General Aviation Security: Increased Federal Oversight Is Needed,
but Continued Partnership with the Private Sector Is Critical to 
Long-Term Success (10-NOV-04, GAO-05-144).			 
                                                                 
Federal intelligence agencies have reported that in the past,	 
terrorists have considered using general aviation aircraft (all  
aviation other than commercial and military) for terrorist acts, 
and that the September 11th terrorists learned to fly at general 
aviation flight schools. The questions GAO answered regarding the
status of general aviation security included (1) What actions has
the federal government taken to identify and assess threats to,  
and vulnerabilities of, general aviation; and communicate that	 
information to stakeholders? (2) What steps has the federal	 
government taken to strengthen general aviation security, and	 
what, if any, challenges does the government face; and (3) What  
steps have non-federal stakeholders taken to enhance the security
of general aviation?						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-144 					        
    ACCNO:   A13335						        
  TITLE:     General Aviation Security: Increased Federal Oversight Is
Needed, but Continued Partnership with the Private Sector Is	 
Critical to Long-Term Success					 
     DATE:   11/10/2004 
  SUBJECT:   Airport security					 
	     Aviation						 
	     Counterterrorism					 
	     Intergovernmental relations			 
	     Terrorism						 
	     National preparedness				 
	     Domestic intelligence				 
	     Federal intelligence agencies			 
	     Aviation security					 
	     Homeland security					 

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GAO-05-144

     

     * Highlights
     * Contents
     * Results in Brief
     * Background
     * Intelligence Information and Industry Characteris
          * Theft of General Aviation Aircraft Has Been a Concern, but
            Intelligence on Threats to General Aviation Is Infrequent and
            Non-specific
          * The Extent of General Aviation's Vulnerability to
          * Implementing a Risk Management Approach Could Improve the
            Assessment of Threats and Vulnerabilities, but TSA Lacks an
            Implementation Plan
          * TSA Faces Challenges in Applying Risk Communication Principles to
            Improve the Quality of Threat Information Disseminated to General
            Aviation Stakeholders
     * TSA and FAA Have Taken Actions to Reduce Security Risks Associated
       with General Aviation but Face Regulatory and Funding Challenges
          * DOJ, FAA, and TSA Have Issued Requirements for Student Pilots,
            but Limitations Exist
          * Procedures for Determining Continued Need for Temporary Flight
            Restrictions Have Not Been Developed
               * The Number, Size, and in Some Cases Duration of TFRs Has
                 Increased since September 11, 2001
          * TFRs May Negatively Affect the General Aviation Industry
          * Enhancing Security at General Aviation Airports Is Difficult
            because of Funding Challenges
     * Nonfederal Stakeholders Have Taken Steps to Strengthen General
       Aviation Security
          * Industry Associations Have Provided General Aviation Airport
            Operators Guidance on Security Practices and Made Recommendations
            to TSA
          * States We Visited Varied in Their Efforts to Address General
            Aviation Vulnerabilities
          * General Aviation Airport Managers and Aircraft Owners Are
            Primarily Responsible for Security Enhancements
     * Conclusions
     * Recommendations for Executive Action
     * Agency Comments
     * Appendix I: Objectives, Scope, and Methodology
     * Appendix II: Comments from the Transportation Security Administration
     * Appendix III: GAO Contacts and Staff Acknowledgments
          * GAO Contacts
          * Staff Acknowledgments
               * Order by Mail or Phone

                 United States Government Accountability Office

Report to the Subcommittee on

GAO

    Homeland Security, Committee on Appropriations, House of Representatives

                                 November 2004

GENERAL AVIATION SECURITY

Increased Federal Oversight Is Needed, but Continued Partnership with the
                Private Sector Is Critical to Long-Term Success

GAO-05-144

Highlights of GAO-05-144, a report to the Chairman, Subcommittee on
Homeland Security, Committee on Appropriations, House of Representatives.

Federal intelligence agencies have reported that in the past, terrorists
have considered using general aviation aircraft (all aviation other than
commercial and military) for terrorist acts, and that the September 11th
terrorists learned to fly at general aviation flight schools. The
questions GAO answered regarding the status of general aviation security
included

(1) What actions has the federal government taken to identify and assess
threats to, and vulnerabilities of, general aviation; and communicate that
information to stakeholders? (2) What steps has the federal government
taken to strengthen general aviation security, and what, if any,
challenges does the government face; and (3) What steps have nonfederal
stakeholders taken to enhance the security of general aviation?

GAO recommends, among other things, that the Transportation Security
Administration (TSA) develop a plan for implementing a risk management
approach to strengthen general aviation security, and that the Federal
Aviation Administration establish a documented process to review and
revalidate flight restrictions.

TSA and FAA generally concurred with GAO's recommendations.

November 2004

GENERAL AVIATION SECURITY

Increased Federal Oversight Is Needed, but Continued Partnership with the
Private Sector Is Critical to Long-Term Success

The federal and state governments and general aviation industry all play a
role in securing general aviation operations. While the federal government
provides guidance, enforces regulatory requirements, and provides some
funding, the bulk of the responsibility for assessing and enhancing
security falls on airport operators. Although TSA has issued a limited
threat assessment of general aviation, and the FBI identified that
terrorists have considered using general aviation to conduct attacks, a
systematic assessment of threats has not been conducted. In addition, to
assess airport vulnerabilities, TSA plans to issue a self-assessment tool
for airport operators' use, but it does not plan to conduct on-site
vulnerability assessments at all general aviation airports due to the cost
and vastness of the general aviation network. Instead, TSA intends to use
a systematic and analytical risk management process, which is considered a
best practice, to assess the threats and vulnerabilities of general
aviation. However, TSA has not yet developed an implementation plan for
its risk management efforts.

TSA and the Federal Aviation Administration (FAA) have taken steps to
address security risks to general aviation through regulation and
guidance, but still face challenges in their efforts to further enhance
security. For example, TSA has promulgated regulations requiring
background checks of foreign candidates for U.S. flight training schools
and has issued security guidelines for general aviation airports. However,
we found limitations in the process used to conduct compliance inspections
of flight training programs. In addition, FAA, in coordination with TSA
and other federal agencies, has implemented airspace restrictions over
certain landmarks and special events. However, FAA has not established
written policies or procedures for reviewing and revalidating the need for
flight restrictions that limit access to airspace for indefinite periods
of time and could negatively affect the general aviation industry.

Non-federal general aviation stakeholders have partnered with the federal
government and have individually taken steps to enhance general aviation
security. For example, industry associations developed best practices and
recommendations for securing general aviation, and have partnered with TSA
to develop security initiatives such as the Airport Watch Program, similar
to a neighborhood watch program. Some state governments have also provided
funding for enhancing security at general aviation airports, and many
airport operators GAO surveyed took steps to enhance security such as
installing fencing and increasing police patrols.

                     Examples of General Aviation Aircraft

www.gao.gov/cgi-bin/ getrpt?GAO-05-144.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Cathleen Berrick,
202-512-8777, [email protected].

Contents

  Letter 1

Results in Brief 3 Background 6 Intelligence Information and Industry
Characteristics Challenge

TSA's Ability to Identify and Assess Threats and Vulnerabilities

and Communicate with General Aviation Stakeholders 15 TSA and FAA Have
Taken Actions to Reduce Security Risks

Associated with General Aviation but Face Regulatory and

Funding Challenges 24 Nonfederal Stakeholders Have Taken Steps to
Strengthen General

Aviation Security 41 Conclusions 50 Recommendations for Executive Action
52 Agency Comments 52

  Appendix I Objectives, Scope, and Methodology

Appendix II Comments from the Transportation Security Administration

  Appendix III GAO Contacts and Staff Acknowledgments 60

GAO Contacts 60 Staff Acknowledgments 60

  Tables

Table 1: Some Major Industry Associations Representing General

Aviation 13 Table 2: TSA and FAA Regulatory Actions Governing the
Screening

and Validation of Pilot and Student Pilot Identities 25 Table 3: Examples
of Security Measures Used by Aviation

Departments of 55 Fortune 500 Corporations 50

  Figures

Figure 1: Use Categories of General Aviation

    Page i GAO-05-144 General Aviation Security

    Figure 2: Composition of the General Aviation Fleet, 2002              10 
    Figure 3: Categories and Numbers of Airports in the United States      11 
    Figure 4: Example of a Rural Turf Runway General Aviation          
              Airport (top) and a More Complex Urban General           
    Aviation Airport (bottom)                                              12 
    Figure 5: Example of Security Advisory Issued by TSA                   21 
    Figure 6: TSA Has Established Regulations that Expand Federal      
    Security Requirements from Commercial Air Carriers to              
             Include Some Private and Public Charter Aircraft              29 
    Figure 7: Temporary Flight Restriction over the Crawford Ranch in  
    Texas when the President Is Present                                    32 
    Figure 8: Washington, D.C. Air Defense Identification Zone         
              Surrounding the 15-Nautical-mile Radius Flight           
    Restriction Zone                                                       34 
    Figure 9: Remaining and Cancelled Security TFRs Over Military      
    Installations                                                          35 
    Figure 10: Violations of Temporary Flight Restrictions Have        
    Increased                                                              36 
    Figure 11: Sign at St. Mary's Airport in Brunswick, Georgia,       
           Warning General Aviation Pilots to Avoid Restricted         
    Airspace                                                               38 
    Figure 12: Airport Watch Program Signs Distributed to General      
    Aviation Airports Around the Country                                   44 
    Figure 13: Examples of Propeller Locks to Prevent Unauthorized     
    Aircraft Use                                                           49 

Abbreviations

CIA                   Central Intelligence Agency                          
FAA                             Federal Aviation Administration            
FBI                             Federal Bureau of Investigation            
TFR                   temporary flight restrictions                        
TSA                                 Transportation Security Administration 

This is a work of the U.S. government and is not subject to copyright
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separately.

United States Government Accountability Office Washington, DC 20548

November 10, 2004

The Honorable Harold Rogers Chairman Subcommittee on Homeland Security
Committee on Appropriations House of Representatives

Dear Mr. Chairman:

General aviation accounts for three-quarters of all aircraft that take off
and land in the United States. These aircraft encompass a wide range of
flight operations at nearly 19,000 general aviation airports nationwide. 1
According to the National Air Transportation Association, the general
aviation industry contributes about $100 billion to the U.S. economy each
year and accounts for about 1.3 million jobs. Federal intelligence
agencies have reported in the past that terrorists have considered using
general aviation aircraft for terrorist acts and that the September 11
terrorists learned to fly at flight schools in Florida, Arizona, and
Minnesota. In addition, the 9/11 Commission identified concerns that
vulnerabilities continue to exist in general aviation.

The Transportation Security Administration (TSA), along with other federal
agencies, state governments, and the general aviation industry, plays a
role in securing general aviation operations. While the federal government
provides guidance on threats and vulnerabilities, enforces regulatory
requirements, and provides some funding assistance, because of competing
needs of commercial aviation security funding and the vastness and
diversity of the general aviation network, the bulk of the responsibility
for assessing and enhancing security falls on airport operators. This
public/private partnership has been strengthened following the terrorist
attacks of September 11, in part, through the teaming of TSA and general
aviation industry associations by means of the Aviation Security Advisory
Committee, which, among other things, helped develop

1

The range of general aviation flight operations encompasses
personal/family transportation, power line inspection and repair, pipeline
patrol, training, transporting medical supplies, emergency services,
rescue operations, wildlife and land surveys, traffic reporting,
agricultural aviation, firefighting, and law enforcement.

