Department of Homeland Security

Office of Inspector General 

TSA's Role in General Aviation Security
 

OIG-09-69 May 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

May 27, 2009 

Preface 

The Department of Homeland Security Office of Inspector General was established by 

the Homeland Security Act of 2002 (Public Law 107-296) by amendment to the Inspector 

General Act of 1978. This is one of a series of audit, inspection, and special reports 

prepared as part of our oversight responsibilities to promote economy, efficiency, and 

effectiveness within the department. 

In response to a congressional request from U.S. Representative Sheila Jackson Lee, 

chairwoman of the Subcommittee on Transportation Security and Infrastructure 

Protection, House Committee on Homeland Security, this report addresses the current 

general aviation security requirements, the threat environment, and the steps the 

Transportation Security Administration has taken in the past 3 years to strengthen general 

aviation security. It is based on interviews with employees and officials of relevant 

agencies and institutions, direct observations, and a review of applicable documents. 

We trust this report will result in more effective, efficient, and economical operations. 

We express our appreciation to all who contributed to the preparation of this report. 

Richard L. Skinner 


Inspector General 

Table of Contents/Abbreviations 


Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2
 

Results of Review ................................................................................................................4
 

Houston Is Not a “Sitting Duck for Terrorism”.............................................................4 


General Aviation in Major Metropolitan Areas Presents Few Security Concerns ........7 


TSA Security Requirements Include General Aviation...............................................13 


TSA Is Using a Threat-Based Approach to General Aviation Security ......................13 


Risk Reduction Steps Have Strengthened General Aviation Security.........................14 


TSA Has a Record-Keeping Process for “Incidents of Concern”................................15 


General Aviation Operations Present a Limited Threat to Security; 


However, Steady Vigilance Must Be Maintained........................................................16 


Appendixes 

Appendix A: Purpose, Scope, and Methodology ........................................................17 


Appendix B: Current TSA GA Security Requirements ..............................................18 


Appendix C: Actions Nonfederal Stakeholders Have Taken......................................24 


Appendix D: General Aviation Intelligence Assessments ..........................................28 


Appendix E: Major Contributors to this Report..........................................................30 


Appendix F: Report Distribution ................................................................................31 

Table of Contents/Abbreviations 


Abbreviations 

AOPA Aircraft Owners and Pilots Association 

DCA Washington Reagan National Airport 

DPA DuPage Airport 

DHS Department of Homeland Security 

FAA Federal Aviation Administration 

FBO fixed base operator 

FRZ Washington DC Metropolitan Area Flight Restricted Zone 

GA general aviation 

GAO Government Accountability Office 

HAI Helicopter Association International 

IAH George Bush Intercontinental Airport 

LAX Los Angeles International Airport 

LASP Large Aircraft Security Program 

LGB Long Beach Airport 

OI Office of Intelligence 

OIG Office of Inspector General 

ORD O’Hare International Airport 

PCSSP Private Charter Standard Security Program 

SFRA Special Flight Rules Area 

TEB Teterboro Airport 

TFSSP Twelve-Five Standard Security Program 

TSA Transportation Security Administration 

TSNM Office of Transportation Sector Network Management 

TSI Transportation Security Inspector 

TSOC Transportation Security Operations Center 

VNY Van Nuys Airport 
OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

General aviation refers to all flights other than scheduled airline flights 

and military aviation. General aviation accounts for 77% of all flights in 

the United States and is a vital component of the national economy. It 

includes the very large air cargo transport sector, air medical-ambulance 

operations, flight schools, corporate aviation, and privately owned aircraft. 

General aviation activity frequently takes place alongside scheduled 

airline operations at large commercial airports, as well as at more than 

5,000 public use airports, almost all of which serve general aviation 

exclusively. 

This review was conducted at the request of Representative Sheila Jackson 

Lee, chairwoman of the Subcommittee on Transportation Security and 

Infrastructure Protection, House Committee on Homeland Security. Our 

objectives were to identify Transportation Security Administration 

security requirements for general aviation airports, threats to general 

aviation, measures taken to secure general aviation, steps nonfederal 

stakeholders have taken to enhance the security of general aviation, and 

any “incidents of concern” with security at general aviation airports. In 

addition, we evaluated allegations of security vulnerabilities at three 

Houston-area general aviation airports. These allegations were presented 

in an investigative report by a local television station. 

We determined that general aviation presents only limited and mostly 

hypothetical threats to security. We also determined that the steps general 

aviation airport owners and managers have taken to enhance security are 

positive and effective. Transportation Security Administration guidelines, 

communication forums, and alert mechanisms, coupled with voluntary 

measures taken by the owners and operators of aircraft and facilities, 

provide baseline security for aircraft based at general aviation sites. 

Significant regulation of the industry would require considerable federal 

funding. We are not making any recommendations to the Transportation 

Security Administration regarding general aviation regulations. The 

Transportation Security Administration reviewed our report and submitted 

many helpful technical corrections, but chose not to submit formal 

comments that would have been appended to the report. 

TSA’s Role in General Aviation Security 

Page 1 
Background 

Within the federal government, responsibility for general aviation (GA) 

security is shared by the Department of Homeland Security (DHS) 

Transportation Security Administration (TSA) and the Department of 

Transportation Federal Aviation Administration (FAA). TSA was 

established within the Department of Transportation shortly after the 

attacks of September 11, 2001, in accordance with the Aviation and 

Transportation Security Act of 2001 (Public Law 107-71). This legislation 

gave TSA responsibility for security for all modes of transportation. In 

early 2003, TSA was moved from the Department of Transportation to the 

newly created DHS, while the FAA remained in the Department of 

Transportation and retained primary responsibility for GA safety. The 

FAA continues to oversee all aircraft manufacturing, operation, and 

maintenance, certifies pilots and airports, and regulates air traffic. TSA 

assumed operational responsibility for passenger and baggage screening 

and regulatory responsibility for air cargo and airport security. 

Within TSA, the offices of Transportation Sector Network Management 

(TSNM) and Intelligence (OI), provide oversight, guidance, and 

information necessary for GA security. The extent to which GA operators 

employ TSA’s voluntary guidance is not easily determined. 

TSNM establishes policies designed to protect and secure U.S. intermodal 

transportation systems, the safe movement of passengers, and the free flow 

of commerce. TSNM’s strategy calls for (1) completion of industry threat, 

vulnerability, and consequence assessments, (2) development of security 

standards, (3) assessment of operator security status vis–à-vis existing 

standards, (4) development of plans to close gaps in security standards, 

and (5) enhancement of systems of security.1 

OI is the only federal intelligence entity focused solely on security of the 

transportation sector. OI provides TSA, FAA, the rest of the 

transportation sector, and the broader intelligence and law enforcement 

community with analysis, warnings, and notifications on credible and 

imminent threats. To facilitate communication and coordination, OI has 

placed liaison officers in key intelligence community and law enforcement 

agencies across the federal government. 

GA Defined 

According to TSA, GA is a vital component of the aviation sector 

and the national economy and accounts for approximately 77% of 

1

 http://www.tsa.gov/what_we_do/tsnm/index.shtm. 

