervisory PSI, and ultimately Branch Manager of the Principal Security Specialist (PSS) Section overseeing over 600 aircraft operators regulated by TSA. Bester has a B.A in Intelligence Studies and Homeland Security Studies from American Military University and is a US Marine Corps veteran.
 
LEO Reimbursement Agreement Program and Stipends for State and Local LEO-Led Canine Teams
 
At the request of AAAE, Holly Mehringer, TSA Assistant Administrator and Chief Financial Officer, joined the call to discuss the elimination of FY24 funding for the Law Enforcement Officer (LEO) reimbursement program and the stipend for state and local LEO-led canine teams. Due to budget constraints, the Administration's FY 24 budget proposed elimination of funding for these programs. TSA had hoped that Congress would find funding to maintain these programs as they have done in the past. Unfortunately, that did not happen and the final FY24 DHS appropriations bill that was signed into law on March 23 zeroed out funding for LEO reimbursement grants and stipends for state and local LEO-led canine teams. Mehringer stated that in a perfect world the agency would have notified airports as soon as March 24 but the agency needed time to work with the Office of Chief Counsel and the Program Offices to determine next steps and formalize guidance.
 
The Other Transactional Agreements (OTAs) that govern both programs were subject to appropriations and had a 30-day termination clause. Due to the lack of appropriations, TSA is enacting the 30-day termination clause, which means that airports can submit invoices for reimbursement for services provided from January 1 through May 1, 2024. Requests for reimbursements will not be accepted after May 15, 2024.
 
For the canine stipend program, TSA is working with law enforcement agencies with current canine agreements to convert to a new "no-cost" OTA. TSA explained that there are benefits to the canine program beyond the stipend, including receiving explosives magazines, canine explosives training aids, evaluations, training support, student classes, and canine replacements. AAAE asked if TSA would be open to negotiation on the OTAs given the lack of funding and TSA replied that the agency is aiming to get over 100 new agreements in place before May 1 to keep participants in the program and prevent a break in service. TSA hopes to be as transparent and flexible as possible but maintains that a certain of level of consistency and standardization is needed for the new agreements, which will also include responsibilities of program participants, including training standards and response times.
 
For the LEO Reimbursement Agreement (RA) Program, airport operators are still responsible for ensuring a law enforcement officer presence and response to security incidents at the checkpoints as well as in and around airports, in accordance with federal regulation and any applicable ASP provisions. However, after May 1, airports are not bound to any enhanced security measures that were included in the LEO RA OTA and related Statement of Joint Objectives.
 
Mehringer cautioned that the Administration's FY25 budget also calls for elimination of funding for these programs and stated that there is little appetite on Capitol Hill to increase funding. AAAE is advocating fiercely for the restoration of funding for these programs. Please see our Airport Action Alert and the related survey looking for your feedback to help our efforts on Capitol Hill.
 
Security Directive 1542-04-08 Series
 
TSA is finalizing changes to the next version of the Security Directive (SD) 1542-04-08 series which governs the Security Threat Assessment and background check process for airport badge holders. Expected changes include extending the minimum required badge renewal from two years to five years. This change would not impact any audit requirements and is intended to provide airports flexibility and discretion. TSA also plans to require submission of copies of identity documents for all applicants at the time of STA submission, which is a recommended best practice today. The requirement to provide copies of identity documents would go into effect on October 31, 2024 even though TSA is currently planning to issue the updated SD in July. The extended timeline provides airports with additional time to prepare and implement any process or technology solutions that may be needed to comply. Finally, TSA plans to clarify the timeframes required for badge revocation when a "Do Not Issue" status is issued. In an exchange with AAAE on the call, which provided feedback to TSA on this section as part of the Quarterly Airport Security Review and based on feedback from our airport members, TSA stated that the updated language will provide a reasonable timeframe for administrative DNIs, such as one business day. DNIs based on watchlist encounters with known or suspected terrorists and where the Federal Security Director is also notified would need to be revoked immediately as agreed to by the airport and FSD.
 
Aviation Worker Screening
 
TSA has released an updated version (version 3) of its aviation worker screening scheduling tool. Version 3 has been updated to improve the randomization of aviation worker screening scheduling. Version 3 replaces Version 2. Use of TSA's aviation worker screening scheduling tool is optional under the ASP amendment.
 
TSA also has posted on HSIN a training facilitation document that provides the ATLAS screening procedures and processes as an exemplar.
 
Enrollment Service and Vetting Programs (ESVP) Update
 
Security Threat Assessments (STAs): Processing times for STAs are currently maxing out at 14 to 21 days. TSA experienced its first surge in STA applications over the spring break travel period and are currently preparing for the expected summer surge in STA volume.
 
As a reminder, TSA generally wants the naming convention for the STA to match what is on the ‘List A' document. If there are any discrepancies between identity documents, TSA will send a data correction for each different naming conventions on the identity documents.
 
For applicants with Permanent Resident Cards (PRC), the Place of Birth (Country) cannot be the United States; the PRC should list the Country of Birth. TSA referred airports to the TSA STA Best Practices guide posted on HSIN for additional information. Airports may also send any questions to their Designated Aviation Channeler or the TSA Aviation Worker inbox.
 