    Page 1 GAO-05-144 General Aviation Security

security guidelines for general aviation airports based on industry best
practices. 2

To assess the status of general aviation security, we answered the
following questions: (1) What actions has the federal government taken to
identify and assess threats to, and vulnerabilities of, general aviation,
and communicate that information to stakeholders? (2) What additional
steps has the federal government taken to strengthen general aviation
security, and what, if any, challenges does the government face in further
enhancing security? (3) What steps have non-federal stakeholders taken to
enhance the security of general aviation? Due to TSA's concerns that the
public release of our detailed findings could compromise aviation
security, we issued a separate restricted report to you detailing the
results of our review. This report is intended to summarize, in a publicly
releasable form, our overall findings and confirm TSA and the Federal
Aviation Administration's (FAA) agreement to take action to better assess
the potential for terrorist misuse of general aviation aircraft, improve
the communication of terrorist threat information to the general aviation
community, help manage security risks associated with access to general
aviation aircraft and airspace, and help ensure that temporary flight
restrictions issued for indefinite periods of time are reviewed,
revalidated, and consistently applied. Information determined to be
sensitive has been removed from this report.

To determine the actions taken by the federal government to assess and
communicate threats and vulnerabilities associated with general aviation,
we reviewed federal agency reports and studies sponsored by industry
associations, and interviewed federal officials and general aviation
industry representatives, including those who provided input to TSA's
Aviation Security Advisory Committee Working Group on General Aviation. To
identify what additional steps the federal government has taken to address
national security risks from general aviation, we obtained and analyzed
data from the FAA, including the number of flight restrictions that affect
general aviation and information from TSA on

The Aviation Security Advisory Committee was formed following the 1988 Pan
American World Airways Flight 103 tragedy (Lockerbie, Scotland) to allow
all segments of the population to have input into future aviation security
considerations. The committee was originally sponsored by the Federal
Aviation Administration. However, when the Aviation and Transportation
Security Act was signed into law, primary responsibility for civil
aviation security were transferred from the Federal Aviation
Administration to TSA, and accordingly, sponsorship of the Aviation
Security Advisory Committee also was transferred to TSA.

efforts to ensure compliance with general aviation regulations and provide
security guidelines for airport operators. We sought to determine the
reliability of these data by, among other things, discussing methods of
inputting and maintaining data with agency officials. On the basis of
these discussions, we determined that the data were sufficiently reliable
for the purposes of this review. To identify what steps nonfederal
aviation stakeholders have taken to enhance the security of general
aviation, we judgmentally selected 31 general aviation airports to observe
security measures implemented since September 11, 2001, and discuss
securityrelated issues. 3 We selected these airports based on
characteristics including size, location, and aviation activity. 4 Because
of the limited number of airports in our sample, and because the selected
airports did not constitute a representative sample, the results of our
case study analysis cannot be projected to the universe of general
aviation airports. We also discussed security issues with selected state
aviation officials. In addition, we surveyed a random sample of publicly
accessible general aviation airports that are eligible for federal funding
to obtain airport managers' views on changes in the security environment
in general aviation since September 11. 5

We performed our work between October 2003 and August 2004 in accordance
with generally accepted government auditing standards. Appendix I provides
more details about our scope and methodology of our work.

TSA and other federal agencies have not conducted an overall systematic

  Results in Brief

assessment of threats to, or vulnerabilities of, general aviation to
determine how to better prepare against terrorist threats. Although TSA
issued a limited assessment of threats associated with general aviation
and the Federal Bureau of Investigation (FBI) stated that terrorists have
considered using general aviation to conduct attacks, a systematic

3

We visited general aviation airports in Alabama, California, Georgia,
Maryland, Massachusetts, New Jersey, New York, South Carolina, Tennessee,
Texas, and Washington.

4

General aviation activities also take place at some commercial airports,
but we did not include commercial airports in the scope of this review.

5

Because this is a probability sample, population estimates based on this
sample data are subject to sampling error. All percentage estimates based
on this sample have 95 percent confidence intervals that are within +/- 6
percentage points of the estimate itself, unless otherwise noted.

assessment of threats has not been conducted. In addition, TSA has
conducted vulnerability assessments at selected general aviation airports,
but agency officials stated that conducting these assessments is costly
and, therefore, impractical to do for the 19,000 general aviation airports
nationwide. TSA intends to implement a risk management approach to better
assess threats and vulnerabilities of general aviation aircraft and
airports and, as part of this approach, is developing an online
vulnerability self-assessment tool to be completed by individual airport
managers. However, we found limitations in the use of the self-assessment
tool. Further, TSA has not yet developed a plan with specific milestones
for implementing these tools and assessments. Without such a plan, it will
be difficult for TSA to (1) monitor the progress of its efforts, (2) hold
responsible officials accountable for achieving desired results, and

(3) ensure that alternative approaches are considered should the tool not
provide sufficient data to provide a desired security baseline of
vulnerabilities.

TSA has also partnered with industry associations to develop security
guidelines that enable general aviation airport managers to assess their
own vulnerabilities to terrorist attack, and works through industry
associations to communicate threat information. However, industry and
state aviation officials we spoke with stated that security advisories
distributed by TSA were general in nature and were not consistently
received. In part this is understandable because, among other things, the
agency relies on other federal agencies for threat information. However,
we have found that applying these principles to the extent possible
provides organizations like TSA with the best opportunity to achieve
desired results.

TSA and FAA have taken steps to address security risks to general aviation
through regulation and guidance, but still face challenges in their
efforts to further enhance security. For example, TSA has developed
regulations governing background checks of foreign candidates for U.S.
flight training schools and has issued security guidelines for general
aviation airports. However, we found limitations in the process used to
conduct compliance inspections of flight training programs. Further,
should TSA establish new security requirements for general aviation
airports, competing funding needs could challenge the ability of general
aviation airport operators to meet these requirements. In addition, FAA,
in coordination with TSA and other federal agencies, has implemented
airspace restrictions over certain landmarks and special events to guard
against potential terrorist threats. However, FAA has not established
written policies or procedures for reviewing and revalidating the
continuing need for extended flight restrictions that limit access to
airspace for indefinite periods of time and could negatively affect the
general aviation industry. In addition, we found limitations in the
process used to allow pilots to fly through securityrelated flight
restrictions.

Nonfederal general aviation stakeholders have partnered with the federal
government and one another to enhance general aviation security and have
individually taken a number of steps to address the threat of misuse of
general aviation aircraft. For example, in addition to developing their
own sets of best practices and recommendations for securing general
aviation aircraft and operations, industry associations have worked with
TSA to develop security initiatives such as the Airport Watch program, 6
launched jointly by the Aircraft Owners and Pilots Association and TSA,
and the TSA Access Certificate program, 7 developed by the National
Business Aviation Association and currently being evaluated at selected
airports by TSA. Some state governments have also provided funding for
enhancing security at general aviation airports and established security
regulations. For example, New Jersey requires that all aircraft stored at
general aviation airports be secured with at least two locks to prevent
unlawful access to the aircraft. In addition, many of the general aviation
airports we visited and surveyed had taken steps to enhance security such
as installing fencing and lighting, and requesting increased local police
patrols.

Because of the importance of securing general aviation operations and to
help address associated challenges, we are making recommendations to the
Department of Homeland Security to take four actions to better assess the
possibility of terrorists' misuse of general aviation aircraft, better
communicate terrorist threat information, and help mitigate security risks
to general aviation operations. We are also making a recommendation to the
Department of Transportation to take action to ensure that temporary
flight restrictions issued for indefinite periods are reviewed and, if
appropriate, revalidated and consistently applied.

6

Airport Watch is a program initiated by the Aircraft Owners and Pilots
Association working with TSA. The program is supported by a TSA-sponsored
toll free hotline (866-GA-SECURE) and warning signs for airports,
informational literature, and training videotapes provided by the
association.

7

The TSA Access Certificate program is based on a set of security protocols
developed by the National Business Aviation Association. TSA is testing
this program at three airports in the Northeast for possible use as a
national security standard for corporate and business operators.

                                   Background

We provided a draft of this report to the Secretary of the Department of
Homeland Security, the Secretary of Transportation, the Assistant
Secretary of Homeland Security for the Transportation Security
Administration, and the Administrator of the Federal Aviation
Administration who generally concurred with our findings and
recommendations. TSA's written comments are presented in appendix II.

General aviation encompasses a wide variety of activities, aircraft types,
and airports. About 85 percent of all general aviation hours flown falls
into one of five categories of flying activity, as defined by FAA and
described in figure 1. The largest of these categories is recreational
flying, which is defined as flying for pleasure or personal transportation
and not for business purposes. In 2002, recreational flying accounted for
about 41 percent of all general aviation hours flown. The remaining
categories include activities such as medical services, aerial
advertising, aerial mapping and photography, and aerial application of
seeds or chemicals. 8

8

TSA considers general aviation aircraft to include all U.S. registered
civil aircraft not

(1) operated under 14 C.F.R. Part 121 (scheduled commercial airlines), (2)
military operations, and (3) on-demand air carriers that operate
nonscheduled commercial service under 14 C.F.R. Part 135

Page 6 GAO-05-144 General Aviation Security

                  Figure 1: Use Categories of General Aviation

                 Percentage  
                 of aviation 
Use           hours flown Description                                      
Recreational  40.8        Use of aircraft for                              
                             pleasure or personal transportation and not for  
                             business purposes.                               
Instructional 15.6        Flying under the                                 
                             supervision of a flight                          
                             instructor.                                      
Business      12.2        Use of aircraft in                               
                             connection with the                              
                             pilot's occupation or private business.          

Various types of aircraft can be used in general aviation operations,
including single-engine and multi-engine piston aircraft, turboprops,
turbojets, helicopters, gliders, and experimental aircraft. The general
aviation fleet in the United States consists of about 211,000 active
aircraft. While this fleet is diverse, certain activities are generally
associated with specific types of general aviation aircraft. For example,
corporate flying generally involves the use of turboprop and turbojet
aircraft, while personal and instructional flying generally involves the
use of singleengine propeller-driven aircraft. The largest category of
general aviation aircraft is single-engine propeller, which in 2002 made
up 68 percent of the general aviation fleet. Types of general aviation
aircraft and their uses are described in figure 2. 9

For a more detailed discussion on the general aviation industry, see GAO,
General Aviation: Status of the Industry, Related Infrastructure, and
Safety Issues, GAO-01-916, (Washington, D.C.: Aug. 31, 2001).

Page 9 GAO-05-144 General Aviation Security

Figure 2: Composition of the General Aviation Fleet, 2002

Sources: FAA, TSA, the General Aviation Manufacturers Association, and the
Helicopter Association International.

There are approximately 14,000 private-use and 4,800 public-use general
aviation airports in the United States, and about 550,000 active general
aviation pilots and instructors. 10 Non-U.S. citizens can also possess
active student pilot certificates in the United States, according to FAA.
Although

10

According to FAA's Airmen's Registry as of July 3, 2004.

general aviation aircraft can take off and land at almost any airport,
including most of the nation's commercial service airports, 11 there is an
extensive system of general aviation airports nationwide. Figure 3
identifies the categories of airports in the United States.

Figure 3: Categories and Numbers of Airports in the United States

510

Commercial service airportsa

Public-use general aviation airports

Private general aviation airports, not open to the public Source: FAA.

a

According to FAA, commercial service airports are those airports that
handle regularly scheduled commercial airline traffic and have at least
2,500 annual passenger enplanements. TSA considers commercial service
airports to be those subject to security requirements under 49.C.F.R. part
1542 and by that definition, there are approximately 450 commercial
service airports.

Public-use general aviation airports can range in size and complexity from
the short, grass landing strip in rural areas to the very busy urban
airports with multiple paved runways of differing lengths that can
accommodate large jet aircraft. Figure 4 illustrates examples of a rural
general aviation airport with a grass landing strip and a more complex
urban general aviation airport.

Airports that handle regularly scheduled commercial airline traffic and
have at least 2,500 annual passenger enplanements.