TSA’s Role in General Aviation Security 

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all flights in the United States.2

 GA encompasses a wide range of 

activities, such as pilot training, business and personal charter 

flights, emergency medical services, and sightseeing. Operations 

at the nation’s 19,000 GA airports and helipads, only about a third 

of which are available for public use, range from short-distance 

flights in single-engine light aircraft to long-distance international 

flights in privately owned jets, and from emergency aero-medical 

helicopter operations to airship displays at sporting events. The 

sole common characteristic of GA operations is that flights are on 

demand, rather than routinely scheduled. 

GA Risk Studies 

Various government and industry studies have concluded that the 

risks associated with general aviation are relatively limited (see 

appendix D). In its November 2004 review, General Aviation: 

Increased Federal Oversight Is Needed, but Continued Partnership 

with the Private Sector Is Critical to Long-Term Success (GAO05-144), the Government Accountability Office (GAO) concluded 

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.” GAO concluded that while the federal 

government provided guidance and some funding and enforced 

regulatory requirements, most of the responsibility for assessing 

and enhancing GA security fell on airport operators. GAO 

recommended that TSA develop a plan for implementing a risk 

management approach to strengthen GA security, and that the FAA 

establish a documented process to review and revalidate flight 

restrictions. TSA and FAA generally concurred with GAO’s 

recommendations. 

Figure 1. Photo of a Cessna 172 

Skyhawk 

Source: http://en.wikipedia.org/wiki/Cessna 

In January 2008, the Congressional Research Service 

reported that typical GA aircraft are too light to use as a 

platform for conventional explosives. Moreover, 

heightened vigilance among airport operators and pilots 

would make it difficult to load the necessary quantity of 

explosives without detection. For example, the 1,300­

pound device involved in the 1993 World Trade Center 

bombing would be beyond the carrying capability of 

most light GA aircraft, such as a Cessna 172 Skyhawk. 

The Skyhawk is one of the most common airplanes used 

by flight schools. The four-seat airplane can be used for 

primary and advanced flight training. In addition, it is a 

2

 http://www.tsa.gov/what_we_do/tsnm/index.shtm. 

TSA’s Role in General Aviation Security 

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practical rental aircraft for cross-country flights. However, its 

payload capacity is approximately 830 pounds, not including the 

weight of a pilot, passenger, or fuel. The report concluded that as a 

platform for conventional explosives, the threat posed by light GA 

aircraft is relatively small compared to the threat posed by trucks.3 

In March 2008, the Aircraft Owners and Pilots Association 

(AOPA) report, General Aviation Security, noted that GAO had 

observed that although nuclear power facilities were not designed 

specifically to withstand a terrorist aviation attack, they are among 

the most hardened industrial facilities in the United States, as they 

were designed to withstand tornadoes, hurricanes, fires, floods, and 

earthquakes.4

 The study concluded that most GA aircraft could not 

penetrate the concrete containment vessel of a nuclear power plant, 

release radiation through an explosion, or otherwise severely 

damage nuclear power plants.5 

Houston in the Media 

Following an investigative report aired by a Houston television 

station concerning security at three local airfields, Chairwoman 

Sheila Jackson Lee requested that we review general aviation 

security at these airfields, and also at others in several other 

metropolitan areas. We performed announced visits to the airports, 

interviewed owners, employees and stakeholders, and toured the 

facilities. In the investigative report “Is Houston a Sitting Duck for 

Terrorism?” reporters visited three GA airports near Houston, 

Texas: David Wayne Hooks Airport in Spring, Texas; Sugar Land 

Regional Airport in Sugar Land, Texas; and Lone Star Executive 

Airport in Conroe, Texas. The television reporters identified what 

they described as “security breaches” at all three airports. 

Specifically, the reporters were able to approach an airfield or 

aircraft without identifying themselves. At one airfield, the reporter 

noted that a fence enclosed only part of the airfield. 

Results of Review 

Houston Is Not a “Sitting Duck for Terrorism” 

This review was initiated in part because of the television station’s 

allegations. We reviewed the allegations and determined that they were 

not compelling. 

3

 Congressional Research Service, Securing General Aviation, January 2008. 4

 AOPA, General Aviation Security Initiatives Since 9-11-2001, March 5, 2008. 5

 AOPA, March 2008. 

TSA’s Role in General Aviation Security 

Page 4 
 

 

 

 

In each instance, the allegation of 

weak security was based on reporters 

gaining access to airfields or aircraft. 

However, the reporters were unaware 

of some passive security and 

monitoring measures. For example, 

the airports had instituted security 

procedures, including 24-hour video 

surveillance, locking or disabling 

grounded planes, and controlling fuel 

access, which the television reporters 

did not test. 

Combined, these airports service more 

than 440,000 aircraft takeoffs and 

landings per year, and each routinely 

operates 24 hours a day, 7 days a 

week. The volume of legitimate 

activity would appear to limit 

opportunities for unobserved loading 

or movement of aircraft. Moreover, 

the issues identified by the television 

reporters were not violations of GA 

guidelines or any federal aviation 

regulations. 

David Wayne Hooks Airport 

David Wayne Hooks Airport is 

the largest of the three airports 

featured in the news story. It is 

Figure 2. Houston Airports Visited 

David Wayne Hooks Airport 

Location: Spring, Texas 

Specialty: Business and military aviation 

Products and Services: Fueling, ground 

handling, passenger services, maintenance, 

aircraft sales and charter, 24-hour operations 

Staff: 225 employees 

Aircraft Movements: 275,000 

Sugar Land Regional Airport 

Location: Sugar Land, Texas 

Specialty: Corporate business travel 

Products and Services: Fueling, ground 

handling, crew services, maintenance, 

luxury terminal, U.S. Customs and Border 

Protection inspection 

Staff: 29 municipal employees 

Aircraft Movements: 85,000 

Lone Star Executive Airport 

Location: Conroe, Texas 

Specialty: Private aircraft, military 

operations 

Products and Services: Fuel, maintenance, 

flight training, aircraft rental, aircraft tiedown and hangar rentals, 24-hour operations 

Staff: 135 employees, three full-service 

private companies, 13 additional aviation 

businesses 

Aircraft Movements: 80,000 

privately owned and operated as a for-profit enterprise. According 

to airport personnel, the airport has two full-time security staff, an 

Figure 3. Aerial View of David Wayne Hooks 

Airport 

Source: www.hooksairport.com/cont.htm, 2004 

FAA tower operator who provides visual 

surveillance, and 24-hour video surveillance. These 

security measures have effectively deterred even 

petty vandalism. The airport does not handle air 

cargo, and most planes are housed in hangars, 

locked, or disabled when not in use. The jet that the 

television reporters approached during the filming of 

their report could not have been moved from the 

ramp without security personnel noticing them 

tampering with the jet. 

TSA’s Role in General Aviation Security 

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Sugar Land Regional Airport 

Figure 4. Diagram of Sugar Land Regional 

Airport 

Source: www.flysgr.com/airportoverview, 

2006 

Sugar Land Regional Airport is 

smaller than Hooks, and has less 

acreage and fewer services, takeoffs, 

and landings. It is owned and 

operated by the municipal 

government. While the television 

reporters noted that the fence did not 

encircle the complex, creating a gap 

of several hundred feet, airport 

managers informed us that fencing 

existed mainly to direct vehicle and 

pedestrian traffic to desired 

gateways for safety reasons, not to 

prevent access. The perimeter 

sectors without fencing were in areas 

where visitors were not expected to 

approach, such as from the adjoining 

minimum-security prison, and from 

a swamp infested with venomous 

snakes and crocodiles. During our 

tour, a manager said that fencing to 

prevent entry was ineffective because anyone who wanted to sneak 

onto the field could scale a fence. Aviation officials explained that 

fencing was ineffective as a security barrier and that meaningful 

protection came from securing planes in hangars and engaging 

wheel and cabin locks on aircraft equipped with these secure 

devices. They further noted that while a reporter might be able to 

approach and even touch an aircraft at an airport, aircraft 

vulnerability does not depend on whether someone can touch a 

plane. 

