Aviation Security: FAA Can Help Ensure That Airports' Access Control Systems Are Cost-Effective
Released: 1995-03-14T00:00:00

Letter

Background

To help provide a safe operating environment for airlines, the Code of Federal Regulations (C.F.R.) title 14, part 107 requires that U.S. airports control access to secured areas. Such controls are intended to ensure that only authorized persons have access to aircraft, the airfield, and certain airport facilities. Other security measures include requiring that airport and airline employees display identification badges and that airlines screen persons and carry-on baggage for weapons and explosives.

In January 1989, FAA made 14 C.F.R. part 107 more stringent by mandating that access controls to the secured areas of certain airports meet four broad requirements. Under the amendment—14 C.F.R. 107.14—access control systems must (1) ensure that only authorized persons gain access to secured areas, (2) immediately deny access to persons whose authorization is revoked, (3) differentiate between persons with unlimited access to the secured area and persons with only partial access, and (4) be capable of limiting access by time and date. According to FAA, these requirements are intended to prevent individuals, such as former airline employees, from using forged, stolen, or noncurrent identification or their familiarity with airport procedures to gain unauthorized access to secured areas.

All U.S. airports where airlines provide scheduled passenger service using aircraft with more than 60 seats must meet the requirements of 14 C.F.R. 107.14. Beginning in August 1989, each of these airports had to develop an access control system plan for FAA field security officials to review and approve. Following approval, FAA gives airports up to 2-1/2 years to comply with the regulation, depending on the number of persons screened annually or as designated by FAA on the basis of its security assessment. FAA expects airports to maintain and modernize their systems to keep them in regulatory compliance. As of August 1994, 258 airports were subject to FAA’s access control requirements. Appendix I lists these airports.

Access control systems are eligible for AIP funds. FAA administers the AIP and provides funds for airport planning and development projects, including those enhancing capacity, safety, and security. FAA’s AIP Handbook (Order 5100.38A) provides policies, procedures, and guidance for making project funding decisions. According to the handbook’s section on safety, security, and support equipment (section 7), only those system components and facilities necessary to meet the requirements of 14 C.F.R. 107.14 are eligible for AIP funds. The airports themselves must fund any additional equipment or software capability that exceeds these requirements. FAA airport programming officials approve AIP funding requests.

Costs for Access Control Systems Greatly Exceed FAA’s Initial Estimate

Airports have installed various systems—mostly computer-controlled—to meet FAA’s four access control requirements. With FAA’s approval, airports have taken the following approaches:

Airports have placed the equipment for their access control systems in different locations. For example, some airports screen persons at checkpoints, while other airports have installed controls on doors beyond such checkpoints. Also, some airports have installed controls on both sides of doors leading into and out of secured areas.

Airports have installed different types of equipment. For example, to secure doors and gates, several airports use magnetic stripe card readers while others use proximity card readers. One airport installed a reader that scans an individual’s hand to determine the person’s identity. Also, we visited one airport that has an “electronic fence” to segregate the commercial and general aviation operations areas; another has a guard gate and magnetic stripe card reader to separate passenger and cargo operations areas. Additionally, some airports have mounted closed-circuit television cameras at doors and gates, while other airports have chosen not to install such technology.

According to FAA’s data, most of the 258 regulated airports have now completed installing their systems, but they will need to modernize these systems in the future. Modernization is necessary when equipment wears out, additional equipment is needed, or equipment or software no longer has the capacity to meet security-related demands. For example, in September 1994, FAA provided one airport that had an approved system with over $3 million in AIP funding to purchase closed-circuit television cameras, help construct a communications center, and make other system modifications to meet additional security needs.

The costs for access control systems are over three times greater than FAA expected. FAA initially estimated that the costs to install, operate, maintain, and modernize systems at all regulated airports would total $211 millionfrom 1989 through 1998. However, updated data provided by FAA show that actual and projected costs for the same period totaled about $654 million. This amount includes $327 million in AIP funds, or 50 percent of total costs over the 10-year period. As of August 1994, 177 (69 percent) of the 258 regulated airports received AIP funding to help pay for their access control systems. Furthermore, on the basis of the updated information, FAA projects that costs for systems in 1999 through 2003 will total an additional $219 million, half of which would be federally funded. Appendix II shows actual and projected access control costs in 1989 through 2003, including AIP funding.

According to FAA officials, FAA’s initial cost projection was low primarily because more access points were secured and more sophisticated and expensive equipment was installed than the agency’s analysis considered. For example, FAA’s analysis assumed that the largest airports would secure 128 access points on average. However, we found that these airports had initially secured about 390 points on average. Appendix III compares FAA’s initial cost figures with the agency’s updated actual and projected costs of access control systems.