Page 11 GAO-05-144 General Aviation Security

Figure 4: Example of a Rural Turf Runway General Aviation Airport (top)
and a More Complex Urban General Aviation Airport (bottom)

                 Source: Georgia Department of Transportation.

General aviation industry interests are represented by a variety of
national organizations. One of the functions of these organizations is
disseminating information from federal agencies to their members. These
associations also provide their members with security best practices and
recommendations tailored to their members' specific needs. Table 1
provides an overview of some of the largest industry associations and
their role in general aviation.

    Table 1: Some Major Industry Associations Representing General Aviation

                         Association Who they represent

  American Association of Airport Executives Airport executives at public use
                                    airports

       Aircraft Owners and Pilots Association Pilots and aircraft owners

Experimental Aircraft Association Recreational aviation enthusiasts and
builders

General Aviation Manufacturers Association Companies manufacturing general
aviation aircraft, engines, and component parts

  Helicopter Association International Helicopter operators and manufacturers

                  National Business Aviation Association, Inc.

                   National Agricultural Aviation Association

Companies that own or operate general aviation aircraft as an aid to the
conduct of their business or are involved with some other aspect of
business aviation

Licensed commercial applicator-operators that use aircraft to enhance food
and fiber production, protect forestry, and control health-threatening
pests

National Air Transportation Association Companies that provide general
aviation service including on-demand air charter, fuel and ground
services, aircraft maintenance, and pilot training

National Association of State Aviation Officials in state government
aviation Officials agencies

Source: Industry associations.

Prior to the passage of the Aviation and Transportation Security Act in
November 2001, FAA had primary responsibility for securing all civil
aviation, including general aviation. Although the act transferred much of
that responsibility from FAA to TSA, 12 FAA maintains a security role
because of its regulatory authority over the imposition of temporary
flight

Aviation and Transportation Security Act (ATSA), Pub. L. No. 107-71, S:
101(a), (g), 115 Stat. 597, 603 (2001).

Page 13 GAO-05-144 General Aviation Security

restrictions (TFR) 13 and its disbursement of grants to fund safety and security
           enhancements at commercial and general aviation airports.

Most of the civil aviation security regulations TSA assumed from FAA did
not apply to general aviation, but rather to commercial passenger air
carriers and commercial airports. 14 Although the security of general
aviation airports remains largely unregulated, the Aviation and
Transportation Security Act and subsequent laws required TSA to develop
additional regulations that affect specific segments of general aviation-
flight training schools and certain charter flight operations. 15

Among other things, with regard to all modes of transportation, the
Aviation and Transportation Security Act also required TSA to

     o receive, assess, and distribute intelligence information related to
       transportation security;
     o assess threats to transportation security and develop policies,
       strategies, and plans for dealing with those threats, including
       coordinating countermeasures with other federal organizations;
     o enforce security-related regulations and requirements; and

o  oversee the implementation, and ensure the adequacy, of security
measures at airports and other transportation facilities. 16

13

FAA has sole authority to issue TFRs and other rules to restrict aircraft
from operating within defined areas, on a temporary or permanent basis, in
order to protect persons or property in the air or on the ground. When
time permits, FAA issues security-based TFRs after consultation with TSA
and other federal agencies, as appropriate.

14

49 C.F.R. parts 1540, 1542 & 1544 (formerly codified, in part, at 14
C.F.R. parts 107 & 108).

15

Pub. L. No.107-71, S:S: 113(a) & 132, 115 Stat. at 622 & 635.

16

Pub. L. No. 107-71, S: 101(a), 115 Stat. at 598.

  Intelligence Information and Industry Characteristics Challenge TSA's Ability
  to Identify and Assess Threats and Vulnerabilities and Communicate with
  General Aviation Stakeholders

TSA and other federal agencies have not conducted an overall, systematic
assessment of threats to, or vulnerabilities of, general aviation to
determine how to better prepare against terrorist threats. However, in
July 2003, TSA issued a limited assessment of threats associated with
general aviation activities. In addition, the FBI stated that intelligence
indicates that terrorists have considered using general aviation aircraft
in the past to conduct attacks. To determine vulnerabilities, TSA
conducted vulnerability assessments at some general aviation airports
based on specific security concerns or requests by airport officials, and
have conducted less intensive security surveys at selected general
aviation airports. To better focus its efforts and resources, TSA intends
to implement a risk management approach to assess the threats and
vulnerabilities of general aviation aircraft and airports, and conduct
onsite vulnerability assessments only at those airports the agency
determines to be nationally critical. However, TSA has not yet developed a
plan with specific milestones for implementing these tools and
assessments.

While TSA has partnered with industry associations to develop security
guidelines for general aviation airports and communicate threat
information to airport operators, we found limitations in the
communication of threat information. Industry and state aviation officials
we spoke with stated that security advisories distributed by TSA were
general in nature and were not consistently received. Risk communication
principles provide that specific information on potential threats include-
to the extent possible-the nature of the threat, when and where it is
likely to occur, over what time period it is likely to occur, and guidance
on actions to be taken. Applying these principles presents problems for
TSA because, among other things, the agency receives threat information
from other federal agencies and that information is often classified.

Theft of General Aviation Aircraft Has Been a Concern, but Intelligence on
Threats to General Aviation Is Infrequent and Non-specific

Neither TSA nor FBI has conducted an overall systematic assessment of
threats to, or vulnerabilities of, general aviation to determine how to
better prepare against terrorist threats. In July 2003, TSA issued a brief
summary assessment of the threats associated with general aviation.
However, the assessment was not widely distributed or made available to
general aviation airports or other stakeholders. In 2004, the Secretary of
the Department of Homeland Security acknowledged that the department,
along with the Central Intelligence Agency (CIA), FBI, and other agencies,
lacked precise knowledge about the time, place, and methods of potential
terrorist attacks related to general aviation. Additionally, industry and
TSA officials stated that the small size, lack of fuel capacity, and
minimal destructive power of most general aviation aircraft make them
unattractive to terrorists and, thereby, reduce the possibility of threat
associated with their misuse.

Historical intelligence indicates that terrorists have expressed interest
in using general aviation aircraft to conduct attacks. The following are
examples of intelligence information indicating terrorist interest in
general aviation:

     o CIA reported that terrorists associated with the September 11 attacks
       expressed interest in the use of crop-dusting aircraft (a type of
       general aviation aircraft) for large area dissemination of biological
       warfare agents such as anthrax.
     o CIA reported that one of the masterminds of the September 11 attacks
       originally proposed using small aircraft filled with explosives to
       carry out the attacks.
     o In May 2003, the Department of Homeland Security issued a security
       advisory indicating that al Qaeda was in the late stages of planning
       an attack, using general aviation aircraft, on the U.S. Consulate in
       Karachi, Pakistan, and had also planned to use general aviation
       aircraft to attack warships in the Persian Gulf.

The Extent of General Aviation's Vulnerability to Terrorist Attack Is
Difficult to Determine

TSA and industry stakeholders we spoke with stated that general aviation
airports are vulnerable to terrorist attack. TSA officials stated also
that it would be difficult for the agency to systematically conduct
on-site assessments of the vulnerabilities of individual general aviation
airports to terrorist activities because of the diversity and large number
of airports. Officials cited the nearly 19,000 general aviation airports
nationwide, noting that each has distinct characteristics that may make it
more or less attractive to potential terrorists.

TSA's efforts to assess vulnerabilities at specific general aviation
airports have been limited. At the time of our review, TSA had conducted
vulnerability assessments at selected general aviation airports based on
specific security concerns or requests by airport officials. TSA officials
stated that the resources associated with conducting vulnerability
assessments, and the diverse nature of general aviation airports, makes it
impractical to conduct assessments at the approximately 19,000 general
aviation airports nationwide, or even the approximately 4,800 public-use
general aviation airports. TSA officials said, however, that they had
conducted a less intensive security survey at additional general aviation

Implementing a Risk Management Approach Could Improve the Assessment of
Threats and Vulnerabilities, but TSA Lacks an Implementation Plan

airports. TSA selected these airports, among other things, in preparation
for special security events such as the G-8 summit and national Republican
and Democratic political conventions.

In response to industry requests for federally endorsed security
protocols, TSA issued security guidelines in May 2004 meant to enable
individual general aviation airport managers to assess their own
facility's vulnerability to terrorist attack and suggest security
enhancements. 17 Although these guidelines were issued after we conducted
our survey of general aviation airport managers, we found that the
majority of airport managers surveyed stated that they would use a
security review/vulnerability assessment tool if it were provided. To
produce these security guidelines, TSA partnered with industry
associations participating in the Aviation Security Advisory Committee's
Working Group on General Aviation Airports Security. The guidelines
include an airport characteristic measurement tool that allows airport
operators to assess the level of risk associated with their airport to
determine which security enhancements are most appropriate for their
facility. The guidelines also contain security guidance based on industry
best practices. TSA officials emphasized that, because security at general
aviation airports is not currently regulated by TSA, the security
enhancements suggested by the guidelines are voluntary and are to be
implemented at the discretion of the airport manager. While TSA's and
general aviation airport managers' assessments at specific general
aviation airports have been limited, TSA has identified a number of
factors that could make general aviation aircraft and airports vulnerable
to exploitation by terrorists.

In order to address challenges in assessing threats and vulnerabilities to
all modes of transportation-including general aviation-and focusing scarce
resources, TSA plans to implement a risk management approach based on
assessments of criticality, threat, and vulnerability. 18 TSA's risk
management approach, as it relates to general aviation security, is
summarized below.

17

Transportation Security Administration, Security Guidelines for General
Aviation Airports, Information Publication A-001, (May 2004).

18

See GAO, Homeland Security: Key Elements of a Risk Management Approach,.
GAO-02-150T (Washington, D.C.: Oct. 12, 2001).

Page 17 GAO-05-144 General Aviation Security

     o TSA plans to use a criticality tool to provide the basis for
       prioritizing which transportation assets and facilities require
       additional or special protection. On the basis of a criticality
       assessment, TSA intends to provide greater security scrutiny to
       general aviation airports that require special protection.
     o TSA plans to apply threat scenarios of how terrorists might conduct
       attacks in specific situations in airport environments to assess
       threats faced by individual general aviation airports.
     o TSA is developing an online self-assessment toolintended to help
       general aviation airport managers develop a comprehensive security
       baseline for their facility.
     o TSA is developing a Transportation Risk Assessment and Vulnerability
       Evaluation tool for conducting on-site assessments of general aviation
       airports that are deemed to be nationally critical.

TSA intends to compile baseline data on security vulnerabilities from
these tools and use the data to conduct a systematic analysis of security
vulnerabilities at general aviation airports nationwide. TSA officials
stated that such an analysis will allow the agency to establish the need,
if any, for minimum security standards; determine the adequacy of current
security regulations; and help the agency and airports better direct
limited resources. They noted that because airports will not be required
to use the tool, the usefulness of the data gathered will be dependent on
the number of airports voluntarily submitting assessment results to TSA.

Despite these plans, however, TSA has not developed an implementation plan
with specific milestones for conducting its risk management efforts. These
efforts have been under development for over a year and were originally
scheduled to have been completed between June and August of 2004. Without
a plan that establishes specific time frames for implementation of the
tools and assessments, it will be difficult for TSA to monitor the
progress of its efforts and hold responsible officials accountable for
achieving desired results. Similarly, without a plan that includes
estimates of the resources needed to effectively implement the agency's
risk management approach, TSA's ability to allocate its resources to areas
of greatest need could be impaired. A plan could also address alternative
approaches that could be implemented if the extent of voluntary
participation of general aviation airport managers does not provide
sufficient data needed to establish the desired security baseline of
vulnerabilities.