Lone Star Executive Airport 

At Lone Star Executive Airport, television reporters were able to 

drive alongside a large, empty corporate jet on the tarmac. 

However, airport staff stated that they have 24-hour surveillance 

using infrared and motion sensor devices, and that security is 

enhanced because the Drug Enforcement Agency and Texas 

Department of Public Safety base their own flight operations from 

the airport. The airport regularly approaches people on the ramp, 

and had reported several security incidents—including one 

involving a news crew seeking unauthorized access—to TSA and 

the local police. Local police have a constant presence at the airport. 

TSA’s Role in General Aviation Security 

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Figure 5. Aerial View of Lone Star Executive Airport 

Source: www.mctx.org/air/location.html , 2005 

General Aviation in Major Metropolitan Areas Presents Few 

Security Concerns 

We also visited GA facilities in busy, heavily populated metropolitan 

areas where people might be at risk in the event of a GA terrorist attack. 

In addition to the Houston-area sites mentioned in the television report, we 

conducted site visits at George Bush Intercontinental Airport (IAH) in 

Houston; O’Hare International Airport (ORD) in Chicago, Illinois; 

DuPage Airport (DPA) in Carol Stream, Illinois; Los Angeles 

International (LAX), Long Beach (LGB), and Van Nuys Airports (VNY) 

in the greater Los Angeles, California, area; and Teterboro Airport (TEB) 

in Teterboro, New Jersey. We also visited Potomac Airfield in Fort 

Washington, Maryland. 

Additional Houston-Area Site Visit 

To determine whether GA might pose a threat at a major Houstonarea airport, we visited IAH. IAH serves the greater Houston, 

Texas, area and is a connecting point for many commercial 

carriers. IAH is publicly owned and handles 2% transient GA and 

no local GA. We met with the TSA airport security manager, who 

stated that the airport security team consisted of the senior 

superintendent, operations supervisors, security coordinators, and 

officers who patrol the GA operations area. The airport security 

coordinators are responsible for key audits (accounting for all 

airport keys to the various facilities); listing emergency contact 

telephone numbers; and obtaining, issuing, and monitoring 

employee and contractor badges. The airport coordinators update 

the officers on regulations, threats, keys, and badges. IAH airport 

TSA’s Role in General Aviation Security 

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officials do not get involved with GA except to ensure that the GA 

facilities follow proper safety and security regulations. 

IAH has fixed base operators at the airport. A fixed base operator 

(FBO) is a retail facility that offers aircraft fuel, oil, and parking 

along with access to restrooms and telephones. Some FBOs sell 

additional aircraft services such as hangar (indoor) storage, 

maintenance, aircraft charter or rental, flight training, deicing, and 

ground services such as towing and baggage handling. FBOs also 

may offer services not directly related to aircraft, such as rental cars, 

lounges, and hotel reservations. IAH has two FBOs: Atlantic 

Aviation and Landmark Aviation. There is no flight school at IAH. 

There have been no incidents of concern since an aviation accident 

in 1991 involving GA aircraft. 

Chicago-Area Site Visits 

ORD officials stressed that GA operations are a minor part of 

ORD’s daily activities. Staff within the Department of Aviation 

for the City of Chicago operate the GA facility the same way they 

operate the commercial facility. 

The airport staff works closely with the TSA federal security 

director in executing their Airport Security Plan. The purpose of 

the plan is to increase communication among airport tenants, the 

airport manager, and law enforcement; identify specific activities 

that should be reported; and increase awareness of security issues. 

The elements of a typical airport security plan might include a 

notification system to include an alerting roster of emergency 

personnel at the airport, identification of airport security personnel 

and their responsibilities, explanation of airport signage, the 

incorporation of new technology such as remote cameras and noise 

sensors, an explanation of the established routine patrols by local 

law enforcement, a description of an annual exercise at the airport, 

and ongoing assessments of potential threats to the airport.6 

ORD typically handles 3% transient GA and has no local GA. 

Signature Flight Support is the only FBO at the airport, and there is 

no flight school. 

There have been no incidents of concern. 

6

 nmshtd.state.nm.us/upload/images/Aviation/NM_GA_Artp_Safety_and_Security07.pdf. 

TSA’s Role in General Aviation Security 

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DPA, approximately 30 miles west of ORD in Carol Stream, 

Illinois, is owned by the DuPage Airport Authority, an independent 

government body established by the State of Illinois. DPA handles 

58% transient general aviation and 38% local general aviation. 

DPA has a 24-hour FAA air traffic control tower and more than 40 

aviation and non-aviation support businesses. The airport has only 

one FBO and one flight school. The airport also has an onsite U.S. 

Customs and Border Protection office. There have been no 

incidents of concern at the airport. 

Los Angeles-Area Site Visits 

LAX is publicly owned by Los Angeles World Airports and 

operated by the City of Los Angeles. We observed minimal GA 

operations at LAX. Transient GA comprise 2% of the daily 

takeoffs and landings at LAX. There is no local GA. Landmark 

Aviation and Atlantic Aviation are the two FBOs at the airport. 

There are no flight schools at the airport, and there have been no 

incidents of concern. 

VNY, also owned by Los Angeles World Airports and operated by 

the City of Los Angeles, is one of the world’s busiest GA airports. 

VNY averages approximately 400,000 takeoffs and landings 

annually. More than 100 businesses are located on the 730-acre 

airport, including 6 major FBOs and 6 flight schools. Celebrities, 

politicians, and business executives use this airport because it 

offers them convenience and anonymity. There have been no 

incidents of concern at the airport. 

LGB has 365,000 annual GA takeoffs and landings annually, 

including Life Flight donor organ and critical care patient delivery, 

law enforcement, and search and rescue flights. The city-owned 

airport services charter flights, private aviation planes, and flight 

schools. In addition, it is a center for law enforcement flights, a 

helicopter landing zone, advertising blimps, planes towing 

advertising banners, and similar functions. 

At LGB, 90% of the traffic is GA. Local GA accounts for 51% of 

the GA traffic and transient GA accounts for 39%. Commercial 

flights are restricted to 66 takeoffs and landings per day. The 

airport has four shorter runways and one 10,000-foot runway used 

primarily for jets. LGB has five FBOs and one flight school. 

There have been no reportable incidents at the airport. 

TSA’s Role in General Aviation Security 

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Teterboro Site Visit 

TEB in Teterboro, New Jersey, is owned and operated by the Port 

Authority of New York and New Jersey, which also owns and 

operates LaGuardia and Kennedy airports. TEB, 12 miles west of 

Manhattan, is the second most active GA airport in the country. 

Airport personnel devote considerable security efforts toward 

protecting the many large private jets and dignitary movements. 

The airport is patrolled 24 hours a day. It has five FBOs and no 

flight school. Officials have not identified any major security 

threats, and there have been no security-related incidents of 

concern. 

There have been two aviation accidents that illustrate the effect of 

GA aircraft impacting buildings. 