FAA Could Help Ensure That Systems Are Modernized in a Cost-Effective Manner

Over the next several years, many access control systems will need to be modernized. FAA can help ensure that modernization is implemented in a cost-effective manner by providing detailed guidance and facilitating the development of standards explaining how to meet the requirements of 14 C.F.R. 107.14. Without detailed guidance, many airports initially spent funds to secure access points that FAA later determined did not need to be secured to meet the agency’s requirements. Also, without standards to guide the design of systems, some airports purchased systems that did not meet FAA’s requirements. Additionally, without guidance and standards to serve as criteria, it was difficult for FAA to ensure that AIP funds were used only for the system components needed to meet the agency’s access control requirements as directed by its AIP funding policy. FAA and the industry have several initiatives under way that could address these deficiencies and help ensure that systems are cost-effective.

FAA Has Not Developed Detailed Guidance and Standards Explaining How Airports Could Best Meet Access Control Requirements

FAA has not developed detailed guidance and standards to explain how systems could meet its four access control requirements in a cost-effective manner. Detailed guidance could help airports determine where equipment should be located. Standards could explain what functions equipment and software should perform and how quickly and reliably these functions should be done. For example, one of FAA’s four access control requirements is that systems grant secured-area access only to authorized persons. Detailed guidance for computer-controlled access control systems could include the following:

Additional equipment beyond a card reader, such as lights that flash when the door is not secured, should be used only if the access point is in a low-traffic area.

Closed-circuit television cameras should be used only at access points where an analysis shows that it is less expensive to have the camera than to have security personnel respond to an alarm.

Standards for computer-controlled access control systems could include the period of time that a secured door or gate can remain open before security personnel are notified, the period of time that can elapse before a terminated employee’s access code is invalidated, the percentage of time that the system is expected to be operable, and the frequency at which the system can misread a card.

Although developing guidance and standards for access control systems is a complex undertaking, FAA has provided airports and airlines with guidance and standards explaining how to meet other agency requirements that are similarly complex. For example, FAA has planning and design guidance explaining how terminals can be configured to accommodate the expected flow of passengers. The guidance recognizes that each airport has its own combination of individual characteristics that must be considered. FAA’s standards for equipment include those to design, construct, and test lift devices for mobility-impaired airline passengers and vehicles for aircraft rescue and fire fighting. Such standards do not specify what equipment airports should use, but rather how a vendor’s equipment should perform to meet FAA’s requirements. For software, FAA has developed standards for the software used in the Traffic Alert and Collision Avoidance System that it requires on most commercial passenger aircraft.

FAA requires that airports use its guidance and standards in order to receive AIP funds. In some cases, FAA certifies that equipment and software from certain manufacturers meet its standards, as it has done for the equipment used to screen persons and the Traffic Alert and Collision Avoidance System. However, similar standards and certifications do not exist for access control systems.

When FAA issued 14 C.F.R. 107.14 in January 1989, the agency did not conduct tests that could have provided the necessary knowledge to establish detailed guidance and standards for computer-controlled systems. Although airports and airlines suggested that FAA conduct tests at selected airports, the agency determined that nationwide implementation of the new requirements should proceed immediately. According to FAA officials, the Office of the Secretary of Transportation attached a very high priority to implementing improved airport access controls. As a result, FAA decided not to delay implementing the new access control requirements by testing and evaluating systems.

Without Detailed Guidance and Standards, FAA Cannot Ensure That Systems Are Cost-Effective

According to security experts and airport and airline representatives,detailed guidance and standards would help airports know which systems satisfy FAA’s access control requirements in a cost-effective manner. Without detailed guidance and standards, it is difficult to determine if the many different systems installed at a wide range of costs are cost-effective. A November 1993 survey by the Airports Council International-North America of 63 airports (24 percent of all regulated airports) found that virtually no two have systems using the same equipment and software.Also, a November 1993 survey by the Airport Consultants Council of 14 airports found that the installation cost per secured access control point ranged from $6,250 to almost $55,000; the average cost was over $30,000.

Without detailed guidance, many airports installed access controls that FAA had approved but later had determined were not needed to meet its requirements. In April 1992, citing concerns about escalating costs, FAA clarified how airports could configure systems. FAA allowed airports that had installed systems to reduce the number of controlled access points if the reduction did not compromise security. According to FAA data, over 120 airports have reduced their number of controlled access points. For example, one airport reduced its total number of controlled access points by 26 percent (106 points) while still meeting FAA’s requirements. Another airport now meets FAA’s requirements with screening checkpoints at concourse entrances, although its initial system included both the checkpoints and card readers installed on both sides of 114 doors located beyond the checkpoints. FAA’s Director of Civil Aviation Security Policy and Planning acknowledges that the agency must take a more proactive approach to ensure that airports meet access control requirements in a cost-effective manner by reducing the number of controlled access points where feasible without decreasing security.