TSA Faces Challenges in Applying Risk Communication Principles to Improve
the Quality of Threat Information Disseminated to General Aviation
Stakeholders

TSA faces challenges in ensuring that threat information is effectively
communicated to the general aviation community due to the generality of
intelligence information given, and the lack of a current, reliable, and
complete list of airport contacts. In addition, intelligence information
may be classified or sensitive, thus limiting with whom it can be shared.
19 TSA partners with industry associations that are part of a General
Aviation Coalition as a primary means for communicating threat information
and developing security guidelines for general aviation airport managers.
20 Specifically, rather than notifying general aviation airport operators
directly, TSA communicates threat advisories to these industry
associations, which in turn are to provide it to their members. A majority
of general aviation airport managers we surveyed reported that they had at
least some contact with nonfederal entities such as state aviation
officials or industry associations such as the American Association of
Airport Executives or the National Business Aviation Association. 21
Additionally, a majority indicated that they had established procedures
for disseminating security-related information to airport employees and
tenants.

TSA issued threat advisories for dissemination by general aviation
associations to general aviation airports. However, industry association
representatives and state aviation officials we spoke with stated that
these security advisories were general in nature and were not consistently

19

For example, 49 C.F.R. Part 1520 limits TSA's ability to distribute
sensitive security information to persons with a need to know, and
Executive Order 13292-Further Amendment to Executive Order 12958, as
Amended, Classified National Security Information, March 25, 2003, limits
the distribution of classified information.

20

The General Aviation Coalition consists of the major general aviation
organizations and focuses on addressing aviation issues of common interest
and concern. The coalition meets every 6 months with the FAA Administrator
and senior FAA managers to present and update issues. The industry
associations that make up the coalition consists of the Aircraft
Electronics Association, the Aircraft Owners and Pilots Association, the
Experimental Aircraft Association, the General Aviation Manufacturers
Association, the Helicopter Association International, the International
Council of Air Shows, the National Aeronautics Association, the National
Agricultural Aviation Association, the National Air Transportation
Association, the National Aircraft Resale Association, the National
Association of State Aviation Officials, the National Business Aviation
Association, the Professional Aviation Maintenance Association, the Small
Aircraft Manufacturers Association, the Soaring Society of America, the
U.S. Parachute Association, and the University Aviation Association.

21

TSA officials said they also conducted outreach programs before national
events requiring special aviation security to educate the general aviation
community on flight restrictions and other planned security measures and
that TSA planned to assign a lead federal security director in each state
as a point of contact for states' general aviation communities.

received. An example of one of TSA's threat advisories is shown in figure
5
below.

              Figure 5: Example of Security Advisory Issued by TSA

Source: U.S. Department of Homeland Security.

Timely, specific, and actionable information are three key principles of
effective risk communication. However, TSA faces inherent challenges in
applying risk communication principles because of: (1) the generality of
intelligence information received from the intelligence community, (2) a
limited capability to identify appropriate officials and airports to
receive threat information, and (3) potential restrictions placed on
communicating classified or sensitive security information to general
aviation stakeholders. Providing threat information to the public or those
with a need to know in accordance with these principles is challenging and
extends beyond threat communications related to general aviation.

The first challenge TSA, along with other federal agencies, faces in
applying risk communication principles is the generality of intelligence
information and the difficulties the government faces in developing such
information. According to TSA, gathering specific threat information is
difficult because the threat posed by a particular person or group varies
over time with changes in the terrorist organization's structure,
objectives, methodologies, and capabilities. Targets also change depending
on the security of the target in question; likelihood of success; mission
complexity; and potential psychological, emotional, and financial impact
of the attack. These variations in groups and targets make predicting how
and when a terrorist event could occur difficult. Nonetheless, we have
reported that public warning systems should, to the extent possible,
include specific, consistent, accurate, and clear information on the
threat at hand, including the nature of the threat, location, and threat
time frames along with guidance on actions to be taken in response to the
threat. 22 According to risk communication principles, without adequate
threat information, the public may ignore the threat or engage in
inappropriate actions, some of which may compromise rather than promote
the public's safety.

A second challenge faced by TSA in communicating threat information to
general aviation airports is the lack of current, reliable, and complete
information about who to contact to facilitate communication. General
aviation airport operators are widely spread among a diverse range of
airports that have historically been subject to little or no federal
regulation or contact. As a result, contact information about who the
owners or operators of individual airports are may not be complete,
current, or readily available. Neither FAA nor TSA maintains a current
database with contact information for all general aviation airports. Thus,
identifying who

GAO, Homeland Security: Risk Communication Principles May Assist in
Refinement of the Homeland Security Advisory System, GAO-04-538T
(Washington, D.C.: Mar. 16, 2004).

Page 22 GAO-05-144 General Aviation Security

should receive threat information at the nearly 19,000 airports poses a
significant challenge. While general aviation industry associations
typically maintain contact information on their members, association
officials stated that when they need contact information on general
aviation airports they generally use data from the FAA.

A third challenge TSA faces in providing classified threat information to
general aviation airport operators is determining which airport officials
have a need and clearance to receive classified or sensitive intelligence
information. In general, the more detailed and specific the threat
information, the more likely the information is classified and, therefore,
not available to those without appropriate security clearances. TSA
officials said they had sanitized threat information in order to issue the
five security advisories to general aviation industry associations in an
unclassified format. TSA officials said they had also granted security
clearances to individuals at certain industry associations who were
willing to undergo the required background check process. However,
although TSA has developed the ability to communicate classified threat
information to some general aviation industry representatives, the agency
still faces limitations on its ability to ensure that airport operators
with a need to know have access to classified threat information, and have
the appropriate clearances.

According to TSA officials, the agency's approach to risk management
should improve its ability to communicate threat information to the
general aviation community by addressing the three challenges mentioned
above. Specifically, once TSA completes threat and criticality assessments
and-in coordination with general aviation airport managers- vulnerability
assessments, the agency will have a greater sense of the threats that
individual general aviation airport managers should be aware of and
therefore be able to communicate more useful and specific threat
information. Conducting vulnerability and criticality assessments should
also help TSA identify airports for which current and reliable contact
information is needed, and identify airport officials with a need to know
classified threat information.

  TSA and FAA Have Taken Actions to Reduce Security Risks Associated with
  General Aviation but Face Regulatory and Funding Challenges

TSA and FAA have taken steps to address security risks associated with
general aviation through regulation, guidance, and funding. However, in
response to the September 11 attacks, TSA has primarily focused on
strengthening the security of commercial aviation and meeting associated
congressional mandates. As a result, TSA has dedicated fewer resources to
strengthening general aviation security, and both TSA and FAA continue to
face challenges in their efforts to further enhance security. For example,
TSA has developed a regulation governing background checks of foreign
candidates for flight training at U.S. flight schools and issued security
guidelines for general aviation airports. 23 However, TSA has not yet
developed a schedule for conducting inspections or determined the
resources needed for monitoring compliance with new regulations. In
addition, should TSA establish security requirements for general aviation
airports, it may be difficult for airport operators to finance security
enhancements independently and federal funding will also be a challenge
since general aviation airports' needs must compete with the needs of
commercial airports for security funding. FAA, in coordination with TSA
and other federal agencies, has implemented airspace restrictions over
certain landmarks and events, among other things, to guard against
potential terrorist threats. FAA officials said that they intermittently
reviewed the continuing need for flight restrictions limiting access to
airspace for indefinite periods of time-those established at the request
of the Department of Defense and for the defense of the national capital
region. However, they had not established written procedures or criteria
for revalidating the need for restrictions to ensure such reviews were
consistently conducted. In addition, we found limitations in the process
used by TSA to review and make recommendations regarding waivers to allow
general aviation pilots to fly through security related flight
restrictions.

23

TSA has proposed a regulation pursuant to section 612 of the Vision
100⎯Century of Aviation Reauthorization Act, Pub. L. No. 108-176,
117 Stat. 2490, 2572-74 (2003), to codify TSA's authority in light of the
transfer of responsibilities from the Department of Justice. The
Department of Justice issued and enforced regulations that require
background checks of foreign candidates for flight training pursuant to
section 113 of ATSA, Pub. L. No. 107-71, 115 Stat. at 622-23.

Page 24 GAO-05-144 General Aviation Security

DOJ, FAA, and TSA Have Issued Requirements for Student Pilots, but
Limitations Exist

Recognizing the threat posed by larger aircraft, whether carrying
passengers or cargo, the Department of Justice, in February 2003, issued a
requirement that all non-U.S. citizens seeking flight training in aircraft
weighing 12,500 pounds or more must undergo a comprehensive background
check. 24 Both TSA and FAA subsequently issued regulations intended to
limit access to aircraft for certain segments of the general aviation
community by increasing requirements for background checks of pilots. As
table 2 shows, TSA and FAA promulgated new regulations governing the
screening and validation of pilot and student pilot identities.

 Table 2: TSA and FAA Regulatory Actions Governing the Screening and Validation
                     of Pilot and Student Pilot Identities

                          Date Agency New requirement

Feb. 2002 TSAa Individuals must successfully complete a fingerprint-based
criminal history records check before serving as a flight crew member.

Feb. 2002 FAAb Flight crew operating aircraft to or from College Park
Airport, Potomac Airfield, or Washington Executive/Hyde Field must
successfully complete a background check by a law enforcement agency and
that may include a fingerprint-based criminal history records check. (All
three airports are within 15 nautical miles of key landmarks such as the
Washington Monument.)

 Oct. 2002 FAAc All pilots must carry and present picture identification along
                         with their pilot certificates.

Jan. 2003 FAA and TSAd FAA may suspend, revoke, or refuse to issue an
airman certificate to anyone (any citizen or noncitizen) when notified by
TSA after TSA's determination that such a person is a threat to
transportation security.

    July 2003 FAA FAA began issuing the new certificates made of plastic and
 incorporating security features such as a hologram of the FAA seal to replace
                          the old paper certificates.

Dec. 2003 TSAe All non-U.S. citizens or nationals seeking flight training
at a U.S. flight school must undergo a comprehensive background check by
TSA, regardless of aircraft weight.

Source: GAO's analysis of regulations.

a

49 C.F.R. S:S: 1544.229 & 1544.230.

b

14 C.F.R. Part 91, SFAR 94.

c

14 C.F.R. S: 61.3.

d

14 C.F.R. S: 61.18 and 49 C.F.R. S:S: 1540.115 & 1540.117.

e

Pub. L. No. 108-176, S: 612, 117 Stat. @ 2572-74 (TSA has yet to finalize
its implementing regulation).

Prior to September 11, FAA did not require background checks of anyone
seeking a pilot license, also referred to as a pilot certificate. In
November

24

28 C.F.R. Part 105. Vision 100 subsequently amended this requirement,
transferring responsibility for conducting the background checks to TSA
and applying this requirement to all non-U.S. citizens seeking flight
training in aircraft weighing more than 12,500 pounds. TSA has developed,
but not yet implemented, regulations to this effect.

Page 25 GAO-05-144 General Aviation Security

2001, the Aviation and Transportation Security Act required that foreign
student pilots seeking training in aircraft weighing 12,500 pounds or more
undergo a background check by the Department of Justice. Under regulations
issued by the Department of Justice, flight training providers are
responsible for ensuring that aliens applying for flight training in
aircraft weighing 12,500 pounds or more fill out and submit a Department
of Justice Flight Training Candidate Checks Program form and are
fingerprinted. 25 The Foreign Terrorist Tracking Task Force is to perform
a criminal history background check of the foreign candidate and notify
the flight training provider whether or not the foreign candidate is
cleared to receive flight training. 26 According to officials from the
Foreign Terrorist Tracking Task Force, a number of foreign student pilot
candidates have been denied from enrolling in a flight training program
between March 17, 2003 and August 18, 2004. 27 FAA officials said that in
February 2002 they took additional steps to make sure that foreign student
pilots who already had student pilot certificates when the new
requirements went into effect were checked.