In February 2005, a CL-600 Challenger corporate jet crashed into a 

warehouse while trying to take off from TEB (see figure 6). The 

plane, with 11 aboard, skidded across a busy highway during the 

morning rush hour, struck two cars, and then crashed into the 

building. No one was killed, though several persons were injured. 

Although the damage to the building was not substantial, it should 

be noted that the plane was not at full speed when it collided with 

the building. In addition, an aircraft this large could have carried a 

sizable load of explosives. 

Figure 6. Photo of the CL-600 Challenger Crash Site 

(Photo by Mario Tama/Getty Images) 

Source: Jetairpollution.com, February 2005 

In October 2006, a small GA aircraft piloted by New York Yankees 

pitcher Cory Lidle flew from TEB and collided with an apartment 

TSA’s Role in General Aviation Security 

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building in New York City, as shown in figure 7. The crash caused 

a fire on the 40th floor of the building. Lidle and his flight 

instructor were killed, and two dozen people were injured, of whom 

12 were residents of the building and the others were firefighters. 

Figure 7. Photo of Belaire Condominium after being hit by the Lidle 

aircraft 

Source: http://en.wikipedia.org/wiki/2006_New_York_City_plane_crash 

National Capital Region Site Visit 

Privately owned Potomac Airfield is located in a residential 

neighborhood in Fort Washington, Maryland. It has one short 

runway that can accommodate only small aircraft. The airport 

handles 95% local and 5% transient GA. On average, the airport 

has 33 aircraft takeoffs and landings per day. There is a small 

flight school at the airport. 

Potomac Airfield is one of three GA airports in the Washington, 

DC, Metropolitan Area Flight Restricted Zone (FRZ) (figure 8). 

The FRZ is contained within and forms the core of a larger, less 

restricted airspace known as the Special Flight Rules Area (SFRA). 

The Washington FRZ is roughly a 15-mile circle around Ronald 

Reagan Washington National Airport. The current shape and size 

of the Washington SFRA, roughly a 30-mile circle around 

Washington, DC, was redefined in 2007. 

TSA’s Role in General Aviation Security 

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Figure 8. Washington, DC, Metropolitan Area FRZ and SFRA 

Source: http://www.faa.gov/news/updates/adiz_frz/media/070727_New_ADIZ-FRZ.jpg 

Private and commercial aircraft may enter the Washington SFRA 

after complying with FAA notices that require, among other 

things, that the pilot file a flight plan that describes the course, 

destination, and other details of the trip. The flight plan is filed 

with an FAA Flight Service Station, which is an air traffic facility 

that provides information and services to pilots before, during, and 

after flights, but unlike air traffic control, is not responsible for 

giving instructions or clearances or providing separation. The 

information is passed on to FAA air traffic control for subsequent 

observation of the aircraft. 

Flights within the FRZ must follow more restrictive procedures. 

Flight within the FRZ is restricted to governmental, certain 

scheduled commercial, and a limited set of waivered GA flights. 

TSA performs background checks on all pilots flying into the FRZ 

and then issues a personal identification number that authenticates 

the pilot’s identity. Only then is the pilot permitted to fly to an 

airport in the FRZ. AOPA describes this as “a process which is 

both time-consuming and inconvenient for most pilots and 

extremely prohibitive for pilots outside the Washington, DC, metro 

area.” Nonvetted pilots who penetrate the FRZ could face severe 

TSA’s Role in General Aviation Security 

Page 12 
 

penalties, including the loss of their pilot’s certificate.7 These 

requirements have had a considerable effect on the Maryland GA 

airports referred to as the “Maryland Three” or “DC-3”: College 

Park Airport in College Park, Washington Executive/Hyde Field in 

Clinton, and Potomac Airfield in Fort Washington. 

TSA Security Requirements Include General Aviation 

TSA scales its security strategy to the wide range of airfield environments 

and classes of operators and aircraft, rather than introducing overly broad 

regulations that are costly to implement. TSA works closely with the 

many associations of GA owners and operators to implement voluntary 

security measures based on threat analysis and risk management. In 

addition, TSA has introduced voluntary guidelines that are being used 

throughout the GA community, and has developed several programs 

targeted at the most vulnerable GA sectors, such as the Twelve-Five 

Standard Security Program that requires additional security for charter 

aircraft weighing between 12,500 and 103,309 pounds, and the MarylandThree Program to reduce the perceived threats posed by GA airports in the 

vicinity of Washington, DC. TSA has also evaluated the effect of its 

security initiatives on the GA industry and, where applicable, its effect on 

modeling international industry best practices and security measures.8 A 

complete list of TSA’s security requirements is provided in appendix B. 

TSA Is Using a Threat-Based Approach to General Aviation 

Security 

TSA analyzes credible intelligence information to determine and prioritize 

the existing threats. The Office of Intelligence, which has primary 

responsibility for assessing potential terrorist threats, has conducted an 

extensive evaluation of threats that would affect or involve the GA 

industry.9 OI has identified several organizations that have shown an 

interest in using GA to obtain flight training or to launch attacks, and OI 

continues to monitor reports of activity by these organizations. OI also 

assesses how aircraft, ranging from helicopters to large aircraft, might be 

used to launch an attack, including how a terrorist might gain access and 

what damage could be inflicted. In addition to foreign terrorist 

organizations, OI assesses the potential of less traditional threats, such as 

7

 www.AOPA.org, “Air Traffic Services Brief: Washington, DC, Flight Restricted Zone/‘DC-3’ Airports,” 


November 6, 2007. 


8

 www.tsa.gov/what_we_do/tsnm/general_aviation/index.shtm.
 

9

 TSA Office of Intelligence, The Threat to General Aviation: 2007 Modal Assessment.
 

TSA’s Role in General Aviation Security 

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narcotics traffickers and domestic terrorist groups targeting jets of specific 

corporations. 

Although OI has identified potential threats, it has concluded that most 

GA aircraft are too light to inflict significant damage, and has not 

identified specific imminent threats from GA aircraft. OI has also 

concluded that there is no credible threat of crop-dusting aircraft being 

used to spread chemical or biological agents. However, OI noted that 

various intelligence sources have identified helicopters as aircraft of 

ongoing interest to terrorists. OI also stated that the potential for a 

terrorist group to use GA aircraft to conduct an attack remains a possibility 

that cannot be ignored. 

Risk Reduction Steps Have Strengthened General Aviation 

Security 

Based on threat assessments conducted by OI and other federal 

intelligence agencies, as well as the heightened awareness of aviation 

vulnerabilities since September 11, 2001, TSA has identified practical, 

targeted measures to lessen risks in the aviation sector.

10 

TSA requires GA facilities that train pilots to conduct name checks for 

non-U.S. citizens seeking flight training. TSA has the authority to direct 

the FAA to immediately suspend, revoke, or refuse to issue licenses to 

pilots who pose a national security threat. TSA requires screening for GA 

aircraft operators who request access to restricted airspace, such as 

airspace in high-risk urban areas or near key infrastructure. TSA also 

conducts routine inspections of flight school providers, operators of heavy 

aircraft, and private charter operations. 

