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?