IDSR Task Force

 

Genesis and Goal of IDSR

As a proactive measure and in consideration of the significant security costs borne by airports, ACI-NA constituted a task force, comprised of staff and several airport representatives, to conduct an in-depth review of current security measures. The In-Depth Security Review (IDSR) task force is comprised of staff and representatives from two Category X, two Category I, and two Category II airports.

In conducting the review, the task force evaluated all existing security requirements to identify those which are duplicative, stale or no longer make sense given the evolution of the threat and/or implementation of countermeasures. Subsequent to the meeting, ACI-NA met with key TSA representatives to involve the agency in the process. TSA committed that senior Legal, Compliance and Policy officials would participate in IDSR.

In order to ensure coordination and since the industry speaks more loudly with one voice, ACI-NA invited AAAE and the Chair of its Security Committee to participate in the meetings. At a subsequent meeting, the group identified numerous security requirements that need to be revised, clarified or rescinded and has been working to ensure the modification of existing requirements to provide additional flexibility for airports through the development of sustainable security measures.

IDSR includes representatives from:

  • TSO Office of Security Policy and Industry Engagement
  • TSA Office of Security Operations
  • TSA Office of Chief Counsel
  • ACI-NA Staff
  • ACI-NA Public Safety & Security Committee Leadership
  • AAAE Staff
  • AAAE Transportation Security Policy Leadership

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IDSR Task Force Establishes Ground Rules

In order for IDSR to be successful in achieving its goals, the IDSR Task Force agreed that it was important to set and adhere to the following ground rules:

  • As existing security measures are modified – to remove or rescind duplicative or outdated procedures, provide additional clarity and flexibility – and incorporated into proposed ASP Amendments or guidance  are created, there should be no new requirements.
  • Measures contained within various Security Directives (SDs) should be divided into groups and placed into categories for comprehensive review by IDSR.  For example, requirements for patrolling the airport were consolidated into one document.
  • TSA removes the specific security measure across various SDs and prepares a draft Proposed ASP Amendment or Guidance Document.  The affected SDs would remain active until all the measures within the SD have been rescinded.
  • Once the review process is completed for the list of security measures in an SD, then it will be re-issued with a short-term expiration date—thereby expiring the SD forever.
  • Any proposed amendment does not supersede previously approved Alternative Measure.

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Security Directive Not Included in IDSR

SD 1542-04-08G is not included in the in-depth security review.  TSA advised that several of the measures outlined in 1542-04-08G will be moved to a notice of proposed rulemaking (NPRM).

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ASP Amendments vs. NPRM Process

ACI-NA PS&S Leadership sought to provide airports immediate relief to unnecessary requirements contained in security directives whose expiration dates were “indefinite.”  Since the Notice of Proposed Rule Making (NPRM) process is lengthy, IDSR Task Force members agreed to identify other vehicles to incorporate applicable security measures:

  • Proposed ASP Amendment
  • Notice of Rescissions, or
  • Guidance documents

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IDSR Review Process

Through the work of IDSR, security measures are As TSA prepares draft Proposed ASP Amendments, each association is offered the opportunity to reach out to a small group of airports to comment on the draft.  ACI-NA utilizes the six airports that originally conducted the initial review to solicit input that is subsequently provided to TSA in response to draft proposed ASP Amendments.  Once complete, TSA issues a Proposed ASP Amendment for a 30 or 45 day comment period to all airports.

ACI-NA through IDSR and with the input and guidance of this group has been working to provide airports additional flexibility in complying with the requirements as they are being incorporated into proposed ASP changes, while recommending the rescission of those that are duplicative or no longer applicable. In addition to providing an opportunity for IDSR to recommend increased flexibility prior to the measures being incorporated into proposed ASP changes, all airports have the opportunity to submit comments in response to the measures contained in the proposed ASP changes, something they were unable to do when the measures were initially issued via Security Directive.