The Aviation Security Advisory Committee reviewed GA airport security 

and concluded that nonfederal stakeholders have taken extensive voluntary 

measures to limit security vulnerabilities.11 Measures range from pilot 

awareness programs and guidelines for flight schools to assisting airports 

in developing security plans and assisting businesses in identifying 

inappropriate airplane purchase offers. GA operators also may implement 

TSA guidelines that provide owners, operators, sponsors, and other 

entities responsible for oversight of GA airports with a set of federally 

endorsed security enhancements and a method for determining when and 

where these enhancements may be appropriate. Examples include 

10 Aviation Security Advisory Committee Report of the Aviation Security Advisory Committee Working 


Group on General Aviation Airports Security, http://www.tsa.gov/assets/pdf/ASAC_Working_Group_11­

2003.pdf. 


11 Ibid. 


TSA’s Role in General Aviation Security 

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securing aircraft against unauthorized access, verifying identity of all 

passengers, and documenting that all baggage and cargo is known to the 

occupants of the aircraft. TSA has established strong lines of 

communication and working partnerships with industry stakeholders, 

which in turn enable the GA industry to obtain, assess, and provide 

security programs and policies to address security vulnerabilities. Industry 

stakeholders told us that areas for improved communication remain, and 

cited the recent release of Security Directive 8F. Little information about 

the directive is available as a result of the directive’s classification as 

sensitive security information. Because of this classification, information 

about the directive is not available to many of the affected owners, 

operators, or their employees. Another result of the classification of the 

directive is that there was no public comment period for the proposed 

rulemaking. 

Appendix C describes the actions that nonfederal stakeholders have taken. 

TSA Has a Record-Keeping Process for “Incidents of Concern” 

Although security experts throughout the federal government and the GA 

industry have concluded that risks inherent in GA are limited, TSA and 

the industry have introduced numerous targeted security measures to 

reduce the industry’s vulnerabilities. They have also introduced 

procedures for documenting and responding immediately to potential 

security incidents. Specifically, TSA coordinated with AOPA to establish 

the General Aviation Hotline and the Airport Watch Program. 

The hotline, developed in partnership with the National Response Center 

at TSA and in coordination with AOPA, is a centralized reporting system 

for GA pilots, airport operators, and maintenance technicians to report 

suspicious activity at their airfield. The hotline was developed to 

complement the AOPA Airport Watch Program. For each program, 

incidents are reported to TSA’s Transportation Security Operations Center 

(TSOC), where reported incidents are logged into a database. After an 

analyst evaluates the information, TSOC may contact the appropriate 

authorities to alert them to potential danger. 

Our review of incidents reported to TSA indicates that the GA industry is 

using the GA Hotline and Airport Watch Program appropriately, but that 

incidents that might represent a security threat are rare. 

One recent incident that could have had security implications, but did not, 

took place on April 22, 2008. It involved a private charter aircraft with 

one passenger flying to the United States from abroad. The aircraft 

arrived in the United States without having previously filed an 

TSA’s Role in General Aviation Security 

Page 15 
 

International Airspace Waiver with TSA and FAA.12 The aircraft departed 

from Germany, made a refueling stop in Iceland, and continued on to 

Chicago. Federal officials met the flight. The pilot was notified that he 

had not filed an International Airspace Waiver with the FAA. A TSA 

transportation security inspector placed a ground hold on the aircraft until 

the proper paperwork was filed and clearances obtained. TSA told us that 

the incident was detected through the Automated Detection and 

Processing Terminal (ADAPT). 

General Aviation Operations Present a Limited Threat to 

Security; However, Steady Vigilance Must Be Maintained 

The current status of GA operations does not present a serious homeland 

security vulnerability requiring TSA to increase regulatory oversight of 

the industry. According to OI, there is no specific, credible information of 

ongoing plots to use GA in an attack in the near future. Other government 

agencies, including GAO and the Congressional Research Service, have 

examined catastrophic scenarios and have concluded that the GA industry 

does not represent a serious vulnerability (see appendix D). 

In addition, TSA has worked cooperatively with the industry to establish 

guidelines and voluntary measures designed to target the most serious 

vulnerabilities, including screening pilots and restricting access to airspace 

over urban areas and key infrastructure (see appendixes B and C). TSA is 

creating new regulations but has been cautious to balance potential costs— 

and the GA industry’s established history of implementing security 

improvements voluntarily—against the benefits of a regulatory regime. 

For these reasons, we conclude that TSA’s response to threats in the GA 

sector has been appropriate, and we are making no recommendations for 

additional measures in this review. Nonetheless, TSA and the GA 

industry must continue to be vigilant. 

12 TSA and FAA use waiver requests to conduct background checks on crewmembers and passengers on 

flights for which waivers of flight restrictions have been sought from the FAA. In cases such as this one, 

the flight restriction in question pertains to international flights to the United States. 

TSA’s Role in General Aviation Security 

Page 16 
Appendix A 

Purpose, Scope, and Methodology 

At the request of Chairwoman Sheila Jackson Lee, Subcommittee on 

Transportation Security and Infrastructure Protection, House Committee 

on Homeland Security, we reviewed TSA regulations governing GA 

security. Our objectives were to identify (1) current TSA security 

requirements for GA airports; (2) current threats to GA, whether TSA has 

identified those threats, and how those threats leave GA airports 

vulnerable; (3) steps TSA has taken to strengthen GA security and 

challenges TSA faces; (4) steps nonfederal stakeholders have taken to 

enhance GA security and other actions they can take; and (5) any record of 

“incidents of concern” with security at GA airports. 

Our scope was limited to TSA and GA airports. We examined airport 

tenants such as flight schools and FBOs, which provide hangar space, 

maintenance, and fuel to aircraft. We visited a sample of GA facilities of 

varying sizes and in locations near and away from major population 

centers. Our review included airports in California, Texas, Illinois, New 

Jersey, and the National Capital Region. The four sites visited in Texas 

included the three identified in the television reports that prompted the 

chairwoman’s letter. 

We reviewed relevant documentation such as legislation, reports, current 

TSA regulations, published guidelines, policies, and procedures. We 

interviewed TSA and private sector personnel who have a stake in GA 

security. We also gathered information from GA advocates and 

stakeholders affiliated with the Aviation Security Advisory Committee 

working group, which developed guidelines for security enhancements at 

GA facilities. We relied on sources of evidence from state and local law 

enforcement officials. 

We assessed the effectiveness of TSA’s current GA security requirements 

at the sites we visited. During these visits, we examined airport security 

policies, procedures, and practices. Finally, to respond to Chairwoman 

Jackson Lee’s inquiry regarding “incidents of concern,” we examined 

TSA’s record of reported incidents and records from airport owners or 

managers. After conducting our review and establishing that TSA and the 

industry are making a concerted effort to collaborate and ensure that the 

industry is secure, we have determined that we have no recommendations 

for TSA. 

Our fieldwork was performed between April 2008 and September 2008. 

This review was conducted under the authority of the Inspector General 

Act of 1978, as amended, and according to the Quality Standards for 

Inspections issued by the President’s Council on Integrity and Efficiency. 

TSA’s Role in General Aviation Security 

Page 17 
Appendix B 

Current TSA GA Security Requirements 

The following requirements have been established by TSA as noted by the 

Transportation Sector Network Management, Office of General Aviation, 

and as reported by AOPA.13 Although the scope of the review did not 

require that we evaluate each TSA GA security requirement, we believe 

that current TSA GA requirements represent a good strategic approach. 

Airspace Waivers 

According to TSA records, the Office of Airspace Waivers manages the 

process and assists with the review of GA aircraft operators who ask to 

enter restricted airspace. Each waiver applicant is required to provide his 

or her last and first names, Social Security number, and date and place of 

birth. This information allows the Office of Airspace Waivers to vet the 

applicants for subsequent approval or denial to fly into restricted airspace. 

