Summary of TSA's Monthly Conference Call for Airport Stakeholders

Summary of TSA's Monthly Conference Call for Airport Stakeholders 
May 2, 2024

On May 2, 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).
 
Policy Updates
 
In response to a question on last month’s TSA call for airport stakeholders, TSA has posted on HSIN the proposed national amendment on law enforcement officer (LEO) procedures for additional comment given the elimination of funding for the LEO reimbursement program and stipends for the state and local LEO-led canine teams.  TSA will still review and respond to all comments submitted last year when the proposed ASP amendment was first issued for notice and comment.  Airports do not need to resubmit their previous comments.  TSA is providing this opportunity to submit any new or revised comments that may be driven by the change in the funding programs.  New or updated comments are due on June 1.
 
TSA still plans to issue an updated proposed Airport Security Program (ASP) amendment for airport sponsors of the Registered Traveler program but did not have a definitive timeframe on today’s call.  TSA is also working internally on guidance to TSA inspectors given that several requirements in the current RT ASP amendment are no longer required by TSA for the RT service provider Clear.
 
TSA is finalizing work on a procedural rule, which would be issued without notice and comment, to clarify CHRC recordkeeping records.  TSA hopes to provide the draft rule to DHS for clearance within the next several months.
 
Flight Training Security Program
 
Yesterday, TSA published a final rule in the Federal Register regarding the Flight Training Security Program.  The final rule goes into effect on July 30, 2024.
 
The Flight Training Security Program (FTSP), which has been in effect since 2004, covers flight training providers, including individual Certified Flight Instructors, who provide training to all flight students.  All non-citizen flight trainees are subject to a Security Threat Assessment (STA), which is a TSA background check conducted on all databases relevant to confirming an individual’s identity, that the individual possesses lawful status in the United States, and that the individual does not pose a security threat.  
 
In finalizing the FTSP regulation, TSA addressed industry recommendations from the Aviation Security Advisory Committee (ASAC) to include critical modifications that enhance the program’s effectiveness and ensure the same stringent security standards. TSA expects these changes to maintain the security benefits of the program while reducing delays and fees, assisting in the tracking of candidate training events, and supporting the portability of a candidate’s STA between providers.
 
The FTSP final rule also clarifies requirements for flight training providers and contractors to maintain records of their flight training requirements.  The flight training provider is responsible for documenting leasing agreements unless that provider cannot register with TSA, in which case, the lessor of the simulator must register with TSA as a provider.  The final rule also allows for electronic recordkeeping.
 
The FTSP final rule also makes the STA time based rather than event based.  The STA will be valid for five years and will cost $140.  It also allows qualified individuals to pay a reduced fee if they already hold a comparable DHS or TSA STA, such as for Global Entry or PreCheck.
  
This final rule includes other modifications that incorporates previously issued clarifications concerning what type of training is covered by the regulation, while eliminating the previous four weight-based categories of training and replacing them with specific training events.  It aligns the FTSP with TSA’s other regulated programs by requiring flight training providers to designate a security coordinator to serve as a security liaison with TSA.  It makes technical amendments to consolidate several definitions applicable to the FTSP that are also used in other parts of TSA’s regulations.  It consolidates provisions related to TSA’s statutory inspection authority in 49 CFR 1503.207.  It makes security awareness training a biannual requirement.   
 
Enrollment Services and Vetting Programs Update
 
Rap Back Update: TSA plans to issue a significant update of the Rap Back User Guide soon.  The update captures many lessons learned and best practices discovered during the two-year implementation period.  Updates include added clarifications on Fingerprint errors and the Manual Name Check (MNC) process to specify when additional fingerprints must be taken and what to do when language reads “treat as no record found”; clarifies an airport’s responsibility to implement internal controls that ensure any automated processes or transactions conducted on their behalf by third party vendors are accurate and in accordance with TSA regulations and policies; clarifies that the Rap Back Identity History Summary (RBIHS) transaction can also be used if the Rap Back Activity Notification (RBN) has no hyperlink to the rap sheet.
 
As a follow up to last month’s discussion surrounding “999999999” Social Security Numbers (SSN) on Security Threat Assessments, TSA today stated that SIDA badges are the only badge type which require SSNs at submission. TSA can accept ‘BLANK’ or ‘NULL’ values for STERILE, and AOA/Public Badges. TSA’s main reason for this relates to data quality; TSA does not want incorrect or ‘made up’ SSNs accompanying STERILE, AOA, or Public Badges. If an airport worker had one of these badges and then needed a SIDA Badge, the SSN update would need to be included (TSA refers to this as a Subprogram Change). As a reminder the fingerprint cases for these subprogram changes cannot be updated by a Rap Back Maintenance Transaction-Replace/Append Biographic data (RBMNT-R) transaction to change the SSN from BLANK or “999999999” to the correct SSN. In order for the case to be correct, a Rap Back Maintenance Transaction-Cancel (RBMNT-C) must be submitted for the original case, and a case submitted/re-subscribed with the corrected information. 
 
