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AIR TRANSPORT ASSOCIATION

• JAMES C. MAY
PRESIDENT AND CEO

August 18, 2003

Mr. Daniel Marcus, Esquire


General Counsel
National Commission on Terrorist Attacks
301 7th Street, SW Room 5125
Washington, DC 20407

Re: Air Transport Association of America, Inc. - Response to Request for


Additional Information

Dear Mr. Marcus:

I welcome the opportunity to provide additional information to the National Commission


on Terrorist Attacks ("Commission") and to supplement my May 22nd testimony. As
indicated in that testimony, ATA and its member airlines fully support the Commission's
efforts to explore the events of September 11, 2001; we will all benefit from the
Commission's review, analysis, and recommendations for the future.1

With regard to your July 18th request, I will address each item as fully as possible. I
anticipate, however, that some of my responses may leave you with more questions. The
ATA, a nonprofit trade association not regulated by the FAA, is not privy to much of the
government's sensitive security information about the events of September 11th that
might be responsive to your requests. My responses are made on behalf of ATA, the

Members are: Airborne Express, Alaska Airlines, Aloha Airlines, America West Airlines, American
Airlines, Astar Air Cargo (formerly DHL Airways), ATA Airlines (formerly American Trans Air), Atlas
Air, Continental Airlines, Delta Air Lines, Emery Worldwide, Evergreen International Airlines, Federal
Express, Hawaiian Airlines, JetBlue Airways, Midwest Airlines, Northwest Airlines, Polar Air Cargo,
Southwest Airlines, United Airlines, United Parcel Service, and US Airways. Associate members are:
Aerovias de Mexico, Air Canada, Air Jamaica, KLM-Royal Dutch Airlines, and Mexicana de Aviacion.

NOTICE: This document contains SENSITIVE SECURITY INFORMATION (SSI) that is subject
to 49 CFR Part 1520. Release of the information contained herein noted as SSI, or the materials
submitted herewith marked as SSI, is prohibited without the express written approval of the
Administrator of the Transportation Security Administration.

AIR TRANSPORT ASSOCIATION OF AMERICA, INC.

1301 PENNSYLVANIA AVENUE, NW SUITE 1100 WASHINGTON, DC 20004-1707


202.626.4168 FAX 202.626.4166
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 2

entity, based on knowledge and information in the possession of ATA employees, and
not on behalf of individual airlines or with knowledge of information they may possess.
Likewise, others may be in a position to more fully answer your questions as, both pre
and post-September 11th, ATA does not gather security intelligence nor provide any
independent analysis of security intelligence to our members.

Finally, as indicated in several of my responses, the ATA and its member airlines, and, in
fact, the public, all rely on agencies of the U.S. government (particularly the FAA prior to
September 11th) to utilize all resources and information they have available to them to
develop a threat picture, provide relevant intelligence information to the airlines and to
formulate appropriate security responses. As stated in the 1997 Gore Commission
Report, "terrorist attacks on civil aviation are directed at the United States...there should
be an ongoing federal commitment to reducing the threats that they pose."3 We believe
the federal government's continued responsibility for the acquisition, analysis and
dissemination of appropriate threat information and security procedures is essential.

1. From the airlines' perspective, how would you characterize the pre-September 11,
2001 performance of the aviation security system in general and the baggage and
passenger screening system in particular? What methods did you use to evaluate
this performance? What steps did you take to improve the system? Please
provide any document or reports generated by ATA with respect to the
effectiveness of the aviation security system.

Response to Request No. 1. Because ATA did not have in place a process or procedure to
evaluate the performance of the aviation security system prior to September 11, 2001 (nor
do we have such a process now), we can only offer the observation that, from our
perspective, the aviation security system generally performed as it was intended in that it
was responsive to the security threats the Government identified.

Although then and now ATA disseminates regulatory updates and advocates positions in
regulatory proceedings on security matters on behalf of our members, as a trade
association we did not formally evaluate, audit or analyze the airlines' compliance with

2 ATA is providing certain documents that contain Sensitive Security Information (SSI) and, therefore,
subject to the terms of the Nondisclosure Agreement executed by your office. ATA is following the TSA's
direction as to the identification and treatment of these documents. Documents containing SSI are marked
accordingly, as are certain sections of this letter. In addition, ATA has a general three-year records
retention policy and was unable to locate some of the requested documents. Responsive documents that
ATA was able to locate (both within and outside this timeframe) have been provided.

White House Commission on Aviation Safety and Security, Final Report to President Clinton. February
12, 1997, Recommendation 3.1, page 26.
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 3

regulatory requirements. That is not our role.4 At the direction of the ATA Board of
Directors, ATA consistently works to improve the civil aviation security system and will
continue to do so. Both pre- and post-September 11th, ATA has worked within the
existing regulatory and legislative framework by providing information about airline
industry practices, operations, and concerns; participating in government/industry
working groups to review a wide range of security concerns; and cooperating fully with
the federal government's efforts. Even with these varied activities, we did not have day-
to-day exposure to the performance of the civil aviation system and, therefore, cannot
characterize its performance.

