+------------------------------------------------+---------------------+
| Bureau of Customs and Border Protection        | Telephone +46 - 8 - |
|                                                | 797 2634            |
| Office of Regulations and Rulings              |                     |
|                                                | Telefax +46 - 8 -   |
| Regulations Branch                             | 797 2240            |
|                                                |                     |
| 1300 Pennsylvania Ave., NW (Mint Annex)        | Mobile +46-70-997   |
|                                                | 2634                |
| Washington,                                    |                     |
|                                                | e-mail              |
| DC 20229                                       | tho                 |
|                                                | mas.jakobson@sas.se |
|                                                |                     |
|                                                | Address:            |
|                                                |                     |
|                                                | Scandinavian        |
|                                                | Airlines\           |
|                                                | Dept. STOKU         |
|                                                |                     |
|                                                | Frösundaviks Allé   |
|                                                | 1, Solna\           |
|                                                | 195 87 Stcokholm    |
|                                                |                     |
|                                                | Sweden              |
+------------------------------------------------+---------------------+
| 19 CFR Parts 4 and 122.                        | October 10, 2006    |
|                                                |                     |
| (USCBP-2005-0003)                              |                     |
+------------------------------------------------+---------------------+

## 

19 CFR Parts 4 and 122.

(USCBP-2005-0003)

SAS welcomes the opportunity to comment on the NPRM published on the
14^th^ of July 2006, on the subject of Passenger Manifests for
Commercial Aircraft Arriving and Departing From the United States.

First, SAS want to emphasize that SAS fully support [all]{.underline}
the recommendations and comments made by Association of European
Airlines (AEA) in their letter to CBP, regarding Passenger Manifests for
Commercial Aircraft Arriving and Departing From the United States, and
SAS would like to refer to that letter for AQQ/APIS-60 topics not
commented by SAS in this document.

SAS will in this letter comment on *some* of the provisions in the NPRM
that SAS find extremely important, and that may have serious effect on
SAS -- and other European carriers -- operations to-, and from the US.

Please also note that SAS [do not]{.underline} regard the APIS --60 as a
feasible option.

Yours sincerely,

Scandinavian Airlines System

![](media/image1.png){width="1.5569444444444445in" height="0.6125in"}

Thomas Jakobson

Manager Facilitation -- Scandinavian Airlines\
Procedures Support & Training

1\. [High-Risk Passengers -- Boarding cards]{.underline}

SAS fully agree with CBP\'s suggestion that high-risk passengers should
be prevented from boarding an aircraft. Manifest data should therefore
be vetted before boarding.

SAS is, however, of the opinion that the issuance of boarding cards
should not be affected by this rule, as it is the *boarding* of
passengers concerned that need to be addressed -- not the issuance of
boarding cards.

[Today, all airlines DCS are fully capable to prevent passengers, who
have not been vetted against any relevant governmental data base, from
boarding an aircraft -- irrespective of boarding cards or
not]{.underline}.

The restriction on issuance of boarding cards will seriously affect
airlines ability to handle huge amounts of passengers in an efficient --
and customer friendly -- way.

The self service kiosk\'s can not be utilized in the check-in process
for passengers to- and from USA, as the restriction on boarding card
issuance will force airlines to refer all *local boarding* passengers to
manual check-in (API registration) before entering the sterile area of
an airport.

The fact that the NPRM allows for travelers, checking in in other
carriers DCS to be issued a (provisional) boarding card without any
vetting result makes the whole concept harder to understand; These
passengers will -- in fact -- have access to the sterile area at the
last airport of transfer, i.e. the airport from which the aircraft will
depart for the non-stop flight to/from the US.

Another issue, of concern to SAS, is the fact that SAS is *moving away*
from the issuance of boarding cards as a way to minimize the mandatory
(sometimes unnecessary) moments in the passenger handling process. SAS
sees this as a, in many cases, logical step to take as passengers in the
near future will only travel on some kind of electronic tickets. Thus --
the next step may be the \'electronic boarding card\'.

Any requirement from the US -- or any other state -- to issue boarding
cards, will seriously preclude any development in this area, and prevent
-- in many cases -- an obsolete way of handling passengers.

**Therefore SAS propose that the requirement to issue boarding cards for
passengers traveling to-, or from the US, must be removed in the Final
Rule.**

**It must be the carrier\'s decision whether to issue a boarding card or
not**.

2\. [The 15 minutes prior to departure deadline for
check-in]{.underline}.

SAS do [not see any reason]{.underline} for any governmental decided
deadline for check-in.

When a passenger has been vetted by CBP, then this should be the *only*
criterion fulfilled for boarding or not boarding.

The 15 minutes prior to departure deadline should not be an government
concern, but the decision to accept a passenger for travel lies solely
within the responsibility of the airline concerned -- *provided* the
passenger have been vetted [and]{.underline} accepted by CBP.

**Therefore SAS propose that the 15 minutes prior to departure check-in
deadline is removed in the Final Rule.**

3\. [Response time]{.underline}.

Any response time for the \"board\" or \"not board\" message beyond 2
seconds/request will have serious effect on the handling of passengers
at the departure station.

The response time (2 seconds) is not the only time that will affect the
\'normal\' processing time; The AQQ handling in itself may very well
prolong every passenger\'s check-in time with approximately 10 seconds.

The areas where passenger check-in takes place are not (today) designed
for extra lines and extended processing of passengers. The consequences
will be congestions at the check-in areas -- and at the departure gates
-- of airports with non-stop traffic to/from the US.

**Therefore SAS propose that the CBP- in the Final Rule - commit to a 2
seconds process time.**

4\. [Lead time for implementation]{.underline}.

The lead-time for implementation (180 days after publication) is *not*
sufficient.

Airlines today have limited IT-resources, and these are often engaged in
projects that -- in many cases -- last over a year in time. In order to
allow airlines to develop system solutions where AQQ is an integrated
part of the functionality, airlines must be allowed to design the best
possible solution, where -- among many issues -- the system stability
(i.e. reliability) is the most important. System outages are -- needless
to say -- of no use to nobody.

[Such development takes time, and SAS see *no possibility* to design,
program, test and code, our DCS within 180 days after the
publication]{.underline}.

A more feasible deadline would be a year (360 days) from publication,
which will allow for more quality in planning, design, testing, and --
last - implementation.

**Therefore SAS propose that the effective date of a Final Rule be
delayed for at least 360 days from the date of its publication.**

5\. [Management of watch lists]{.underline}.

SAS will here point to the importance of having all questions, raised by
AEA in their document regarding management of watch lists, answered
before publishing the Final Rule.

**The reason for this is obvious; in addition to the time for processing
of passengers (see 3. Response time) the time for extra, additional
queries for passengers, *not immediately* cleared, will have impact on
the process. In order to be able to determine *how much impact* this may
have, it is essential that airlines -- to the extent possible - be
informed of the internal CBP processing of such passengers**.