Security Policy Alert: TSA Monthly Conference Call Summary for August 2021

August 5, 2021

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:

TSA PreCheck Expansion
TSA PreCheck enrollments have rebounded and are now exceeding pre-pandemic levels. Enrollments in June and July 2021 outpaced June and July 2019 enrollment levels. In July, over 215,000 individuals enrolled in TSA PreCheck '“ over 10,000 individuals per day. In addition, TSA PreCheck customers continue to move through security quickly. In July, 96% of TSA PreCheck travelers waited 5 minutes or less.
 
TSA continues to seek ways to grow TSA PreCheck. As required by the TSA Modernization Act of 2018, in January 2020, TSA selected additional enrollment providers to offer TSA PreCheck enrollment. TSA expects that the launch of new enrollment providers will boost TSA PreCheck enrollments through increased enrollment locations, additional price points and offerings, and increased marketing. On July 9, TSA issued a Federal Register Notice announcing that new enrollment providers would be able to set their own price point for TSA PreCheck enrollments and renewals. The $85 price point will remain in place for individuals who wish to enroll via the current enrollment offering, under the Universal Enrollment Services contract. 
 
TSA estimates that new enrollment providers will begin operations by the end of the year, though this is dependent upon them meeting the remainder of TSA requirements, including an IT security review process that focuses on protection of PII and biometric and biographic information provided by applicants.
 
TSA expects that the new enrollment providers will gradually roll out operations. When a new enrollment provider launches, it will likely open one or two enrollment locations. Once the enrollment provider has successfully launched, it will gradually roll out nationwide. Enrollment providers can begin operations once they have met TSA requirements; TSA is not requiring all three enrollment providers to meet the requirements before an individual enrollment provider can begin operations.
 
Policy, Plans and Engagement Update
Proposed ASP Amendment TSA-NA-16-01C: On June 28, TSA posted the proposed ASP National Amendment, TSA-NA-16-01C: Inspection of Merchandise and Consumables Intended for Clubs and Lounges in the Sterile Area for notice and comment. The purpose of the update is to clarify that the airport operator would not be responsible for inspecting merchandise and consumables designated for aircraft operator owned or operated clubs and lounges in the Sterile Area.  

TSA made some other clarifications throughout the proposed amendment, including modifying the definition of 'œcommercially prepared'; clarifying that inspected merchandise must be locked, attended to, or monitored to ensure there is not any unauthorized access; and clarifying that the record of each inspection must include when the inspection was started and completed.

The 45-day comment closes on August 13. Instructions for submitting comments are found in the transmittal memo. As always, AAAE will be submitting comments on behalf of our airport members. As discussed on the AAAE Transportation Security Services Committee call yesterday, AAAE will focus its comments on the definition of 'œcommercially prepared' and how the proposed language could introduce significant new and expansive inspection requirements. 

Cyber Incident Reporting Requirements: Earlier this year, TSA solicited comments on proposed cyber incident reporting requirements as part of the TSA-NA-14-01 series. Comments were due in April. 

Following the recent cybersecurity attack on a pipeline operator, TSA has issued two pipeline security directives related to cybersecurity and TSA is examining the appropriate path forward for reporting cybersecurity incidents for all modes of transportation. Depending on the outcome of those discussions, TSA may need to repost any incident reporting requirements for the aviation industry for a second round of notice and comment.

Ramp Movement ASP Amendment: Last week, TSA issued as final ASP National Amendment TSA-NA-21-02 which cancels and supersedes the original FAA amendment from 1993. The ASP amendment covers ramp movement access for foreign and domestic flight crews and others. 

In response to questions about the document'™s serial number, TSA explained that earlier this year, the agency released a proposed ASP National Amendment, also with the TSA-NA-21-02 serial number, that proposed new vetting requirements for small airports. TSA then issued this ASP National Amendment in final with the same serial number. Since the proposed amendment is not part of the ASP, there should not be any issues, but TSA understands the confusion. TSA is considering issuing all future proposed ASP National Amendments with a simplified serial number of the year followed by two Xs, such as TSA-NA-21-XX and include the subject title. 

Rap Back Mandate: Acting Executive Assistant Administrator for Operations Support Tom Bush has approved the multi-program change to mandate the use of Rap Back for airport operator, AOSSP air carrier, and Full All-Cargo AOSSP carrier CHRC populations. Before this can be issued, TSA needs the Administrator'™s approval for a regulatory exemption that will be published in the Federal Register and will permit the agency to issue the final program changes. TSA anticipates publication in the Federal Register will occur before the end of this month. While the regulatory exemption is only related to the air carrier AOSSP change, TSA has decided to hold all program changes for issuance until the same time.  

TSA expects the program changes will be issued with a six-month effective date and a two-year implementation timeframe to have all applicable CHRC populations subscribed to the program. In the meantime, TSA is working on a Security Directive 1542-04-08 series update to ensure that the SD and Rap Back requirements do not conflict. AAAE requested that airports and the Quarterly Airport Security Review be involved in working with TSA on any SD updates.