In December 2003, the Vision 100-The Century of Aviation Reauthorization
Act (Vision 100) 28 transferred responsibility for conducting background
checks from the Department of Justice to TSA and expanded the background
check requirement to include all foreign student pilots regardless of the
aircraft's size in which they train. 29 TSA has

2528 C.F.R.Part 105.

26

The Foreign Terrorist Tracking Task Force was created in response to
Homeland Security Presidential Directive 2, Oct. 29, 2001. The purpose of
the task force is to (1) deny entry into the United States of aliens
associated with, suspected of being engaged in, or supporting terrorist
activity; and (2) locate, detain, prosecute, or deport any such aliens
already present in the United States. The directive required that the task
force be staffed by personnel from the Department of State, the
Immigration and Naturalization Service, the Federal Bureau of
Investigation, the Secret Service, the Customs Service, the intelligence
community, military support components, and other federal agencies as
appropriate. The Department of Justice delegated authority for
establishing and administering the Flight Training Candidate Checks
Program to the Foreign Terrorist Tracking Task Force.

27

The regulations establishing the Flight Training Candidate Checks Program
became effective on March 17, 2003. 68 Fed. Reg. 7,313 (Feb. 13, 2003)
(codified at 28 C.F.R. Part 105).

28

Pub. L. No. 108-176, S: 612, 117 Stat. at 2572-74.

29

As of July 2004, FAA reported that 3,742 foreign student pilots had active
student certificates and TSA officials estimated that over 200,000 pilots
currently licensed by FAA are non-U.S. citizens.

developed a regulation implementing the mandates of Vision 100 and, at the
time of our review, planned to publish the final regulation and assume the
background check responsibilities from the Department of Justice by
September 30, 2004. According to TSA officials, TSA's Alien Flight Student
program will be similar to the Department of Justice's Flight Training
Candidate Checks Program. 30 A key challenge for TSA is fulfilling its
responsibility to enforce security related regulations will be monitoring
the compliance of flight training programs in the United Sates and Puerto
Rico with this new requirement. We found limitations in the monitoring of
these flight-training programs.

In addition to the Department of Justice regulations governing foreign
student pilots, FAA, in July 2002, implemented changes to the process of
issuing a U.S. pilot certificate to foreign nationals already holding a
pilot certificate from a foreign country. 31 Historically, FAA issued
pilot certificates to pilots who held licenses issued by nations that are
members of the International Civil Aviation Organization based on their
foreign license. Members of the organization, including the United States
and 187 other nations, (including nations known to sponsor terrorism)
agreed to issue private pilot certificates to those holding pilot licenses
from other organization member nations without requiring them to undergo
skills testing.

Because of the destructive potential of larger aircraft, the Aviation and
Transportation Security Act directed TSA to promulgate new rules governing
security requirements for certain public and private charter operations.
Generally, the "twelve-five rule" requires nonscheduled or ondemand
charter services (for passengers or cargo) using aircraft weighing 12,500
pounds or more to implement a specific program of security procedures
similar to those required of scheduled commercial airlines and

30

According to TSA officials, most foreign candidates must receive a U.S.
student or work visa to receive flight training in the United.States.
Under the Department of Justice's Flight Training Candidate Checks
Program, the Department of State would not issue such visas to foreign
candidates unless they had received preliminary approval from the
Department of Justice. TSA officials said that TSA intends to work with
the Department of State to continue this process when the TSA regulation
is finalized.

31

According to TSA officials, responsibility for conducting these checks
will transfer from Department of Justice to TSA in October 2004.

public charters. 32 Similarly, the "private charter rule" requires private
charter services using aircraft weighing 100,309.3 pounds (45,500
kilograms) or more, or that have 61 or more passenger seats, to implement
many of the same security procedures required of the major airlines.
However, we found that TSA faces challenges in monitoring compliance with
these new security regulations. Figure 6 shows that selected existing
security requirements have been expanded from commercial air carriers to
public and private charter aircraft.

Prior to the Aviation and Transportation Security Act, certain aviation
charter services were already subject to security requirements. For
example, charter services using aircraft with 31 seats or more were
required to meet security requirements similar to those in place for
scheduled commercial air carriers.

Page 28 GAO-05-144 General Aviation Security

Figure 6: TSA Has Established Regulations that Expand Federal Security
Requirements from Commercial Air Carriers to Include Some Private and
Public Charter Aircraft

Source: GAO analysis of regulations.

aThe sterile area is the portion of an airport defined in the airport
security program that provides passengers access to boarding aircraft
through the screening of persons and property.

Procedures for Determining Continued Need for Temporary Flight
Restrictions Have Not Been Developed

Since September 11, 2001, FAA has issued temporary flight restrictions
(TFR) for some Department of Defense facilities and for the protection of
the national capital region for indefinite periods without a documented
process to justify their continuance. FAA imposes TFRs to temporarily
restrict aircraft operations within designated areas. Prior to September
11, FAA issued TFRs primarily to safely manage airspace operations during
events of limited duration. Since then, however, FAA, in coordination with
TSA, the Department of Defense, and the Secret Service, among others,

The Number, Size, and in Some Cases Duration of TFRs Has Increased since
September 11,

has increasingly used TFRs for the purposes of national security over
specific events and critical infrastructure. 33

FAA has authority over the U.S. National Airspace System and is the agency
responsible for implementing TFRs via the Notice to Airmen system. 34 For
security-related TFRs, FAA generally requests that TSA's Office of
Operations Policy evaluate requests received from federal and nonfederal
entities-such as the FBI, the Department of the Interior, and state or
local government entities-associated with National Special Security Events
and selected sporting events. 35 TSA evaluates such requests using
security related criteria.

Based on their evaluation of requests for selected security-related TFRs,
TSA officials will make recommendations to FAA regarding whether the TFR
should be issued. On the basis of this information, FAA will make a
determination whether to issue the TFR through the Notice to Airmen
system.

According to FAA officials, prior to September 11, 2001, TFRs were rarely
issued for security purposes. Since then, however, FAA has issued numerous
TFRs for the purpose of national security as a result of increased focus
on aviation security. FAA officials stated that Notices to Airmen and
other records of TFRs were historically not kept after the restrictions
were removed, thus they were unable to provide accurate information on the
number of TFRs issued for national security purposes prior to September
11, 2001. Since that time, however, FAA officials said the agency had
issued approximately 220 Notices to Airmen and associated TFRs.

33

FAA may issue TFRs related to security including TFRs issued for sporting
events and significant national landmarks (14 C.F.R. S: 99.7.) In
addition, FAA may issue securityrelated TFRs by working directly with the
Secret Service for the security of the President and other dignitaries (14
C.F.R. S: 91.141) and the Department of Defense for protection of certain
military facilities (14 C.F.R. S: 99.7).

34

Notices to Airmen are a method by which FAA communicates to pilots
information that is time-critical and is either of a temporary nature or
is not known far enough in advance to permit publication on aeronautical
charts or other operation publications. This can include the
establishment, condition, or change in any facility, service, procedure,
or hazard in the national airspace system. They may be regulatory
(restrictive) or advisory in nature, or both.

35

The Secretary of Homeland Security, after consultation with the Homeland
Security Council, is responsible for designating events as National
Special Security Events. A recent example was the 2004 G-8 Summit in Sea
Island, Georgia.

The size-that is, the amount of airspace restricted both vertically and
laterally-of some TFRs has increased. For example, prior to September 11,
TFRs for presidential visits had a radius of 3 nautical miles with a
ceiling of 3,000 feet. 36 Since then, presidential TFRs have had a radius
of 30 nautical miles, with a ceiling of 18,000 feet. 37 The rationale for
increasing the size of presidential TFRs, according to FAA, was based on
the difficulty the military might have in preventing an airborne attack on
the President once an aircraft was within the 3-nautical mile zone. Figure
7 illustrates the area now covered by a presidential TFR over the Crawford
Ranch in Texas when the President is in residence.

36

Presidential TFRs are issued to address security with respect to airspace
over presidential and other parties. No person may operate an aircraft in
the vicinity of an area to be visited or traveled by the President, Vice
President, or other public figures for which this type of restriction is
issued. According to TSA officials, the size of TFRs issued for
dignitaries other than the President did not increase after September 11,
2001.

37

The first 10 nautical miles from the center of the TFR constitute a no-fly
zone. The area from 10 to 30 nautical miles of the TFR constitute an air
defense identification zone (ADIZ) where operators must obtain a unique
beacon code to identify themselves and maintain constant radio contact
with air traffic controllers.

Figure 7: Temporary Flight Restriction over the Crawford Ranch in Texas when the
                              President Is Present

Source: GAO.

In the case of the national capital region and selected military
installations, the duration of TFRs implemented for national security
reasons has been put in place and subsequently extended for indefinite
periods of time. For example, temporary flight restrictions in and around
the national capital region were established shortly after September 11
and according to FAA officials, no set date has been established for their
removal. These restrictions in and around Washington, D.C., are the
flight-restricted zone and the Washington, D.C. Metropolitan Air Defense
Identification Zone, as shown in figure 8. 38

14 C.F.R. S: 99.3 defines an air defense identification zone as an area of
airspace over land or water in which the ready identification, location,
and control of civil aircraft is required in the interest of national
security. General aviation aircraft must meet certain operational
requirements; that is, pilots must have an approved flight plan by FAA,
maintain two-way radio communications with air traffic control, and have a
transponder that transmits a unique code. According to TSA officials,
smaller general aviation aircraft are limited in their ability to access
the flight restricted zone because of limited operational capabilities
needed to operate in the air defense identification zone. FAA officials
noted that additional airspace, extending in places as much as 45 nautical
miles from the Washington Monument, is also included in the zone.

Figure 8: Washington, D.C. Air Defense Identification Zone Surrounding the
                15-Nautical-mile Radius Flight Restriction Zone

Source: GAO and the Aircraft Owners and Pilots Association.

Note: The Air Defense Identification Zone consists of three overlapping
zones centered on the regions three major airports-Baltimore-Washington
International, Dulles International, and Reagan National Airport-and
extends approximately 30-nautical miles in all directions.

In addition, FAA issued 21 TFRs around various military facilities
throughout the country because of security concerns at these facilities
after the terrorist attacks of September 11. While 8 of these TFRs have
since been canceled, 13 were still in effect as of July 27, 2004, with no
scheduled date for removal or documented analysis to justify their
continued need. According to FAA officials, the agency plans to convert 11
of these areas to national security areas. 39 Once FAA publishes revised
aeronautical charts reflecting the new, permanent advisories recommending
that pilots avoid the airspace, FAA officials said they plan to cancel the
TFRs. In January 2004, FAA issued proposals for converting the remaining
two TFRs to permanently prohibited airspace (where no flights are
permitted). At the time of our review, FAA was still reviewing comments on
the proposal to permanently restrict the surrounding airspaces. Figure 9
shows the status of security-related TFRs FAA established over military
installations since September 11.

  Figure 9: Remaining and Cancelled Security TFRs Over Military Installations

Source: FAA.

In commenting on the draft report, FAA officials noted that one of the 11
remaining military TFRs-Anniston, Alabama-was canceled and established as
a national security area after completed we completed our review. National
security areas are established at locations where there is a requirement
for increased security and safety of ground facilities. For example, FAA
designated a national security area over Rocky Flats Environmental
Technology Site, located in Colorado. Pilots are advised to avoid flying
over these designated areas. During times of heightened alert levels, FAA
may increase the national security area advisories to TFRs.

TFRs May Negatively Affect the General Aviation Industry

TSA, FAA, and general aviation industry stakeholders we spoke with stated
that TFRs negatively affect primarily general aviation operators and
airports. According to aviation industry representatives we contacted and
FAA, the increase in the number, size, and duration of TFRs and, at times,
limited notice given prior to their establishment since September 11 has
resulted in numerous inadvertent violations of restricted airspace. For
example, the Washington, D.C. Air Defense Identification Zone has been
violated over 1,000 times, constituting over 40 percent of all TFR
violations since September 11, 2001. As figure 10 shows, since September
2001, the number of violations of all TFRs has increased dramatically.
General aviation has accounted for most TFR violations committed within
U.S. airspace. Further, about 95 percent of all TFR violations occurred in
airspace secured for either presidential security or other national
security purposes.