TSA has received several questions about what the Place of Birth (POB) and Citizenship (CIT) values should be for applicants from U.S. Territories such as Puerto Rico, American Samoa, Guam, or the Federalized States of Micronesia. In these instances, the POB State or Country can be the Country code. For reference, Puerto Rico=PRI, Guam=GUM, American Samoa =ASM, the Northern Mariana Islands=MNP, and the US Virgin Islands=VIR. TSA can adjudicate the case and return an STA result as long as the case does not indicate foreign POB or CIT. TSA presumes in these cases that an acceptable birth certificate or other proof of U.S. Citizenship was obtained by the airport operator at enrollment. However, in these cases, the country of CIT must be the United States. TSA does not want "PRI, ASM, GUM", etc. as the CIT value. Using these codes in the CIT field will cause TSA to send data corrections back to the airport operator and will delay the STA response time. A specific note for Federalized States of Micronesia (FSM) and Republic of Marshall Islands (RMI): they will receive admission stamps in their passports upon admission by U.S. Customs and Border Protection (CBP). The 11 alphanumeric admission/departure characters on Form I-94 take the place of their Alien Registration Number ("A-Number") for those admitted under the Compacts who do not otherwise don't possess an A-Number. A specific note for Western Samoa: POB should always be "WSM" and CIT is wherever the applicant actually has citizenship (likely WSM or USA). WSM more likely than not will require manual adjudication so TSA encourages airports to remember to include the USCIS Registration/ARN at the time of STA submission.
 
Rap Back Update: As of March 29, the Rap Back mandate is now fully in place for airport operators. TSA thanked the more than 320 airports participating in the program, which now has just under one million active subscriptions. Full implementation of the Rap Back program represents nearly a decade long process evolving from voluntary participation from 2016 to 2022 to the required two-year subscription process for all covered individuals. TSA expects to release an updated version of the Rap Back User Guide (RBUG) within the next 30 days; as a reminder, under the Rap Back mandate, the RBUG is included by reference in airports' Airport Security Programs.
 
On the call, TSA stated that the agency cannot accept nine 9s (999999999) in the field for Social Security Numbers (SSN). Under the Security Directive 1542-04-08 series, SSN is a required field for a Security Threat Assessment. For the Rap Back program, according to TSA, the SSN cannot be improperly formatted with nine 9s. In addition, if submitted, these records cannot be updated by a Rap Back Maintenance Transaction-Replace/Append Biographic data (RBMNT-R) transaction. In order for the case to be corrected, a Rap Back Maintenance Transaction-Cancel (RBMNT-C) must be submitted, and the case must be re-submitted/re-subscribed with the corrected information. In response to a question on the call, and in a follow-up e-mail to AAAE, TSA stated that the field should be left blank if the SSN is not required (such as for certain badge types).
 
TSA also advised airports to ensure that the trusted agents are reviewing the biographic data in the fingerprint machines before it is submitted to the DAC and TSA to avoid any additional transactions to complete or update the record.
 
ESVP remains available for outreach, training and to answer any questions related to Rap Back processes, best practices, and clarifications. TSA encourages airport operators to continue to communicate their observations and concerns through their local TSA compliance teams and the Rap Back inbox. The TSA ESVP team also continues to host stakeholder engagement sessions with airports both virtually and in-person.
 
Safe Skies Update
 
Jessica Grizzle from Safe Skies provided the following update:
 
PARAS 0046 Security at Tenant and Third-Party Controlled Facilities at Airports is now available for free download on the Safe Skies website here. This guidebook builds on the information in PARAS 0025 Security Regulatory Compliance at Tenant Facilities and identifies security solutions with straightforward applications that can improve everyday tenant security operations and processes. 
 
PARAS 0045 Implementing Biometric Technology at Airports is also available for free download on their website here. The guidance is intended to assist airports and their stakeholders in making informed decisions regarding the potential use of biometrics for various functions at airports, including aviation worker access control and passenger processing.
 
Safe Skies recently issued the following ASSIST reports, which can be found on the Safe Skies conference on HSIN or requested directly from Safe Skies: 
 
SSDA—24-003 CrowdScan Crowd Density Analytic Sensors – Seattle-Tacoma International Airport
 
SSDA—24-004 Telaeris XPressEntry XPID200-Series Handheld Badge/Biometric Reader – Lexington Blue Grass Airport
 
SSDA—24-005 Magnasphere® Anti-Climb System – Safe Skies Perimeter Test Facility
 
SSDA—24-006 Magnasphere® Motion® MSK-101 Intelligent Motion Sensor – Safe Skies Perimeter Test Facility
 
SSDA—24-0009 Rohde & Schwarz QPS Walk2000 Aviation Worker Screening System – Fort Lauderdale–Hollywood International Airport
 
SSDA—24-010 Evolv Express® Aviation Worker Screening System – Fort Lauderdale–Hollywood International Airport
 
Safe Skies anticipates additional reports on walk-through screening technology that may be used for aviation worker screening to be available at the end of April or early May.
 
Registered Traveler
 
Several airports on the call asked about the status of the Registered Traveler (RT) ASP amendment update. TSA issued a proposed ASP amendment for airport sponsors of the Registered Traveler program for notice and comment last year. TSA reported earlier this year that the agency would be reissuing the proposed amendment for an additional round of notice and comment. TSA did not have a timeframe for the second round of notice and comment. In the meantime, TSA has been working directly with Clear, currently the sole Registered Traveler service provider, and has relieved the company of several requirements that are currently outlined in existing RT ASP language. Airports expressed frustration that their ASP contains outdated requirements and, in at least one case, airports must still audit these outdated requirements even though they are no longer in effect per TSA direction to Clear.
 
Next TSA Conference Call
 
The next monthly TSA conference call for airport stakeholders is scheduled for Thursday, May 2 at 1:00 p.m. ET.