ATA and AEA Urge DHS Secretary Chertoff that steps be taken to coordinate APIS Quick Query and Secure Flight

October 27, 2005

The Honorable Michael Chertoff
Secretary
Department of Homeland Security
3801 Nebraska Avenue, NW
Washington, DC 20528

Dear Mr. Secretary:

Earlier this year we wrote you expressing our serious concerns with the suggestion that the Department (DHS) was considering a requirement for Advanced Passenger Information (API) one hour prior to a flight’s department to or from the United States (APIS-60). Such a requirement would, as we indicated have serious negative consequence for international air transportation. We greatly appreciate the fact that our concerns are being listened to.

More recently, as part of the ongoing related effort to resolve passenger pre-screening concerns, we have been involved in discussions with both the Bureau of Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) regarding their respective efforts and plans to assume full responsibility for all prescreening of airline passengers. This would allow for elimination of selectee and no-fly lists administered by the air carriers as well as addressing the APIS-60 issue. We applaud these efforts and we are eager to work with the Department and provide our support.

Unfortunately, while both agencies are headed to the same general goal, it appears that there is a lack of full coordination of their respective efforts. As a consequence, there is a serious risk that extremely limited resources will be wasted in the development of analogous programs to effectively accomplish the same end result, all but with one system working domestically and the other internationally. Obviously, we are all eager to avoid such inefficiencies and we are hopeful that a single, unified system will be developed and deployed in the near term.

As a result, we are urging that steps be taken at once to coordinate and integrate both the CBP’s APIS Quick Query (AQQ) initiative and the TSA Secure Flight program. Both should be designed to function through coordinated information feeds and avoid unnecessary duplication of communications, programming and information requirements.
Ideally, from an airline industry point of view, a real-time, interactive passenger prescreening process should incorporate on a number of key features:

• They should supersede the No-Fly Lists and reduce the amount of redundant data required from the airlines.
• Response time for a “board/don’t board” message should be no greater than 2 seconds per passenger in order to avoid additional delays at check in and boarding.
• Timeframe for implementation should be consistent with airlines’ financial and technical constraints.
• They should be compatible with other interactive systems such as the Australian Advanced Passenger Processing (APP).
• They should remain operational until the flight departure time to permit transfer passenger handling and accommodate irregular flight operations.
• The number of “no-boards” or referrals must be manageable and the identification parameters set appropriately.
• The Government should provide for rapid resolution of “no-boards”.
• Overall development costs should be born by the government and technical specifications must not result in major overhauls of airlines IT systems at their own expense.

Please be assured that we are absolutely committed to working with DHS to develop the best possible passenger prescreening system and will do everything within our ability to advance that goal.

As always, we greatly appreciate your taking our concerns into consideration.

Sincerely,

cc CBP Commissioner, Robert C. Bonner
TSA Administration, Kip Hawley

ATA Member Airlines: ABX Air, Inc., Aeromexico*, Air Canada*, Air Jamaica Ltd.*, Alaska Airlines, Inc., Aloha Airlines, Inc., America West Airlines, Inc., American Airlines, Inc., ASTAR Air Cargo, Inc., ATA Airlines, Inc., Atlas Air, Inc., Continental Airlines, Inc., Delta Air Lines, Inc., Evergreen International Airlines, Inc., FedEx Corporation, Hawaiian Airlines, JetBlue Airways Corp., Mexicana*, Midwest Airlines, Inc., Northwest Airlines, Inc., Polar Air Cargo, Southwest Airlines Co., United Airlines, Inc., UPS Airlines, US Airways, Inc. *Associate Member
ATA, 1301 Pennsylvania Avenue, NW, Suite 1100, Washington, DC 20004 www.airlines.org

AEA Member Airlines: Adria Airways, Aer Lingus, Air France, Air Malta, Alitalia, Austrian, bmi, British Airways, Cargolux, Croatia Airlines, CSA, Cyprus Airways, Finnair, Iberia, Icelandair, Jat Airways, KLM, LOT, Lufthansa, Luxair, Malev, Meridiana, Olympic Airlines, SAS, SN Brussels Airlines, Spanair, SWISS, TAP Air Portugal, Tarom, Turkish Airlines, Virgin Atlantic Airways AEA, Avenue Louise 350B – 1050 Brussels, 32 (0)2 639 89 99, www.aea.be

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