Applications must be filed for aircraft operating into, out of, within, and 

flying over the United States. The process also includes an evaluation of 

the aircraft, crew, passengers, and purpose of the flight. The application is 

then adjudicated and recommended for approval or denial to the FAA, 

Office of Air Traffic Services. The FAA shares the responsibility for 

managing the waivers with TSA. The FAA asserts the safety provisions, 

while TSA manages the security portion of the process. Airspace waivers 

help to mitigate the threat of an airborne attack. 

Flight School Security Regulations 

The Interim Final Rule at 49 CFR 1522.23(d), Flight Training for Aliens 

and Other Designated Individuals: Security Awareness Training for Flight 

School Employees, requires flight schools to ensure that all of their flight, 

ground, and chief instructors, as well as administrative personnel who 

have direct contact with students, receive both initial and recurrent 

security awareness training. Flight schools may choose to use the TSA 

security awareness program or develop their own. If a flight school 

chooses to develop its own program, the program must adhere to the 

standards in the rule. 

Current Security Programs 

Secure Fixed Base Operator Program 

The TSA Secure Fixed Base Operator Program was launched on 

December 31, 2007, with industry partner Signature Flight Support, at 

Anchorage, Alaska, and Shannon, Ireland. This public-private partnership 

13 AOPA, General Aviation Security Initiatives Since 9-11-2001, March 5, 2008. 

TSA’s Role in General Aviation Security 

Page 18 
Appendix B 

Current TSA GA Security Requirements 

program allows FBOs to check passenger and crew identification against 

manifests or, as of May 18, 2009, the Electronic Advance Passenger 

Information System. The latter is a U.S. Customs and Border Protection 

web-based application that collects electronic traveler manifest 

information from commercial carriers for international flights arriving in 

or departing from the United States. The system then passes manifests to 

Customs and Border Protection through the Advance Passenger 

Information System. According to a TSA official, “working in close 

coordination with industry partners, TSA believes that this security 

initiative will provide additional security for flights inbound to the United 

States. The broader application of such programs will provide robust 

security while maintaining operational flexibility for general aviation 

operators.” 

Twelve-Five Standard Security Program 

The Twelve-Five Standard Security Program (TFSSP) requires that certain 

aircraft operators using aircraft with a maximum takeoff weight of 12,500 

pounds or more execute a security program. Operators were required to 

be in compliance with the program effective April 1, 2003. 

Private Charter Standard Security Program 

The Private Charter Standard Security Program (PCSSP) requires 

operators to execute a security program, but adds additional requirements 

for aircraft operators who use aircraft with a maximum takeoff weight of 

more than 100,309 pounds or with a seating configuration for 61 or more 

passengers. Operators were required to be in compliance with the 

program effective April 1, 2003. 

This program subjects operators of large charter aircraft to the same 

processes that are associated with commercial passenger aviation, 

including passenger screening through metal detection devices, x ray 

systems for carry-on and checked luggage, and a certified passenger and 

baggage screening workforce.14 

Large Aircraft Security Program 

TSA has issued a Notice of Proposed Rulemaking that seeks to amend the 

TFSSP and PCSSP and apply new security requirements to all aircraft 

weighing more than 12,500 pounds. In addition, TSA proposes that 

airports serving large aircraft should adopt mandatory security 

requirements. Among the requirements in the proposal, the major 

14 http://www.nbaa.org/ops/security/programs/pcssp/ (URL as of January 14, 2009). 

TSA’s Role in General Aviation Security 

Page 19 
Appendix B 

Current TSA GA Security Requirements 

provisions for aircraft operators include criminal history record checks and 

security threat assessments for flight crew, checking passenger names 

against the TSA’s No-Fly and Selectee lists, developing a security 

program, and biennial auditing of the security program. Additionally, the 

proposal would require approximately 320 airports designated by the 

Department of Transportation as “reliever” airports, and airports that 

regularly serve scheduled or public charter operations in large aircraft, to 

adopt a “partial” airport security program that would include specific 

training, record retention, personnel, and notification requirements. 

The GA industry asked TSA to extend the period for public comment on the 

agency’s Large Aircraft Security Program (LASP) proposal by 60 days. As 

a result of the extension, the new deadline for public comment was 

February 27, 2009. LASP would require U.S. operators of aircraft 

exceeding 12,500 pounds takeoff weight to implement a security program 

much like that for charter operators of large aircraft, described above in the 

section on the PCSSP. The proposed LASP rule would add requirements 

for large aircraft operators and some airports receiving those aircraft. In 

addition, large aircraft operators would be required to submit to compliance 

audits of their security programs using TSA-approved auditors and to verify 

that their passengers are not on the No Fly or Selectee portions of the 

consolidated terrorist watch list maintained by the federal government 

through the use of a TSA-approved watch list provider.15 

Many GA organizations vigorously oppose LASP. Melding the TFSSP 

into the much more elaborate PCSSP would push existing security efforts 

for the largest charter flights down to many smaller aircraft involved in 

corporate and private aviation 

Rules for the Aviation Community 

Washington Reagan National Airport Access Standard Security Program 

TSA Interim Final Rule, 49 CFR (Parts 1520, 1540, and 1562), developed 

in coordination with other DHS agencies and the Department of Defense, 

takes into consideration the special security needs of Washington Reagan 

National Airport (DCA). Under the TSA security plan, 48 GA flights per 

day are allowed in and out of Washington Reagan National Airport. All 

GA aircraft are required to meet the security measures set forth in the 

Washington Reagan National Airport Access Standard Security Program. 

To meet security measures, TSA is to conduct a series of steps, which 

include an inspection of crew, passengers, accessible and checked 

property, and the aircraft. Passenger and crew manifests are to be 

15 Transportation Sector Network Management, Office of General Aviation, March 2008. 

TSA’s Role in General Aviation Security 

Page 20 
Appendix B 

Current TSA GA Security Requirements 

submitted 24 hours in advance of each flight. TSA is to execute enhanced 

background checks for all passengers and fingerprint-based criminal 

history records check for flight crew. There is to be an armed security 

officer on board each flight. All Washington Reagan National Airport 

Access Standard Security Program flights must depart from an approved 

gateway airport (an airport authorized by TSA to “send” GA flights to 

DCA). According to TSA, there are 21 approved gateway airports. 

Maryland-Three Program 

The Maryland-Three Program allows properly vetted private pilots to fly 

to, from, or between the three GA airports within the National Capital 

Region. These airports are College Park Airport, Potomac Airfield, and 

Hyde Executive Field, and all are located within the Washington, DC 

Metropolitan FRZ. 

GA Community Several Security Advisories 

According to TSA officials, TSA has provided the GA community 

advisories to execute security requirements. TSA encourages GA aircraft 

and airport owners and operators to consider securing unattended aircraft 

to prevent unauthorized use and verify the identification of crew and 

passengers prior to departure. TSA also advises the GA community to 

verify that baggage and cargo are known to the persons on board. Where 

identification systems exist, TSA requests the GA community to 

encourage employees to wear proper identification and challenge persons 

not wearing proper identification. At one GA facility in Chicago, airport 

security officials punish employees who do not properly display their 

airport identification. The penalties range from a verbal warning to 

dismissal. It is also stressed that they be aware of and report persons 

whose identification appears altered or inconsistent. 