Figure 10: Violations of Temporary Flight Restrictions Have Increased

Number of violations

    1,400

1,238

1,200

    1,000

800

600

506

417

400

                                      314

200

28 413017

0
1998 1999 2000 Jan. to Sept. to 2002 2003 Jan. to
Aug. Dec. May
2001 2001 2004

Source: GAO analysis of FAA data.

Although no TFR violations have been shown to be terrorist related,
violators are subject to disciplinary action. According to FAA officials,
violations of a TFR typically result in a suspension of the pilot's
certificate ranging anywhere from 15 days to 90 days. They said that the
most common reason for TFR violations is pilots not reading the Notices to
Airmen for the flight area, a required preflight procedure. Other reasons
for violations included weather problems, mechanical failures, and pilot
in-flight disorientation (i.e., getting lost). FAA officials stated that
the number and severity of disciplinary actions imposed on pilots
violating TFRs have increased since September 11. However, FAA officials
were unable to provide statistical information on the number and severity
of disciplinary actions for pilots violating TFRs before or since
September 11.

The imposition of TFRs can also have an economic impact on general
aviation operations. 40 TSA, FAA, and industry associations we spoke with
stated that the costs associated with restricting airspace can be
significant. The National Business Aviation Association commissioned a
study to estimate the economic impact TFRs have had on general aviation
since September 11. 41 While we did not independently assess the validity
of the association's assumptions or calculations, the study estimated that
general aviation passengers and firms lost over $1 billion because of
increased costs to passengers and lost revenues and additional operating
costs for general aviation firms. 42

We visited St. Mary's Airport in Brunswick, Georgia, to discuss the
economic impact of TFRs with an affected general aviation airport
operator. 43 St. Mary's is located approximately 3 miles south of the
Kings Bay Naval Base, where FAA issued a security-related TFR shortly
after September 11. The airport operator stated that the loss of much of
the general aviation traffic through his airport resulting from the TFR
had significantly reduced his ability to generate revenue to sustain
operations.

40

These costs may be expected to increase with the number of TFRs, and with
their size and duration. A TFR that encompasses a large area and is in
effect for a long period of time is more likely to cause flights to be
cancelled, delayed, or diverted than is a TFR that covers a smaller area
or is in effect for only a short while.

41

Key assumptions underlying the study's estimates were that the typical TFR
lasts about 4 hours and affects approximately 15 flights per hour. Of the
affected flights, about 40 percent were assumed to be delayed, with about
50 percent assumed to be diverted, imposing costs on passengers and
aircraft operators.

42

HLB Decision Economics INC (HLB Reference 6795) March 2004, "The Economic
Costs of Restricting General Aviation Access to Ronald Reagan Washington
National Airport and TFRs (Temporary Flight Restrictions) Since September
11, 2001." The study estimated that, from September 11, 2001, through
March 2004, 2,898 TFRs affected general aviation in the following ways:
approximately 11,101 general aviation flight cancelations, 74,334 general
aviation flight postponements, and 103,162 general aviation flight
diversions to more circuitous routes.

43

St. Mary's would be directly affected by FAA proposals to permanently
prohibit flight operations within airspace under temporary flight
restrictions at the time of our review.

According to the operator, the airport's proximity to the TFR around the
base significantly deters pilots from using the airport. Other airport
operators we visited that were affected by TFRs also cited their negative
economic impacts. A sign warning pilots to avoid restricted airspace near
the St. Mary's Airport is pictured in figure 11.

Although TFRs may have economic and other negative impacts on the general
aviation industry, FAA did not establish a systematic process for
periodically reviewing the continuing need for TFRs over the national
capital region and the 13 TFRs over military installation, or determine
the long-term economic or other impacts on general aviation operations of
these restrictions. While FAA officials said they frequently reviewed TFRs
on an informal basis, they did not conduct routine assessments of the
continuing need for indefinite TFRs based on a consistent, documented set
of criteria or determine the impact of these restrictions on general
aviation. In June 2004, FAA officials, in reporting to Congress on the Air
Defense Identification Zone, did not cite specific criteria or the process
used to determine the continuing need for the restrictions. Instead, FAA
based its report primarily on unspecified security reasons submitted by
TSA. TSA officials cited the continuing threat posed to the national
capital region by organizations such as al Qaeda. While the air defense
identification zone around the national capital region is unique, it is

Enhancing Security at General Aviation Airports Is Difficult because of
Funding Challenges

possible that future circumstances may warrant the issuance of other
temporary flight restrictions of indefinite duration. Without documented
procedures and criteria, FAA cannot ensure that future reviews of flight
restrictions issued for indefinite periods are properly conducted, or
consistently ensure that restrictions on airspace are still needed.

We also found that TSA and FAA were limited in their ability to mitigate
the threat of airborne attack. This is a result of limitations in airspace
restrictions, and the practice of granting pilots waivers to enter
temporarily restricted airspace.

Enhancing general aviation security is difficult because of funding
challenges faced by the federal government and general aviation airport
operators. General aviation airports have received some federal funding
for implementing security upgrades since September 11, but have funded
most security enhancements on their own. General aviation stakeholders we
contacted expressed concern that they may not be able to pay for any
future security requirements that TSA may establish. In addition, TSA and
FAA are unlikely to be able to allocate significant levels of funding for
general aviation security enhancements, given competing priorities of
commercial aviation and other modes of transportation.

About 3,000 general aviation airports are eligible to receive FAA Airport
Improvement Program grants. 44 General aviation airports can use Airport
Improvement Program grant funds for projects that provide safety and
security benefits. For example, 6 of the 31 airport managers we
interviewed, including one of the largest general aviation airports in the
country, said they used Airport Improvement Program grants to pay for some
of their security enhancements after September 11, 2001. In fiscal year
2002, general aviation airports received $561 million in Airport
Improvement Program grants, of which $3.2 million (or about 0.6 percent)
was awarded for security projects, and in fiscal year 2003, $680 million,
of which $1.3 million (or about 0.2 percent) was awarded for security

44

These airports are eligible to receive Airport Improvement grants because
they have submitted applications to be included in and have been accepted
in FAA's National Plan of Integrated Airport Systems. These grant funds
are usually limited to planning, designing, and constructing projects such
as runways, taxiways, aprons, and land purchases. However, they may also
be used for security and safety purposes. Eligible safety and security
projects include improvements or equipment that is required by federal
regulation or, according to FAA officials, if TSA makes an
airport-specific determination that security enhancements are needed.

projects. 45 Because general aviation airports are generally not subject
to any federal regulations for security, 46 in order to meet eligibility
requirements for their grants, general aviation airport projects are
generally limited to those related to safety but have security benefits,
such as lighting and fencing, as well as the acquisition and use of
cameras, additional lighting, and motion sensors. 47 FAA officials stated
that if new security requirements were established for general aviation
airports, security-related enhancement projects related to these
requirements would be eligible and receive priority for Airport
Improvement Program funding. However, given the competing demands of
commercial airports, the large number of general aviation airports
eligible for such funding, and the limitations of the Airport Improvement
Program, 48 funding could be uncertain for general aviation airport
operators to meet any new securityrelated requirements.

The Office for Domestic Preparedness within the Department of Homeland
Security administers two grant programs that could benefit general
aviation airports-the State Homeland Security Grant Program and the Urban
Areas Security Initiative. 49 Under these programs, states may purchase
equipment to protect critical infrastructure, including equipment for
general aviation airports, if the state declares general aviation airports
critical infrastructures. During the course of our review, we learned of
one state that plans to spend a small amount of Department

45

The amounts of 2002 and 2003 Airport Improvement Program funds do not
include grants provided to general aviation airports in states that
receive FAA block grants since detailed information about the total
amounts given to general aviation airports or the amounts of those funds
that went for general aviation security are not readily available,
according to FAA officials. Airport Improvement Program block grant states
are Illinois, Michigan, New Jersey, North Carolina, Pennsylvania,
Tennessee Texas, and Wisconsin.

46

The Potomac, Washington Executive/Hyde Park, and Montgomery County general
aviation airports in Maryland are subject to federal security regulations.

47

The Aviation and Transportation Security Act had extended eligibility for
Airport Improvement Program funding to any additional security-related
facilities and equipment required by law or the Secretary of
Transportation after September 11, 2001, and before October 1, 2002.

48

GAO, Airport Finance: Past Funding Levels May Not Be Sufficient to Meet
Airports' Planned Developments, GAO-03-497T (Washington, D.C.: Feb. 25,
2003).

49

The Office of Domestic Preparedness allocated nearly $1.7 billion in State
Homeland Security grants among the 50 states, the District of Columbia,
and five territories for fiscal year 2004, and an additional $671 million
in Urban Area Security Initiative grants among 50 metropolitan areas.

  Nonfederal Stakeholders Have Taken Steps to Strengthen General Aviation
  Security

of Homeland Security grants to improve the security of general aviation
airports. According to officials in Wisconsin, the state plans to use at
least $1.5 million of its $41 million Homeland Security Grant in 2004 to
enhance security at general aviation airports located along the Great
Lakes.

Vision 100 also authorized the Department of Homeland Security to
establish a $250 million Aviation Security Capital Fund administered by
TSA to alleviate some of the demand on the Airport Improvement Program for
security enhancement grants. Of this amount, $125 million is
discretionary, with priority given to the installation of
baggage-screening equipment at commercial airports while the balance is
allocated by formula based on airport size and other security
considerations. TSA officials noted that Congress did not provide an
appropriation for fiscal year 2004 for the fund. If Congress decides to
make appropriations in the future for these purposes, general aviation
airports will still have to compete with commercial airports for this
discretionary funding. Given the extent of unmet security funding needs at
commercial airports, it seems unlikely that a significant proportion of
funding would be available for general aviation. For example, estimates to
install explosive detection system machinery with commercial airport
baggage systems range from $3 billion to $5 billion. At the time of our
review, $1.2 billion had been appropriated for this effort, and according
to the House Committee on Appropriations, airports will be funded, at
best, for about half of their installation needs. Even if funds were
available, TSA would face a challenge in establishing and prioritizing
security projects eligible for Aviation Security Capital Fund grants
across a wide spectrum of general aviation airports with diverse
characteristics. Although funding is limited for airport improvement,
someairport managers we spoke with said they had expended thousands or
hundreds of thousands of dollars for security in order to attract more
tenants to their facility or to retain their existing tenants.

Nonfederal stakeholders with an interest in general aviation security-
including industry associations, state governments, general aviation
airport operators (owners and managers), and users of general aviation
airports and aircraft-have taken steps to strengthen the security of
general aviation airports and operations. Industry associations have
developed and provided recommendations on best practices for enhancing
security around general aviation airports, have partnered with the federal
government to develop federally endorsed security guidelines, and have
sponsored and provided training for their own voluntary security programs.
Some states also have suggested best practices, established regulations,
and provided funding to general aviation airports to reduce security
vulnerabilities. General aviation airport operators and tenants, such as
air charter services, have also implemented policy and procedural measures
to restrict access to airport property and aircraft. Many airports we
visited and surveyed had installed physical security enhancements, such as
fencing, lighting, surveillance cameras, and electronic access control
gates, and had hired additional security guards. General aviation aircraft
owners have also taken steps to protect their aircraft from misuse.