Later in the call, Enrollment Services and Vetting Programs reported that there are 236 airports and 19 air carriers participating in Rap Back. TSA has seen significant increases in enrollments as well as Rap Back Notifications (RBNs). TSA reminded airports to ensure they are reviewing the RBNs in a timely manner and click the 'œcomplete the review' in the FPRD. TSA also issued an updated Rap Back User Guide on July 24 which is available on both HSIN and FPRD.
 
For the 90 or so airports not yet participating in the Rap Back program, TSA stands ready to assist and will be hosting Privacy Informational Briefings on August 31, September 1 and 2 for any airports interested in signing up in advance of the mandate. Local AFSD-Is can provide additional information about the briefings.
 
Prohibited Items List Modification Process: Based on GAO recommendations and requirements under the TSA Modernization Act, TSA has enhanced its process for modifying the Prohibited Items List (PIL). TSA'™s Requirement and Capabilities Analysis'™ (RCA) oversees this process. Formal requests for changes to the PIL are submitted by the public to TSA, usually through the Civil Rights and Civil Liberties office. TSA'™s Executive Steering Committee and RCA review the requests and conduct risk analysis on valid requests to either add or remove items from the PIL. TSA then provides notification to industry to solicit industry comments and feedback. Industry comments are then reviewed by the Executive Steering Committee and the TSA Administrator. If approved, the PIL change is then published in the Federal Register and the 'œWhat Can I Bring?' web page is updated. 

As an example of industry engagement as part of the PIL modification process, TSA pointed to the recent request for PIL changes regarding competitive shooting unpressurized air cylinders which TSA shared with industry for comment. TSA received about 16 comments related to the proposed change, mainly from air carriers, pilots, law enforcement and the FAA. TSA will once again be posting on HSIN the proposed change with certain clarifications based on the comments received for an additional round of comments.

Third-Party Canine Screening of USPS Cargo: In 2019, TSA and the United States Postal Service (USPS) conducted a pilot at Phoenix Sky Harbor International Airport to use third-party canines to screen USPS cargo. Based on the success of the pilot program, USPS has expanded the program to 13 domestic airports and hopes to add an additional 15 airports in the near future. USPS pays for the third-party canines and selects the airports. Canine screening is conducted both on and off airport property. TSA works in advance with all stakeholders, including the FSD, air carriers, airport operators, law enforcement and the canine companies, prior to commencing screening operations of USPS cargo using third-party canines. 

Enrollment Services and Vetting Programs Update
Manual Name Check Update: The FBI has enhanced its policy related to individuals who are physically unable to provide fingerprints, specifically double amputees. This category now includes those who are permanently incapable of physically providing legible fingerprint images due to amputation, illness, or some injury affecting their hands or fingers. If, after two rejections for poor quality, the airport or aircraft operator determines that the individual meets the definition of 'œpermanently incapable of physically providing legible fingerprint images due to amputation, illness, or some injury affecting their hands or fingers', then the airport or aircraft operator should check the box entitled 'œDouble Amputee' on the FPRD screen and complete the on-line form. TSA issued an Aviation Worker bulletin on July 19 detailing this change which can be found on HSIN. 
 
Stakeholder Engagement: ESVP staff are visiting airports across the country to discuss Rap Back, the Centralized Revocation Database, and other topics. TSA will continue to reach out via AFSD-Is to schedule either in person, virtual, or blended meetings. On the call, TSA shared some early lessons learned from their perspective: 
·      Additional Resources: As TSA moves towards more participation in Rap Back, eBadge and other programs, TSA recommends each airport establish a robust staff with FPRD access based on badged population.
·      Increased FPRD Access: According to TSA, if one or two people are primarily responsible for adjudication and work queue review, volume could make for some long days. More people in FPRD can help clear the queues of cases with no record, so the Airport Security Coordinator or Adjudication team can focus on applicants with records.
·      Communication: TSA encouraged airports to reach out to the Rap Back team, local TSA Compliance team, and their DAC if they have any questions, concerns or need additional information. As passenger throughput is returning, TSA wants to answer any questions airports may have. 
 
STA Processing Delays: TSA reported that enrollment applications for Aviation Workers have increased by three percent from July 2019 to July 2021 and have increased by more than 114 percent from July 2020 to July 2021. According to TSA, more than 68 percent of applications are returned within 10 days. The remaining 32 percent of applications, which require manual review, are returned to airports within 10-30 days. Less than 1 percent of applications require a third level, manual review by USCIS. Most of these cases belong to applicants who were Lawfully Permanent Residents but have since become naturalized citizens. The applicant submits a new document to the airport; however, there is still a mismatch because the documents do not match the USCIS response.  
 
AAAE commended TSA for its efforts to continue to monitor STA processing times and prioritize resources to minimize extended wait times. AAAE stressed than 10 days is still a significant delay in this competitive job market and qualified applicants will look elsewhere during that time. 
 
Computed Tomography (CT) Deployment
TSA'™s initial purchase of 300 Smiths CT machines have been fully deployed and are in use at airports across the country. Through-put concerns have normalized for the most part and, as of now, CT throughput matches AT throughput in standard lanes. 