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Airport Representation (Est. 2009)

Category X:     Orlando International Airport

Category X:     Hartsfield-Jackson International Airport

Category I:      Spokane International Airport

Category I:      Tampa International Airport

Category II:     Savannah Hilton Head International Airport

Category II:     Gerald R. Ford International Airport

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Expansion Airport Representation (Added 2011)

As security measures identified under the In-Depth Security Review began to get more complex, IDSR Task Force expanded the number of airports participating in internal IDSR review process.  The following airports were added in the last year:

Category X:     Seattle-Tacoma International Airport

Category I:      Southwest Florida International Airport

Category I:      Port Columbus International Airport

Category I:      Salt Lake City International Airport

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Intelligence and Risk Analysis Drive Performance Measures

Given the complexity of remaining security measures, ACI-NA advocated for TSA’s Office of Risk Based Security and Office of Intelligence and Analysis to participate in the IDSR process.  Using intelligence and a risk-based approach to security in reviewing the remaining security measures, it is a goal of IDSR to develop performance-based measures that provide flexibility for airports that allow limited resources to be better utilized.

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Key IDSR Points

  • Before proposals developed through IDSR “hit the street,” an internal group of airports conducts a review to provide comment.
  • ACI-NA IDSR participants ensured that there would be a process so that all airports had an opportunity to comment on proposed ASP changes.
  • Having three opportunities to comment on security requirements is significant and something that did not exist before.
  • To eliminate confusion about which measures remain in a Security Directive or Airport Security Program, an IDSR Product List is available to airport operators on TSA’s Secure Web Board.  Further, airport members of IDSR recommended that all applicable Security Directives (SDs) be re-issued with expiration dates. 
  • Airport security and operations managers participate in the IDSR Task Force review process which brings a considerable amount of security and operations experience to the table.

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Status of Efforts to Date (June 2013)

Rescissions and flexibility provided through IDSR efforts:

  1. Employment History Investigations – rescinded October 15, 2010

  2. IDSR Members win TSA’s Partnership Award, November 2010

  3. Federal Flight Deck Officer SOP-rescinded from ASPs December 21, 2010 (now available on the TSA Secure Web Board as guidance).

  4. Provided airport operator comment and feedback as DHS transitioned from its Homeland Security Advisory System to the National Terrorism Advisory System, April 26, 2011.

  5. The Patrols ASP Amendment allows airports greater flexibility to conduct patrols, where previously it was restricted to law enforcement personnel.

  6. The Public Advisories amendment gives the airport flexibility in making announcements for controlling baggage, and eliminated the “threat level Orange” announcements.    

  7. Multiple “works in progress” as noted on TSA’s IDSR Product List available through the TSA Secure Web Board.

  8. DCA SD rescinded.

  9. Modification and flexibility for Sterile Area concession employees under ASP Change 13-02.

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Next Steps for IDSR (2013)

  • SD Sunset Package:To assist in tracking the applicability of security measures, the IDSR Task Force is focusing on the rescission of several Security Directives (SDs).  To accomplish this, the Task Force agreed that TSA would reissue all of the SDs with expiration dates.  Through the IDSR review process, IDSR will continue to identify redundant security measures that can be rescinded, those measures that need to be clarified and identify options for compliance to enhance an airport’s ability utilize its limited resources.  ACI-NA will continue to work with its members to review and comment on proposed amendments, guidance or information circulars that may be generated from the SD Sunset Package.  SDs not included in this Package include: SD1542-06-01F, SD1542-04-08G, SD1542-01-10G.
  • ACI-NA hosted a Webinar on TSA’s Compliance & Enforcement Policy.
  • IDSR is scheduled to review the National Terrorism Advisory System and the correlation to Aviation Security Measures (AVSEC), to include AVSEC Contingency Plans, as well as review and streamline policies for reporting suspicious incidents.
  • IDSR will also review LEO requirements, vehicle inspections and ID media checks, movement privileges on airport ramp areas, the handling of liquids, aerosols & gels, and airport categorization.

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IDSR Resources

In consultation with airport representatives on the IDSR Task Force, TSA has developed an IDSR Product List for tracking IDSR progress.  The Product List is available to authorized airport users on the TSA’s Secure Web Board.

 

For more information, please contact ACI-NA’s Lydia Beairsto

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