Industry Calls For Systematic Approach To Evaluating Threat Risk

The Air Transport Association and its member airlines believe that the threat of terrorism, particularly aviation terrorism, can best be defeated by close cooperation between government and industry. Such cooperation should focus primarily on the rigorous application of systematic risk management techniques. This approach permits risks to be assessed and prioritized, and available resources are deployed accordingly through a layered systems approach to security. This pragmatic approach offers the best course for the United States.

Among the terrorist threats we are confronting, the risk of a MANPADS attack on a commercial airliner is an extremely serious concern. So too, however, are threats from other types of weapons and tactics that might be utilized by those intent on harming our nation by attacking our aviation system. Therefore, it is critically important in confronting all of these threats that we be guided by the best intelligence and law enforcement information available. With this information, we can apply a systematic risk management program to determine how to best marshal available resources.

The airline industry must rely upon government intelligence and law enforcement authorities to prioritize the threat of a MANPADS attack relative to the array of other terrorist threats confronting the United States. Once that priority is assigned, there is universal agreement on three key lines of defense against a MANPADS attack, each of which offers unique benefits:

• Actions to stem the proliferation of MANPADS and reduce/eliminate their availability to terrorists
• Actions to reduce the opportunity for terrorists to operate in the vicinity of airport facilities where aircraft are most vulnerable to attack (including improved intelligence and information sharing)
• Development of counter-MANPADS technologies suitable for application in the commercial aviation environment.

Each of these lines of defense offers the potential for significant risk reduction. It is of vital importance, therefore, that each line of defense be advanced in a layered security program with balanced focus and adequate resources. A failure to advance these defenses on a proportional basis – an over-reliance on “over-resourcing” any one line while not advancing the others unacceptably increases the risk of failure.

At present there is no coherent effort to rank the MANPADS threat in relation to other risks. This is resulting in a significant distortion of resources and focus, with counter-MANPADS technology development receiving inflated resources and attention, while the other threats are under-emphasized.

The ATA and its member airlines believe that a decision to push forward with the development and even initial deployment of counter-MANPADS technology systems is being promoted largely at the instigation of the vendor community without an adequate information base. If this pressure is not tempered by careful deliberation, there is a serious risk of substantial resources being misdirected at a time when those resources are critically needed to confront other significantly high priority threats.

Alternatively, if, after careful deliberation, the government has determined that the MANPADS is the highest priority threat, the available resources appear to be misallocated with over emphasis on counter-MANPADS system development and deployment, while anti-proliferation and airport vulnerability programs suffer. Unfortunately, we believe development and deployment is being pushed without the necessary deliberation or ranking.

Before moving forward with further expenditures for the development or deployment of counter-MANPADS technology for commercial aviation, the ATA member airlines urge both Congress and the Administration to insist that the MANPADS attack risk be assigned a priority in relation to all other threats of aviation terrorism.

Utilizing that ranking, future expenditures must be proportionally distributed to counter the array of threats presented. Further, within the category of expenditures dedicated to the MANPADS threat, funds must be allocated to effectively advance, anti-proliferation and vulnerability defenses on a level equivalent to technology development.

Finally, before any decision is made to move forward with the deployment of counter-MANPADS technology aboard commercial aircraft, the following questions must have been clearly and definitively answered.

Deployment

Are systems to be installed aboard all commercial aircraft or, as some suggest, only aboard Civil Reserve Air Fleet aircraft or wide-bodies traveling to certain destinations?

• If a less-than-full fleet deployment is planned, is there reason to believe US adversaries would not take that into account in targeting vulnerabilities since it is unlikely such installations will be secret?
• Since larger aircraft are relatively better able to withstand a MANPADS strike, how is deployment on that fleet rationalized?

Costs

• What is the expected full life cycle cost of a counter-MANPADS system in commercial operation, including acquisition, installation, maintenance, operation, weight/drag penalties, and other costs resulting from the mandated requirements?
• Will the manufacturers of this technology guarantee the life cycle cost estimates?
• How would costs be impacted by any mandated compliance period and what is the anticipated compliance period?
  How do the costs compare on an annualized per aircraft basis to the historic record of airline profits/losses on a per aircraft basis?
• How does the government plan to support this program?

The defense of our aviation system must be a national defense priority and one fully supported by general tax dollars. Any suggestion that the industry or its customers can sustain these costs is misplaced.

System Effectiveness/Reliability

• What is the likelihood of a counter-MANPADS system effectively engaging and destroying a single MANPADS attack; two simultaneously fired MANPADS; more than two?
• What guarantees are system manufacturers willing to provide with regard overall system reliability; how will these guarantees be enforced?
• What guarantees are systems manufacturers willing to provide with regard to system effectiveness?

  

Liability

• Who is liable if a system fails to operate or if a false alarm contributes to an aircraft accident?

FMI: www.airlines.org