TSA stresses to the GA community that it must direct increased vigilance 

to unknown pilots or clients for aircraft or helicopter rental or charters, as 

well as to unknown service and delivery personnel. TSA emphasizes that 

the GA community must be aware of and report the following: individuals 

impersonating pilots, security personnel, emergency medical technicians, 

or other uniformed airport personnel using vehicles to gain access to 

aviation facilities or aircraft; aircraft with unusual or unauthorized 

modifications; persons loitering in the vicinity of aircraft or air operations 

areas, persons loading unusual or unauthorized payload onto aircraft, or 

persons who exhibit odd behavior. 

TSA’s Role in General Aviation Security 

Page 21 
Appendix B 

Current TSA GA Security Requirements 

Security Initiatives 

General Aviation Hotline and Airport Watch 

TSA has developed and implemented a GA Hotline, 866-GA-SECURE 

(1-866-427-3287), in partnership with the National Response Center. The 

hotline serves as a centralized reporting system for GA pilots, airport 

operators, and maintenance technicians to report suspicious activity at 

their airfield. 

Figure 9. Aircraft Owners and Operators Association Airport Watch 

Source: Airport Watch Brochure, www.aopa.org/airportwatch/brochure.pdf, 1995–2008, 

Aircraft Owners and Pilots Association. 

The hotline was developed in coordination with AOPA to complement the 

AOPA Airport Watch program “Lock Up, Look Out” (Figure 9). 

According to an AOPA official, this program enlists the support of 

approximately 550,000 GA pilots to watch for and report suspicious 

activities that might have security implications. According to an AOPA 

official, AOPA has distributed Airport Watch materials to 5,400 publicuse GA airports, several pilot groups, and thousands of individual pilots. 

The program provides special materials, including a video to train pilots to 

be alert for suspicious people or activities on the airport. 

Airport Security Guidelines 

In April 2003, TSA requested that the Aviation Security Advisory 

Committee Working Group establish a working group consisting of GA 

TSA’s Role in General Aviation Security 

Page 22 
Appendix B 

Current TSA GA Security Requirements 

industry associations, airport operators, and state and federal government 

representatives to develop guidelines for security enhancements at GA 

airports nationwide. This list of recommended guidelines or best practices 

was designed to establish nonregulatory standards for GA airport security. 

Their primary purpose is to help prevent the unauthorized use of a GA 

aircraft in an act of terrorism against the United States. 

Members of the working group reviewed numerous GA airport security 

recommendations and industry best practices. The result of this effort was 

the Report of the Aviation Security Advisory Committee Working Group 

on Aviation Airports Security, available at 

http://www.tsa.gov/assets/pdf/ASAC_Working_Group_11-2003.pdf. 

On November 17, 2003, the Aviation Security Advisory Committee 

formally transmitted the report’s recommendations to TSA. TSA used this 

report as a baseline from which to create the “Security Guidelines for 

General Aviation Airports.” These federally endorsed guidelines are used 

to enhance security at GA facilities throughout the Nation by addressing 

aviation security concepts, technology, and enhancements. 

TSA Access Certification 

TSA launched a pilot project in cooperation with the National Business 

Aviation Association at Teterboro Airport and Morristown Municipal 

Airport in New Jersey and White Plains Airport in New York. The 

initiative was to provide a “proof of concept” to validate a National 

Business Aviation Association-proposed security protocol, which led to 

the TSA Access Certification and a corporate waiver for certain types of 

operations, such as international flights to and from the United States. 

Phase I of the pilot program was completed on June 30, 2003. Phase II 

was completed on December 31, 2003. 

Recommended Security Action Items for Fixed Base Operators 

These Security Action Items were created for FBOs. Most of these 

measures complement the guidance in the May 2004 Security Guidelines 

for General Aviation Airports. TSA has confirmed the value of these 

measures during discussions, outreach sessions, and security reviews with 

partners representing FBOs. The security action items are presented in six 

categories: (1) general security measures, (2) FBO security coordinator, 

(3) FBO training outline, (4) aircraft security, (5) transient pilots, and (6) 

reporting suspicious activity. 

TSA’s Role in General Aviation Security 

Page 23 
Appendix C 

Actions Nonfederal Stakeholders Have Taken 

The following actions taken by nonfederal stakeholders are summarized 

from the Aviation Security Advisory Committee Working Group 2003 

report:16 

Aircraft Owners and Pilots Association 

AOPA developed a nationwide aviation watch system, the Airport Watch 

Program, which allows the Nation’s 550,000 pilots to use a TSAsupported centralized toll-free hotline to report and act on information 

provided by GA pilots and other individuals at airports. The Airport 

Watch Program includes warning signs for airports, informational 

literature, and a training videotape to educate pilots and airport employees 

about ways to enhance the security of their airports and aircraft. 

Airports and Airport Tenants 

Many airports and individual airport tenants have already implemented 

security enhancements in addition to the aforementioned Airport Watch 

Program. Such initiatives include installing alarm systems; controlling 

access; and monitoring and improving gates, fencing, and lighting. Some 

airports are also experimenting with new technologies in security 

monitoring, surveillance, and access control, including Wi-Fi—wireless 

fidelity communications—and sophisticated target acquisition software 

programs. 

American Association of Airport Executives 

The American Association of Airport Executives, General Aviation 

Airport Security Task Force, delivered a set of eight recommendations to 

TSA in June 2002. The recommendations were developed by establishing 

categories of airports based on runway length and number of based 

aircraft. Recommendations included establishing a threat communication 

system, developing a new pilot license, securing aircraft, and expanding 

the FAA contract tower program. 

Experimental Aircraft Association 

The Experimental Aircraft Association mobilized its network of nearly 

1,000 chapters nationwide to improve security at many of the Nation’s 

airports through increased knowledge and vigilance. Airport Watch 

distributed videotapes and other educational materials concerning security 

practices and airspace restrictions nationwide. In addition, updated Notices 

to Airmen are provided near-real-time to pilots via the association’s website 

16 http://www.tsa.gov/assets/pdf/ASAC_Working_Group_11-2003.pdf. 

TSA’s Role in General Aviation Security 

Page 24 
Appendix C 

Actions Nonfederal Stakeholders Have Taken 

and direct e-mail, to warn of security-sensitive areas and airport closures. 

The Experimental Aircraft Association has led the development of new 

sport pilot and light sport aircraft regulations, which will help to improve 

security by registering with the FAA an estimated 10,000 to 15,000 

previously unregistered ultralight training aircraft and certifying a similar 

number of ultralight pilots and instructors who heretofore had not been part 

of the FAA certification process. 

General Aviation Coalition (no longer active) 

In December 2001, the General Aviation Coalition issued a series of 12 

recommendations for GA security. The government and the GA 

community have implemented many of them. 

General Aviation Manufacturers Association 

The General Aviation Manufacturers Association, in conjunction with the 

U.S. Department of the Treasury, is working to help aircraft sellers 

identify unusual financial transactions that could indicate attempts to 

launder money via the purchase of aircraft, or otherwise suspicious 

customer behavior. The publication titled “Guidelines for Establishing 

Anti-Money Laundering Procedures and Practices Related to the Purchase 

of General Aviation Aircraft” was developed in consultation with 

manufacturers, aviation finance companies, used aircraft brokers, and 

fractional ownership companies. 