Industry Associations Many of the general aviation industry associations
we contacted had developed guidance to help enhance the security of
general aviation

Have Provided General

Aviation Airport Operators operations and airports. For example, the
following are some of the

recommendations or best practices designed to strengthen security at
Guidance on Security general aviation airports made by some of the members
of the Aviation Practices and Made Security Advisory Committee's Working
Group on General Aviation

Recommendations to TSA Airports Security: 50

     o Posting signs at general aviation airports warning against
       unauthorized use of aircraft.
     o Securing aircraft when unattended using existing mechanisms such as
       door locks, keyed ignitions, and locked hangars to protect aircraft
       from unauthorized use or tampering.
     o Controlling vehicle access to areas where aircraft operate by using
       signs, fences, or gates.
     o Installing effective outdoor lighting to help improve the security of
       aircraft parking, hangar, and fuel storage areas, as well as airport
       access points.
     o Allowing local law enforcement operational space at the airport to
       provide a security presence that serves as a natural deterrent to
       terrorism.

50

The members of the Aviation Security Advisory Committee Working Group on
General Aviation Airports Security are the Aircraft Owners and Pilots
Association, the Airports Consultants Council, the American Association of
Airport Executives, the Experimental Aircraft Association, the General
Aviation Manufacturers Association, the Helicopter Association
International, the National Air Transportation Association, the National
Association of State Aviation Officials, the National Business Aviation
Association, and the

U.S. Parachute Association.

Several general aviation industry associations, in partnership with TSA,
have also initiated their own voluntary security programs to address the
security of general aviation operations and airports. For example:

     o The Aircraft Owners and Pilots Association, working with TSA,
       established and operates the Airport Watch program. The program was
       formed in March 2002-similar in concept to a neighborhood watch
       program-to improve general aviation airport community awareness.
       Through the program, the association provides warning signs for
       airports, informational literature, and training videotapes to educate
       pilots and airport employees on how the security of their airports and
       aircraft can be enhanced. TSA operates a toll-free hotline
       (866-GA-SECURE) where airport operators, managers, and pilots can
       report suspicious activity to TSA. In May 2004 the hotline began
       receiving calls regarding a variety of airport users' concerns of
       suspicious activities or individuals in and around general aviation
       airports. Figure 12 shows an example of the posters identifying the
       hotline TSA provides to general aviation airports.
     o The National Business Aviation Association developed a set of security
       procedures that corporate aircraft operators can put into place to
       increase the security of their operations. In January 2003, the
       association, in partnership with TSA, initiated a pilot project,
       called the TSA Access Certificate program, at Teterboro Airport in New
       Jersey for operators who had established these procedures in a
       security program and had their security program reviewed and approved
       by TSA. TSA approval allows operators to operate internationally
       without the need of a waiver each time they enter the country. 51 (In
       August 2003, TSA expanded the program

According to general aviation industry association officials, general
aviation aircraft operators wishing to fly to the United States from other
countries must stop in one of seven portal countries before entering the
country.

Page 44 GAO-05-144 General Aviation Security

to include corporate aircraft operators based at Morristown, New Jersey,
and White Plains, New York.) According to association officials, the
concept of a TSA-approved security program could be applied to other types
of general aviation operations. Officials also stated that one operator of
a single general aviation aircraft applied for and received a TSA access
certificate to operate internationally. 52

o  The National Agricultural Aircraft Association created a program to
educate aerial application pilots on safety and security issues (the
Professional Aerial Applicators Support System). 53 According to
association officials, the training program qualifies operators in most
states to meet continuing education requirements needed to maintain state
agricultural aviation licenses.

In addition to providing security guidance and developing security
programs, 10 general aviation industry associations worked together to
make security recommendations to TSA to help prevent the unauthorized use
of general aviation aircraft in a terrorist attack. The group met
throughout the summer of 2003 to review and discuss numerous general
aviation airport security recommendations and evaluated each
recommendation for its appropriateness and effect on enhancing security at
general aviation airports. On the basis of this review, the group issued a
report to TSA on suggested security guidelines. 54

States We Visited Varied in Their Efforts to Address General Aviation
Vulnerabilities

We visited 10 states and found that their efforts to enhance general
aviation security reflected a range of activities. Some states had
implemented new requirements for security, funded security enhancements,
or provided guidance on best practices. Specifically, 2 of the 10 states
we visited had imposed requirements for general aviation airports and
aircraft owners and operators since September 11, 2001. 55

52

TSA officials noted that all certificate holders are corporations.

53

According to the association, the majority of its members are licensed as
commercial applicator-operators who use aircraft to enhance food and fiber
production, protect forestry, and control health-threatening pests.

54

Report of the Aviation Security Advisory Committee Working Group on
General Aviation Airports Security, October 1, 2003, Transportation
Security Administration, Washington, D.C.

55

In addition, TSA officials said that New York had mandated that all
general aviation airports in the state apply TSA's security guidelines.

     o In July 2002, the Massachusetts Aeronautics Commission issued a
       requirement that all airport employees-including general aviation
       airport employees-wear special photo identification badges. According
       to state officials, the badges enable airport personnel to distinguish
       between those who are, and are not, authorized to be on airport
       property.
          * In March 2003, the Governor of New Jersey issued an executive
            order that directed aircraft owners and operators who use the
            state's 486 licensed general aviation facilities to take steps to
            limit access to aircraft. Called the "two-lock rule," the
            executive order requires that all aircraft parked or stored at a
            general aviation facility in New Jersey for more than 24 hours be
            protected by a minimum of two locks that secure or disable the
            aircraft to prevent illegal or unlawful operations.
          * Four of the 10 states we contacted provided funding for security
            enhancements at general aviation airports. This funding, however,
            was generally limited to matching funds for federal grants used
            to install measures that had both a safety and a security
            benefit, such as airport perimeter fencing and lighting projects.
            Some states had grant programs that could be used strictly for
            security enhancements:
     o For fiscal years 2002 through 2004, Georgia's Department of
       Transportation Aviation Programs provided a total of $1,174,000 in
       grants to general aviation airports for fencing, lighting, and
       electronic card-reader gates.
     o In February 2002, Tennessee's Aeronautics Commission issued a policy
       that the state would provide 90 percent of the cost (not to exceed a
       total of $50 million annually) on security-related projects at general
       aviation airports. Eligible projects include security fencing and
       gates, signage, security lighting and motion sensors, and surveillance
       cameras and monitors.
     o In 2003, the State of Washington established a $2 million annual
       matching grant program for general aviation airport security
       enhancements funded by proceeds from the state's aviation fuel tax.
     o In 2004, Virginia appropriated $1.5 million to the state's Department
       of Aviation specifically for security upgrades at general aviation
       airports.
          * California's Aviation Division established a grant program for
            research and development projects that could fund security
            enhancements at general aviation airports. However, the Aviation
            Division's budget has not been sufficient to provide any grants
            from the program over the past 3 years.
          * One of the 10 states we contacted provided guidance on security
            best practices, while 2 others provided guidance on preparing
            airport-specific security plans and self-assessments of
            vulnerabilities. In 3 of the 10 states, the incentive for
            airports to develop security plans is tied to funding
            eligibility.
     o In March 2003, Virginia's Aviation Department Director issued a set of
       best practices and later established a voluntary security
       certification program, encouraging airports to assess their
       vulnerabilities and develop airportspecific security plans.
     o In May 2002, Tennessee's Aeronautics Division issued guidance on
       developing an airport emergency and security plan.
     o In April 2003, Washington's Aviation Division issued security
       guidelines for general aviation airports based on recommendations from
       a task force of pilots, general aviation associations, airports, law
       enforcement, and government agencies.

General Aviation Airport Managers and Aircraft Owners Are Primarily
Responsible for Security Enhancements

Unlike commercial service airports, general aviation airports are not
subject to current federal security regulations, 56 and, therefore,
general aviation managers and aircraft owners determine what security
measures they will use to protect their assets. To determine security
measures undertaken since September 11, we judgmentally selected and
visited 31 general aviation airports in 10 states open to the public and
part of FAA's National Plan of Integrated Airports. 57 Airport managers we
contacted reported spending as little as $10 for providing forgery-proof
identification badges for airport employees to as much as $3 million on,
among other voluntary measures at one airport, fencing and
around-the-clock security guards. In our survey, about a third (36
percent) of managers reported that funds to pay for security improvements
had come from airport revenues, while about a fifth reported receiving
federal grants (21 percent) and a

5649 C.F.R. Part 1542.

57

A primary purpose of the National Plan of Integrated Airports (NPIAS) is
to identify the airports that are important to national transportation
and, therefore, eligible to receive grants under the Airport Improvement
Program. The NPIAS is composed of all commercial service airports, all
reliever airports, and selected general aviation airports. The word
"airport" includes landing areas developed specifically for helicopters
and seaplanes as well as conventional fixed wing aircraft landing areas.

fifth reported receiving state grants (22 percent) to finance security
improvements. 58

According to 18 of the 31 airport managers and 3 of 5 tenants (e.g., fixed
base operators) 59 we visited, the security measures and practices they
implemented following the September 11 attacks were self-initiated, common
sense kinds of measures that were expected by the public and their clients
to help protect property from vandalism or theft. Many of these measures
were no-cost or low-cost security enhancements based primarily on
procedural changes. For example, for those airports that did not have
formal written security plans, airport managers said they generally
discussed security issues with their tenants on a regular basis through
meetings and e-mails. Other airports that had formal written security
plans or procedures updated those security plans and procedures based on
recommendations from industry associations. Some of the 31 airport
managers we visited said they had arranged for more frequent patrols by
local law enforcement officers since September 11, some for no cost to the
airports.

Many of the airports we visited had implemented an "airport watch"
program-similar to neighborhood watch programs-and displayed signs
designed and provided by the Airline Owners and Pilots Association, as
discussed above. Other airports absorbed the cost of installing new signs
warning against trespassing. Our survey of airport managers identified an
increase in the use of security awareness training since September 11. For
those aircraft owners who do not store their aircraft in a hangar, forms
of securing their aircraft from unauthorized use include attaching devices
to propellers, known as "prop locks," to prevent them from rotating; and
devices to cover throttle levers, known as "throttle locks," to prevent
someone from being able to start the aircraft. Figure 13 shows two kinds

58

We conducted a probability sample consisting of 499 or the 2,829 general
aviation airports that are open to the public and part of FAA's National
Plan of Integrated Airports (NPIAS). We conducted this survey between
March and May 2004, and obtained 344 eligible responses. From this sample,
estimates are produced for a target population defined as managers of
service level general aviation airports that were included in the FAA
National Plan of Integrated Airports database as of January 2004. Because
we used a probability sample, the estimates could be different for a
different random sample. For estimated percentages in this report, we are
95 percent confident that the actual value is within +/- 6 percentage
points of the survey estimate.

59

Fixed-base operators provide a variety of services to pilots, such as
flight training, aircraft rental, fueling, maintenance, parking, and the
sale of pilot supplies.

of prop locks aircraft owners use. According to airport and state aviation
officials, prop locks range in cost from about $150 to about $300.

Sources (top to bottom): San Carlos Airport, San Carlos, California and
Virginia Department of Aviation.

Several of the airport managers we visited had invested in high-cost
security measures to minimize access by potential criminals and terrorists
to airport property and, thus, tenants' aircraft. Specifically, airport
officials

                  Page 49 GAO-05-144 General Aviation Security

                                  Conclusions

we visited had obtained federal or state grant assistance for purchasing
additional fencing and lighting or purchasing high-tech surveillance
cameras. However, several airport managers and tenants considered
additional security a cost of conducting business in the post-September 11
environment. Airports officials generally said that they spent between
$25,000 and $500,000 on security enhancements such as fencing, lighting,
and electronic access gates. While airport officials said they would like
to add more security enhancements, they were reluctant to spend much more
on enhancing security until TSA issued guidance on what security measures,
or combination of security measures, TSA considers appropriate. (As noted
previously, TSA issued security guidelines with recommended enhancements
in May 2004, after the majority of our site visits.)