As a best practice, TSA suggests for STERILE and AOA/Public Badges that either the correct SSN is submitted, or no SSN at all. TSA encouraged airports to continue to ensure trusted agents are reviewing the biographic data in the fingerprint machines before you submit them to the Designated Aviation Channeler and TSA to avoid additional transactions to complete/update the record.
 
Airport operators who accept CHRC certification letters from aircraft operators should note that any enrollment date on those Certifications is likely is in the past. There is no requirement to have an updated enrollment date, as the certification is a one-time requirement.
 
Security Threat Assessment (STA) Update: STAs continue to process within 14 to 21 days.  TSA experienced an increase in enrollment volume over spring break and are preparing for what they refer to as the summer surge for enrollment volume.
 
As a reminder, TSA generally wants the naming convention for the STA to match what is on the ‘List A’ document (such as a US Passport). If there are discrepancies between Identity Documents, TSA wants each different naming convention and will send data corrections for each different convention. If TSA returns that an applicant has an alias/AKA, please enter the alias/aka exactly as TSA directs. If an airport does not make the requested change, TSA cannot adjudicate the case.
 
For applicants with Permanent Resident Cards (PRC), the Place of Birth (Country) cannot be “US”. The PRC will list what the Country of Birth is. Please refer to TSA’s STA ‘Best Practice’ Guide or send questions to your Designated Aviation Channeler (DAC) or the Aviation Workers Inbox.

On the call, TSA ESVP thanked the following airports for hosting their teams for in-person and virtual stakeholder engagements over the last month: Ontario (ONT), Palm Springs (PSP), San Diego (SAN), San Bernardino (SBD), Long Beach (LGB), John Wayne (SNA), Charleston International Airport (CHS), Jacksonville International Airport (JAX) and Nashville International Airport (BNA). At the end of the call, TSA Compliance reiterated that the recent compliance activity related to STA data errors and corrections – which is still paused – was based on data generated by TSA’s Intelligence and Analysis office and not generated from ESVP’s site visits with airports.

Safe Skies Update
 
Jessica Grizzle provided the following update on behalf of Safe Skies.
 
The following open RFPs are available on the Safe Skies website here
o    PARAS 0062 Mitigating Impacts to Airport Security and Operations from Locally Hosted Major Events (Closing May 10)
o    PARAS 0064 AI in Airport Security (Closing May 24)
o    PARAS 0061 Ensuring Security Operational Readiness for New and Renovated Facilities (Closing June 7)
 
PARAS 0050 Public Safety and Security at On-Airport Rental Car Facilities has been finalized and is available on the Safe Skies website. The report consolidates methods, strategies, tools, and technologies that an airport can use to enhance security and public safety, and reduce criminal activity at on-airport rental car facilities.
 
PARAS 0060 Strategies for Developing an Aviation Worker Screening Program is underway and on track for July publication. 
 
PARAS 0059 Enhanced Scheduling Tool for Aviation Worker Screening is available for airports by request to jessica.grizzle@sskies.org. FSD approval of the schedule is required if an airport uses this tool. 
 
Safe Skies recently issued the following ASSIST reports: 
o    SSDA—24-014 Senstar FiberPatrol® FP1150 Fence-Mounted Intrusion Detection System – Pittsburgh International Airport
o    SSDA—24-015 FiberRanger FR302 Fence-Mounted Intrusion Detection System – Pittsburgh International Airport
 
Reminder the following ASSIST reports are available and may be of interest for aviation worker screening: 
o    SSDA—24-001 Athena Weapons Detection Aviation Worker Screening System – San Diego International Airport
o    SSDA—24-002 Thruvision WalkTHRU Aviation Worker Screening System – San Diego International Airport
o    SSDA—24-0009 Rohde & Schwarz QPS Walk2000 Aviation Worker Screening System – Fort Lauderdale–Hollywood International Airport
o    SSDA—24-010 Evolv Express® Aviation Worker Screening System – Fort Lauderdale–Hollywood International Airport
o    ASSIST reports will be issued in May for 1) Liberty Defense and 2) Xtract one
 
Next TSA Conference Call
 
The next monthly TSA conference call for airport stakeholders is scheduled for Thursday, June 6 at 1:00 p.m. ET.  There will not be a TSA call in July.