Helicopter Association International 

The Helicopter Association International (HAI) significantly enhanced its 

efforts to keep members informed of developing security issues. HAI 

made changes to its website by including a separate, clearly marked 

“Security Issues” link on its homepage, links to the FAA’s Notices to 

Airmen website, other pages that have graphical depictions of Temporary 

Flight Restrictions, and links to various federal agency organizational 

charts and new, pertinent rules and regulations. HAI has coordinated a 

number of issues with security officials, including alternate means of 

compliance with the Twelve-Five Rule for firefighting and offshore 

operations, discrete transponder codes for electronic news-gathering 

helicopters that allow certain operations within the FRZ and waivers for 

flying over sporting events, utility patrol requirements, and heliport 

security.17 Additionally, HAI is developing a Call-When-Needed program 

to provide a nationwide resource of prevetted pilots and prescreened 

17 Transponders produce a response when they receive a radio-frequency interrogation. In aviation, aircraft 

have transponders to assist in identifying them on radar and on other aircrafts’ collision avoidance systems. 

TSA’s Role in General Aviation Security 

Page 25 
Appendix C 

Actions Nonfederal Stakeholders Have Taken 

aircraft with a broad range of capabilities that can respond to natural 

disasters or security-related events. 

National Agricultural Aircraft Association 

The National Agricultural Aircraft Association has produced an 

educational program called the Professional Aerial Applicators Support 

System that includes a new educational portion every year, specifically 

addressing security of aerial application or crop-dusting operations. The 

Professional Aerial Applicators Support System program annually reaches 

roughly 2,000 people. It is presented at state and regional agricultural 

aviation association meetings throughout the country. In addition, 

National Agricultural Aircraft Association members have undergone 

several industry-wide Federal Bureau of Investigations background 

investigations since September 11, 2001. 

National Air Transportation Association 

On September 24, 2001, the National Air Transportation Association 

issued a series of recommended security procedures for all aviation 

businesses through its Business Aviation Security Task Force. The 

recommendations focused on immediate steps that should be taken, as 

well as longer term actions. Examples included improving signage, 

appointing a single manager responsible for security at each location, 

developing a security mission statement, verifying identification, and 

seeking local law enforcement assistance to develop security plans. In 

addition, an advisory poster was created and distributed free to all 

National Air Transportation Association members. 

National Association of Flight Instructors 

The National Association of Flight Instructors, an affiliate of the 

Experimental Aircraft Association, has developed a series of security 

recommendations and best practices for flight schools and flight instructors 

that have been distributed widely throughout the flight training community. 

Currently, the National Association of Flight Instructors is working in 

cooperation with TSA to develop training materials and distribution 

methods to support flight school security awareness training. 

National Association of State Aviation Officials 

In December 2002, the National Association of State Aviation Officials 

submitted to federal and state authorities a document outlining GA 

security recommendations, which included securing unattended aircraft, 

developing a security plan, and establishing a means to report suspicious 

TSA’s Role in General Aviation Security 

Page 26 
Appendix C 

Actions Nonfederal Stakeholders Have Taken 

activity. In addition, it recommends that airports establish a public 

awareness campaign, perform regular inspection of airport property, and 

control movement of persons and vehicles in the aircraft operating area. 

The state aviation officials suggested that federal authorities implement a 

new pilot ID, establish a government watch list to verify the identity of 

persons requesting flight lessons, implement a process for categorizing 

airports, and ensure adequate federal funding for airport security. 

National Business Aviation Association 

TSA launched a pilot project in cooperation with the National Business 

Aviation Association at Teterboro Airport in New Jersey. TSA has 

expanded the project to include Part 91 operators—operations involving 

small noncommercial aircraft—based at Morristown, New Jersey, and 

White Plains, New York. This initiative is proceeding as a proof of 

concept validating a National Business Aviation Association proposed 

security protocol for Part 91 operators who can apply for a TSA Access 

Certificate. The TSA Access Certificate allows operators to operate 

internationally without the need for a waiver. TSA is also considering 

granting access for TSA Access Certificate holders to designate temporary 

flight restrictions. 

United States Parachute Association 

The United States Parachute Association disseminated detailed security 

recommendations to its 219 skydiving clubs and centers across the United 

States, most of them based on GA airports. Skydive operators and their 

customers are often in airports during days and hours when others are not, 

and can enhance any airport watch program. Other recommendations 

were aimed at ensuring security of jump aircraft during operations as well 

as when aircraft are idle. 

TSA’s Role in General Aviation Security 

Page 27 
Appendix D 

General Aviation Intelligence Assessments 

The following GA intelligence assessments have examined the magnitude 

of destruction that terrorists could accomplish. 

Government Accountability Office 

In September 2004, a GAO report stated that “nuclear power facilities are 

among the most hardened industrial facilities in the United States. They 

are massive structures with thick exterior walls and interior barriers of 

reinforced concrete designed to withstand tornadoes (and projectiles 

propelled by tornadoes), hurricanes, fires, floods, and earthquakes.” 

While most facilities were not designed around the notion that terrorists 

might deliberately crash an aircraft into them, most were designed to 

withstand an accident involving an aircraft. 

Aircraft Owners and Pilots Association 

An AOPA-commissioned report revealed that a GA aircraft could not 

penetrate the concrete containment vessel of a nuclear power plant. Nor 

would an explosives-laden GA aircraft likely cause the release of 

radiation. A small aircraft attack on any auxiliary plant buildings would 

not cause a safety failure, and a GA aircraft could not ignite the zirconium 

cladding on spent nuclear fuel. In short, GA aircraft are not a threat to 

nuclear power plants. 

Congressional Research Service 

In its December 2005 report and most recently updated January 2008 report 

on Securing General Aviation, the Congressional Research Service stated 

that “the limited capabilities of the typical GA aircraft to carry conventional 

explosives, noting that even the 1,300-pound device involved in the 

February 1993 World Trade Center bombing would be beyond the carrying 

capability of a light GA aircraft. Thus, at least with regard to being used as 

a platform for conventional explosives, the threat posed by light GA aircraft 

is relatively small compared to trucks which have significantly larger 

payload capacities.... Executing an attack that involves loading a GA 

aircraft with a large quantity of explosives may be difficult without raising 

some suspicion at the airport, at least domestically where airport operators 

and pilots have been instructed to be vigilant for unusual activities.” 

According to the Congressional Research Service, “Improving upon GA 

security without unduly impeding air commerce or limiting the freedom of 

movement by air remains a significant challenge. However, policymakers 

have received mixed signals about the relative security risk posed by GA 

TSA’s Role in General Aviation Security 

Page 28 
Appendix D 

General Aviation Intelligence Assessments 

due to its diversity and a general lack of detailed information regarding the 

threat and vulnerability of various GA operations.”18 

18 Congressional Research Service, Securing General Aviation, January 2008. 

TSA’s Role in General Aviation Security 

Page 29 
Appendix E 

Major Contributors to this Report 

Douglas Ellice, Chief Inspector, Department of Homeland 

Security, Office of Inspections 

Peggy Mayfield, Team Leader, Department of Homeland Security, 

Office of Inspections 

Levar Cole, Inspector, Department of Homeland Security, Office 

of Inspections 

TSA’s Role in General Aviation Security 

Page 30 
Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

DHS OIG Audit Liaison 

TSA Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

TSA’s Role in General Aviation Security
 

Page 31
 
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