For the program of record, TSA is currently testing three different configurations:
·      Base, which is CT Only;
·      Mid-size, which is CT plus automatic infeed and automatic diverter;
·      Full-size, which is CT integrated with Automatic Screening Lanes (ASL). Full-size configurations have the highest through put but also require the most space.
 
TSA intends to make a purchase of mid-size systems later this month and deployment of these systems will begin in the latter part of this calendar year. TSA will use a hub and spoke approach for deployment, placing equipment from like vendors at spoke airports from a main hub.

The next purchase of base and full-size is scheduled for end of this calendar year. TSA would like to deploy as many full-size systems as possible depending on space.

TSA is investigating two different configurations of remote screening to increase efficiency of the CTs. In addition to remote screening in a separate room, TSA is also exploring cross-lane remote screening wherein any operator at ant CT can review images.

TSA is also investigating image on alarm only, with explosives and prohibited item algorithms that would enable officers to only review bags which alarm.

Safe Skies Update
Jessica Grizzle from the National Safe Skies Alliance provided the following updates on both the PARAS and ASSIST programs.
 
PARAS: The following PARAS documents will be published later this month:
·      PARAS 0030 Guidance for Access Control System Transitions - The objective of the research was to produce guidance detailing considerations, pitfalls, and lessons learned during access control technology selection, procurement, and implementation. The document discusses various Access Control System (ACS) configurations, regulatory context and implications, six phases of the ACS transition process from planning to operations/maintenance, technology trends, and legal implications/data protection considerations. 
·      PARAS 0031 Airport Response to Unmanned Aircraft System (UAS) Threats - The objective of this research was to produce guidance to assist airports in working collaboratively to plan for and respond to UAS threats. The document covers the various stakeholders involved in response and how to engage them in the planning process, methods for determining if an unauthorized UAS is a threat, response considerations including what information needs to be disseminated, how best to convey that information and to whom it should go, and recovery from an event including how to determine an all-clear status and understanding the subsequent investigation. 

PARAS 0043 Guidance for Security Operations Center (SOC) Planning and Design has been awarded to EVANS Consoles Incorporated with Kerri Knox serving as Principal Investigator. The objective of this research is to develop comprehensive guidance to assist airports with SOC planning, design, and implementation. The research team is interested in talking to airports who are undergoing or have recently completed work on an SOC. The centers could be a greenfield project, repurposing of an existing space, or an update to an existing SOC. The goal is to collect detailed information about what has been done successfully and what lessons were learned along the way. 

Safe Skies is currently accepting Problem Statements for FY 2022 PARAS projects. Submissions are due September 1. Problem Statements form the basis of all PARAS projects and are descriptions of security problems or questions for which airports needs an answer. Although all PARAS projects must have a security component, the range of topics is still quite broad. Examples from ongoing projects include UAS threats, access control systems, credentialing efficiency, security of cargo operations, and airside vehicle access gates. Additional topic examples can be found in published guidance that is available for free download on the Safe Skies website. Additional information regarding PARAS can be found here: https://www.sskies.org/paras/. Please contact Jessica.grizzle@sskies.org with any questions or for access to a simple Problem Statement template. 

ASSIST: Two thermal analytic systems were evaluated for perimeter intrusion detection at San Antonio International Airport. The resulting evaluation reports below are available on HSIN in the Safe Skies conference. 
o  iOmniscient iQ-Infinity Intelligent Thermal Video Analytic Application, San Antonio International Airport
o  Senstar Symphonyâ„¢ 7 Thermal Video Analytics System, San Antonio International Airport
 
TSA Staffing and Hiring Update
 Since the beginning of the year, TSA has on-boarded 4,680 officers and are on track to have over 8,500 by year'™s end. On Monday, TSA on-boarded 460 officers and have over 400 scheduled for the next on-boarding on August 15. This is an improvement over the last 6 months and TSA is planning to continue this increased pace of hiring all the way through next June.          

In addition to hiring, TSA shared other efforts that are helping to ensure airports are staffed to required levels:    
o  Increased NDO deployments, with currently over 400 officers deployed to 47 airports.
o  Increased hours for Part Time officers.
o  Readiness incentives for officers with perfect attendance at locations with staffing challenges. This has decreased the use of sick leave.
o  Increased use of overtime (averaged less than one percent for the first half of the year with over three percent allocated for second half of the year).
o  Hiring incentives that should also help delay some of the first-year attrition due to a second-year payout
o  Increased retention incentives to include additional airports
 
TSA is currently working with airport Scheduling Operations Officers to develop staffing allocations for next year. Fiscal Year 2022 staffing allocations will be based on the greater of pre-pandemic FY19 levels or, for airports that have met or exceeded 2019 passenger volumes, current FY21 plus four percent for growth. TSA plans to release these allocations in mid-September and will brief industry in early October on the Resource Allocation Plan (RAP) FY22 process. 

Next TSA Conference Call
The next TSA conference call for airport stakeholders is scheduled for Thursday, September 2 at 1:00 p.m. ET. Please note the updated conference call number and passcode: 1-800-857-5826 and passcode 9596778.

Based on questions and comments from both AAAE and ACI-NA, TSA plans to address policy interpretations regarding CHRC and training record retention on the next monthly conference call.