Officials from the National Business Aviation Association said that
corporate aviation departments are more likely to take high-cost measures
to protect their aircraft. For example, some of the large member
corporations had provided information on the types of security measures
they used before September 11, to protect their aircraft from tampering,
theft, or hijacking. According to the association, these included the
types of security initiatives shown in table 3.

Table 3: Examples of Security Measures Used by Aviation Departments of 55
Fortune 500 Corporations

                       All aircraft are stored in hangars

All hangars are closed and monitored with security systems when the area
is unattended.

           Mechanics are all company employees or vetted contractors.

                       Visitors are personally escorted.

        Aviation facilities are restricted by an access control system.

Aircraft doors are kept closed and locked when the aircraft is in a secure
                                    hangar.

Comprehensive background investigations are conducted for flight crew personnel.

                Source: National Business Aviation Association.

From its inception, TSA has primarily focused its efforts on enhancing
commercial aviation security to prevent aircraft from again being used as
weapons. The amount of TSA's resources and the vastness and diversity of
the general aviation airport system mean the bulk of the responsibility
for determining vulnerabilities and instituting security enhancements has
fallen and will likely continue to fall on airport operators. As the 9/11
Commission concluded, homeland security and national preparedness

Page 50 GAO-05-144 General Aviation Security

often begins with the private sector. While the federal government can
provide guidance and some amount of funding for security enhancements,
long-term success in securing general aviation depends on a partnership
among the federal government, state governments, and the general aviation
industry.

Even with such a partnership, enhancing security at general aviation
airports presents TSA and the general aviation community with challenges
that will not be easily or quickly resolved. For example, TSA's planned
risk management approach for general aviation could assist the agency in
providing guidance and prioritizing funding for security enhancements by
assessing vulnerabilities and threats to better target its efforts.
However, without a documented implementation plan for assessing threats
and vulnerabilities that sets forth time frames and goals and the
resources needed to achieve these goals, there is limited assurance that
TSA will focus its resources and efforts on areas of greatest need,
monitor the progress of its efforts, and hold responsible officials
accountable for achieving desired results. In addition, completing
vulnerability and threat assessments in partnership with general aviation
airports should help TSA better communicate threat information. However,
because TSA must rely on other federal agencies to provide threat
information and follow federal requirements governing disclosure of
classified information, it is difficult for TSA to adhere to risk
communication principles, particularly in providing specific and
actionable information. Nevertheless, effective communication of threat
information is important because misallocation of limited resources and
disruption of operations are possible effects of communicating nonspecific
or incorrect threat information.

While TSA and FAA have promulgated regulations to help reduce security
risks associated with access to aircraft and airspace, the intended
security benefit of these regulations may be limited for a variety of
reasons. For example, we found limitations in TSA's process for monitoring
flight training providers and operators of private charter aircraft, and
in granting waivers to pilots to fly through security related flight
restrictions. In addition, FAA has not documented its process for
reviewing and revalidating the need for continuing security-related flight
restrictions on airspace that are established for indefinite periods.
Without plans for monitoring compliance or procedures to document agency
processes, TSA and FAA cannot ensure that these regulations achieve their
intended effect or minimize the negative impacts of the regulations on
affected general aviation industry stakeholders.

To better assess the threat of terrorists' misuse of general aviation
aircraft

  Recommendations for

and to improve the quality of communicating terrorist threat information

Executive Action to the general aviation community, we recommend that the
Secretary of the Department of Homeland Security direct the Assistant
Secretary of Homeland Security for the Transportation Security
Administration to take the following two actions:

     o Develop an implementation plan for executing a risk management
       approach that will help identify threats and vulnerabilities. Such a
       plan should include milestones, specific time frames, and estimates of
       funding and staffing needed to focus its resources and efforts on
       identified airports.
     o After identifying the most critical threats and vulnerabilities, apply
       risk communication principles, including to the extent possible the
       nature of the threat, when and where it is likely to occur, over what
       time period, and guidance on actions to be taken-in developing and
       transmitting security advisories and threat notifications.

To help ensure that temporary flight restrictions issued for indefinite
periods are reviewed and, if appropriate, revalidated and consistently
applied, we recommend that the Secretary of the Transportation direct the
Administrator of the Federal Aviation Administration to establish a
documented process to justify the initiation and continuance of flight
restrictions for extended periods.

In our restricted report, we also made two recommendations to the
Secretary of the Department of Homeland Security regarding monitoring
compliance with regulations governing the identification of student
pilots, their training, and the operation of certain general aviation
aircraft; and the process for granting pilots waivers to enter restricted
airspace.

                                Agency Comments

We provided draft copies of this report to the Department of Homeland
Security, the Department of Transportation, the Transportation Security
Administration, and the Federal Aviation Administration for their review
and comment. TSA generally concurred with the findings and recommendations
in the report and provided formal written comments that are presented in
appendix II. TSA provided technical comments that we incorporated as
appropriate. FAA also generally concurred with the findings and
recommendations in the report and provided technical comments that we
incorporated as appropriate.

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
the date of this report. At that time, we will send copies of this report
to the Secretary of the Department of Homeland Security, the Secretary of
the Department of Transportation, the Assistant Secretary of Homeland
Security for the Transportation Security Administration, and the
Administrator of the Federal Aviation Administration and interested
congressional committees. In addition, the report will be available at no
charge on GAO's Web site at http://www.gao.gov.

If you or your staff have any questions about this report or wish to
discuss it further, please contact me at (202) 512-8777 or at
[email protected], or Chris Keisling, Assistant Director, at (404) 679-1917
or at [email protected]. Key contributors to this report are listed in
appendix

III.

Sincerely yours,

Cathleen A. Berrick Director, Homeland Security and Justice Issues

Appendix I: Objectives, Scope, and Methodology

To determine what steps the federal government has taken to identify and
assess threats to and vulnerabilities of general aviation, and communicate
that information to stakeholders, we interviewed individuals in the
Transportation Security Administration's (TSA) Office of Transportation
Security Policy, Office of Operations Policy, and General Aviation
Operations and Inspections Office on TSA's role in enhancing general
aviation security. Individuals from these offices provided documentation
on TSA's threat assessment efforts as well as its past vulnerability
assessment activities and future vulnerability assessment plans. We
examined documentation on TSA's means of obtaining intelligence
information and disseminating that information to general aviation
stakeholders. We also interviewed individuals from FAA's Special
Operations Division and Airspace and Rules Division on their roles in
securing general aviation. We examined documentation from the Federal
Bureau of Investigation (FBI) and the Central Intelligence Agency (CIA) on
intelligence regarding potential terrorist misuse of general aviation. In
addition, we examined documentation from TSA and FBI on the reasons
general aviation may be vulnerable to terrorist misuse. We also spoke to
staff in and examined documentation from TSA's Office of Threat Assessment
and Risk Management to obtain information on plans to implement a risk
management approach to further assess threats and vulnerabilities and to
enable the agency to implement risk communication principles to
communicate threat information.

To determine what steps the federal government has taken to strengthen
general aviation security, and what, if any, challenges the government
faces in further enhancing security, we obtained and analyzed information
from Federal Aviation Administration (FAA), including data on the number
of flight restrictions that affect general aviation and the amount of
federal funding that has been spent on enhancing general aviation
security. We sought to determine the reliability of these data by, among
other things, discussing methods of inputting and maintaining data with
FAA officials. We spoke to TSA officials about, and examined related
documentation on, security guidelines published by TSA, including
documentation on TSA's activities with the Aviation Security Advisory
Committee's Working Group on General Aviation Airports Security. We
interviewed general aviation industry representatives, including those who
provided input to the TSA-sponsored Aviation Security Advisory Committee's
Working Group on General Aviation Airports Security, to obtain their views
on federal efforts to enhance general aviation security. We also
interviewed individuals from TSA's Office of Compliance on the
promulgation of regulations as a result of the passage of the Aviation and
Transportation Security Act, as well as TSA's plans for ensuring operator

Appendix I: Objectives, Scope, and Methodology

compliance with these regulations. We interviewed personnel from FAA's
Special Operations Division regarding FAA's issuance of temporary flight
restrictions, including the criteria and internal controls FAA uses to
examine requests for these restrictions from federal and nonfederal
entities. As part of this analysis, we took steps to verify the
reliability of data from FAA on the number of violations of temporary
flight restrictions. We interviewed FAA and TSA officials on potential
limitations of the effectiveness of these flight restrictions. We also
contacted the Director of the Foreign Terrorist Tracking Task Force on
efforts to screen foreign students applying for flight training in the
United States. We examined potential sources of funding for additional
security measures at general aviation airports, including challenges
associated with limited funding.

To determine the actions individual general aviation airport managers have
taken to enhance security at their airports, we visited 31 general
aviation airports in 10 states. We judgmentally selected these 31 airports
to observe a cross section of general aviation airports. However, we
limited our selection of general aviation airports to the 2,829 listed in
FAA's National Plan of Integrated Airport Systems, because these airports
are eligible for FAA funding and are open to use by the general public.
The remaining 16,000 general aviation airports are generally privately
owned and not open to use by the public, and/or are small landing strips
with fewer than 10 based aircraft, and are not eligible for federal
funding. To ensure we selected a cross section of general aviation
airports listed in the National Plan, we based our selection on:

 1. Size, using the number of based aircraft as an indicator-100 or more
       aircraft we considered large, 25 to 99 medium, and 24 or fewer small.
 2. Regional location-northeast, northwest, southeast, and southwest areas
       of the country.
 3. Proximity to potential terrorist targets such as large population
       centers versus sparse population areas, as well as near to and far
       from other critical infrastructures and symbolic landmarks.
 4. Airport characteristics, including number, length, and type (turf or
       paved) of runways, and primary types of general aviation operations
       such as recreational aviation, business and corporate aviation,
       charter services, and flight training.

Because we judgmentally selected these general aviation airports, we
cannot draw generalized conclusions based on airport managers' interview

Appendix I: Objectives, Scope, and Methodology

responses. However, the anecdotal information provided is intended to
complement the findings of our random survey of 500 general aviation
airports.

To obtain examples of what some states have done to enhance general
aviation security, we judgmentally selected 10 states with efforts to
enhance general aviation security ranging from issuing new security
requirements to those in the early stages of determining how they would
address general aviation security. To select this range of states, we
conducted a literature search to determine which states had proposed or
enacted new security laws, regulations, or requirements. We also requested
recommendations from the National Association of State Aviation Officials
and other industry associations such as the Aircraft Owners and Pilots
Association, and noted which state aviation directors had participated in
the National Association of State Aviation Officials' Task Group on
General Aviation Security. We also considered whether a state participated
in FAA's block grant program in which FAA provides airport improvement
program grant money to a state in a lump sum and the state determines
which airport projects to fund, rather than each airport applying directly
to FAA for grant funds on a project-by-project basis. Finally, on the
basis of our resources, we considered those states in which we also
planned to visit general aviation airports. Because we did not randomly
select the states in which we obtained information, we cannot draw
generalized conclusions about all states. However, the information
obtained from these 10 states serves to provide examples of what some
states have done to enhance general aviation security.

Appendix II: Comments from the Transportation Security Administration

 Appendix II: Comments from the Transportation Security Administration Appendix
          II: Comments from the Transportation Security Administration

Appendix III: GAO Contacts and Staff Acknowledgments

Cathleen A. Berrick (202) 512-3404

  GAO Contacts

Chris Keisling (404) 679-1917

In addition to those named above, Leo Barbour, Grace Coleman,

  Staff

Chris Ferencik, Kara Finnegan-Irving, Dave Hooper, Stan Kostyla,
Acknowledgments Thomas Lombardi, Mark Ramage, Robert Rivas, Jerry Seigler,
and Richard Swayze were key contributors to this report.

(440245)

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