Similarly, without standards on which to base system design, airports have incurred higher costs for systems that are based on proprietary software and a “closed architecture.” Many airports contracted with firms to install, maintain, and modify their systems using proprietary software and a closed architecture. In such cases, only the vendor providing the system is familiar enough with the system to effectively maintain or make changes to it. According to security experts, the use of proprietary software and a closed architecture can increase a system’s lifecycle costs by as much as 100 percent, primarily because of higher maintenance and modification costs. These experts told us that appropriate standards could have provided for an access control system design based on an open architecture. An open architecture would have allowed different vendors to compete for system maintenance, thus decreasing costs. Also, according to security experts, standards would have reduced total system costs by allowing for economies of scale and easier incorporation of new technologies.

Furthermore, without standards on which to base system design, some airports purchased systems that did not meet FAA’s requirements. When FAA issued 14 C.F.R. 107.14, airports looked to firms that had developed and installed access control systems at locations such as military facilities, prisons, hospitals, office buildings, and homes. According to security experts, in many cases it was difficult to transfer the security technology and operational knowledge used for such systems to the airport environment. The November 1993 survey by the Airport Consultants Council found that 21 major airports incurred costs to replace or significantly modify systems that did not operate adequately to meet FAA’s requirements. For example, one such airport had to replace its inadequate system, including card readers, at a cost of over $1.5 million. According to security experts, well-defined standards could have guided vendors in developing systems and provided airports with greater assurance that the systems would meet FAA’s access control requirements. Also, standards could have provided a basis for FAA to certify a vendor’s system.

Finally, detailed guidance and standards could have provided criteria for FAA to use in evaluating airports’ AIP funding requests for access control systems. Generally, FAA airport programming officials worked with FAA security officials to determine if AIP funding would be used only for the system components needed to meet FAA’s requirements as directed by the agency’s AIP Handbook. However, they both lacked well-defined criteria against which proposed access control systems could be compared and evaluated. This problem continues as airports request AIP funds to help modernize their systems. For example, one airport with an approved system requested $1.2 million in AIP funds to secure additional doors. An FAA regional Special Agent for security told us that the lack of criteria has caused her to be unsure how to determine if this funding request should be approved.

FAA and Industry Are Considering Changes in Their Approach to Access Control

In January 1994, FAA requested that the public identify up to three regulations that should be amended or eliminated to reduce undue regulatory burdens. Both airports and airlines identified 14 C.F.R. 107.14 as one of the most costly and burdensome regulations imposed on them and stated that FAA should reassess how to control access in a more cost-effective manner without decreasing security. FAA’s December 1994 response cites ongoing efforts to revise its security regulations and work with the industry to set standards for access control systems.

FAA and the industry have three initiatives under way for considering changes to access control that could help ensure that systems are cost-effective. First, FAA is working with the industry to revise airport and airline regulations, including 14 C.F.R. 107.14. Specifically, FAA is reviewing its four access control requirements to determine how they help meet security needs as part of an overall security strategy. FAA plans to issue a Notice of Proposed Rulemaking on any revisions to its security regulations by mid-1995.

Second, through the Aviation Security Advisory Committee, FAA is working with the industry to consider the feasibility of implementing a system that would allow transient employees, such as pilots and flight attendants, to use a single card to gain access at all major airports—a universal access system. Research on and testing of a universal access system is one method to help develop standards for access control technology. The Congress has directed that $2 million of FAA’s fiscal year 1994 appropriation be used for the initial costs to develop and implement a universal access system. FAA and the industry are now working to evaluate how such a system could best be implemented. Tests involving three major airlines and two high-security airports are scheduled to begin in March 1995.

Third, FAA is facilitating an ongoing effort with the industry to develop standards for systems that would comply with the requirements of 14 C.F.R. 107.14 and meet the needs of all regulated airports. As of December 1994, this effort includes developing standards for how equipment and software should function to meet requirements. FAA and the industry also plan to (1) incorporate knowledge gained from testing the universal access system, (2) identify near-term approaches to make systems easier to maintain and equipment and software easier to modify, and (3) promote modernizing existing systems to the new standards. This effort is scheduled to be completed by October 1995.

Conclusions

Airport and airline security is of paramount importance. To this end, FAA and the industry plan to spend millions of dollars to modernize access control systems as part of an overall security strategy. At this time, however, FAA cannot ensure that these modernization efforts will result in the best use of limited federal and industry funds.

FAA and the industry have initiatives under way that provide a basis for helping to ensure that access control systems are cost-effective. Specifically, following 5 years of experience with installing and using systems, both FAA and the industry are in a good position to complete their current effort to review overall aviation security needs as they relate to access control requirements and to change the requirements if necessary. As a next step, FAA and the industry can complete their ongoing work to develop and implement standards explaining how equipment and software should function to meet access control requirements.

In addition to ongoing initiatives, FAA can help ensure that systems are cost-effective by developing and implementing detailed guidelines explaining where system equipment should be placed. FAA officials can use the detailed guidance and standards as criteria to evaluate AIP funding requests and help ensure that these funds are used only for the system components needed to meet access control requirements.

Recommendations

To help ensure that systems are cost-effective, we recommend that the Secretary of Transportation direct the Administrator, FAA, to develop and implement detailed guidance based on the agency’s access control requirements that explains where system equipment should be located.

FAA should incorporate these guidelines and the standards being developed into its review process for Airport Improvement Program funding requests.

Agency Comments

We discussed our findings and recommendations with FAA’s Assistant Administrator for Civil Aviation Security; Director of Civil Aviation Security Policy and Planning; Director of Civil Aviation Security Operations; Manager, Programming Branch, Airports Financial Assistance Division; and other Department of Transportation officials. These officials provided us with clarifying information, and we revised the text as necessary.

FAA officials were concerned that our statement that systems cost more than FAA initially had anticipated implies that the systems and the components used in them should have been less costly. We explained that our purpose is to present factual information on the different systems airports installed and that without detailed guidance and standards, it is difficult to determine if systems should have been less costly. FAA officials also stated their concern that achieving cost-effective systems means using the least expensive equipment. We stated that this is not our position and that systems may be cost-effective using equipment that is more expensive in the short term but lasts longer and performs better, resulting in less cost over time. FAA officials also expressed concern that using standards to assist in making AIP funding decisions would limit the agency’s ability to accommodate security needs at individual airports. In our view, the standards would provide a baseline from which to begin evaluating funding requests and would not prohibit FAA from taking into account the access control needs of individual airports. Furthermore, FAA and the industry plan to develop standards that will accommodate the needs of all airports subject to access control requirements. Therefore, we believe that standards could allow for airport-by-airport decisions while still providing a tool to help ensure that systems are cost-effective. Finally, FAA officials noted that the appropriate use of access control systems by airport and airline employees is a critical factor in ensuring that such systems are effective. We concur with this position.

Scope and Methodology

We performed our review between October 1993 and January 1995 in accordance with generally accepted government auditing standards. All dollar amounts in this report have been adjusted to constant 1993 dollars. Additional details on our scope and methodology are contained in appendix IV.

As agreed with your offices, unless you publicly announce its contents earlier, we plan no further distribution of this report until 10 days after the date of this letter. At that time, we will send copies of this report to appropriate congressional committees; the Secretary of Transportation; the Administrator, FAA; the Director, Office of Management and Budget; and other interested parties. We will make copies available to others on request.

This report was prepared under the direction of Allen Li, Associate Director, who may be reached at (202) 512-3600. Other major contributors are listed in appendix V.

14 C.F.R. 107.14-Regulated Airports by FAA Region, as of August 1994

Alaskan Region

Central Region

Eastern Region

Great Lakes Region

New England Region

Northwest Mountain Region

Southern Region

Southwest Region

Western-Pacific Region

Total Actual and Projected Costs for Access Control Systems by Year, as of August 1994

Comparison of FAA’s Initial Estimate for Access Control Systems With Airports’ Actual and Projected Costs

Scope and Methodology

To address our objectives, we performed work at FAA headquarters in Washington, D.C. We also met with officials at FAA’s Central Region in Kansas City, Missouri; its Northwest Mountain Region in Seattle, Washington; Southern Region in Atlanta, Georgia; and Western-Pacific Region in Los Angeles and San Francisco, California. We visited 17 airports of varying size throughout the country. We interviewed executives and former executives of aviation industry associations, including those representing the interests of airports, airlines, and pilots. We attended a major conference in Nashville, Tennessee, at which we communicated our understanding of access control issues and sought the knowledge of airport managers.

We attended meetings of the Aviation Security Advisory Committee; the Committee’s Universal Access System subgroup; and RTCA, Incorporated Special Committee 183. We conferred privately with these groups’ members, which included senior FAA officials, aviation industry representatives, and system experts. At our request, FAA surveyed all 258 regulated airports to gather detailed data on the costs that airports and airlines have incurred to date and on costs that they anticipate incurring through the year 2003 for access control systems. We worked closely with FAA during all phases of its survey to understand the validity of the information. Finally, we reviewed the agency’s regulations, policies, and procedures governing access control systems.

Major Contributors to This Report

Resources, Community, and Economic Development Division, Washington, D.C.

Seattle Regional Office

Randall B. Williamson, Assistant Director Lisa C. Dobson Dana E. Greenberg The first copy of each GAO report and testimony is free. Additional copies are $2 each. Orders should be sent to the following address, accompanied by a check or money order made out to the Superintendent of Documents, when necessary. Orders for 100 or more copies to be mailed to a single address are discounted 25 percent.

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