2. What did the ATA and the airlines know about the terrorist threat to civil aviation
in the 3-month period leading up to 9/11? What specific steps did ATA or the
airlines take in response to such threats? In your testimony, you indicate that the
FAA provided the airlines with no specific, credible threat information about
hijackings during 2001 prior to September 11. Do you believe this was because
the FAA did not receive such information from the intelligence community,
because the FAA did not adequately transmit what it knew to the airlines, or some
combination of the two?

3. You testified that FAA provided the airlines with no specific, credible information
about hijackings during all of 2001 up to and including September 11 and issued
no relevant Security Directives during that period. Yet, former Associate
Administrator for Civil Aviation Security Canavan testified that heightened
concern was communicated to the airlines via 15 Information Circulars (IC's) and
five Security Directives (SD's) during that time span. The SD's are a form of
communications which your testimony indicated "deals with more definite threat
information warranting a modification of security procedures." How do you
respond to Mr. Canavan's assertion?

Response to Request Nos. 2 and 3. ATA's knowledge as to any alleged terrorist threat to
civil aviation in the three-month period leading up to September 11th is based on
information it received from the FAA. As I indicated in my May 22nd testimony, in 2001
(prior to September 11th), FAA issued fifteen Information Circulars relating security
information to the airlines. None were directed at nor required action by ATA. Four ICs
mentioned the term "hijacking" - three of them making a generic reference to the threat
and one providing a more descriptive reference to a conventional hijacking concern.
None contained specific information about the threat of hijackings similar to those that
4
ATA did conduct a review of non-airline employee employment history investigations conducted in the
summer of 2001. Under the Air Carrier Standard Security Program ("ACSSP"), a compilation of security
requirements that FAA required carriers to implement, airlines were required to conduct a limited review
and reverification of these investigations. While ATA reverified investigations on behalf of some of our
members, the ATA did not evaluate, audit or analyze the results. A summary overview of the review and a
report submitted to the FAA are located in Tab 1.
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18,2003
Page 4

occurred on September 1 llh. In addition, in 2001 (prior to September 11th), FAA issued
six Security Directives, all requiring action by the airlines. None were directed at nor
required action by ATA. As I indicated in my May 22nd testimony, none were relevant or
contained specific, credible information pointing to a hijacking similar to those occurring
on September 11th. Neither the Information Circulars nor the Security Directives
provided any information relating to a security threat different from threats the FAA had
previously described to the airlines.

Since ATA was simply a recipient of security information from the FAA, ATA has no
ability to form a belief as to whether FAA did not receive certain information from the
intelligence community, or did not adequately transmit the information it received to the
airlines.

4. How did economic factors affect the civil aviation security system prior to
September 11, 2001? How did the airlines balance economic and security
interests within that system? What role did economic factors play in creating the
system you called "prevent or defer" rather than "prevent and detect"? Please
describe the differences between these two approaches.

Response to Request 4, Prior to September 11th, the airlines were subject to an extensive
regulatory security scheme developed and administered by the FAA. The FAA
determined the regulatory purposes, goals, program requirements, and enforcement
parameters. Neither the ATA nor the airlines made these determinations; instead, the
airlines implemented them as directed by the FAA. For this reason, the airlines did not
"balance economic and security interests." I can only assume that a number of factors
influenced the agency's determinations, but ATA cannot assess the effect of economic
factors on the FAA's regulatory scheme in place prior to September 11th. I would note
that several Presidential Orders and regulations from the Office of Management and
Budget require agencies, including the FAA, to conduct a meaningful cost/benefit
analysis of certain categories of proposed regulatory requirements. In this context, ATA
would provide industry input on both the estimated costs and likely operational impacts
of proposals.

TSA CONSIDERS THIS TEXT AS SSI AND SUBJECT TO THE SSI


NONDISCLOSURE AGREEMENT. The FAA. in the initial "Purpose" section of the

9/11 Closed by Statute


Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18,2003
Page 5

9/11 Closed by Statute

5. Specifically, what was the status of box cutters at each of the airport security
checkpoints that the hijackers passed through on September 11, 2001? You state
in your testimony that box-cutters were a "restricted item" in Checkpoint
Operations Guides. Was this the case at all of the checkpoints the hijackers
passed through? You further indicate that the screening systems in place on 9/11
were "not designed to detect or prohibit these types of small items." Under these
circumstances, how were box-cutters to be identified and kept off an aircraft
pursuant to the Checkpoint Operations Guides?

Response to Request No. 5. In response to the first two questions, ATA has no
information as to the "status" of box cutters at each of the airport security checkpoints the
hijackers passed through on September 11th, As indicated in my May 22nd testimony, the
Checkpoint Operations Guide ("COG") was a non-regulatory, non-binding guidance
document developed by the FAA, Regional Airline Association, and ATA, with the
FAA's approval in the interpretation of FAA regulations. The COG guidance listed box
cutters as "restricted" items posing a potential danger.

TSA CONSIDERS THIS TEXT AS SSI AND SUBJECT TO THE SSI


NONDISCLOSURE AGREEMENT. Under the COG guidance, if an alarm sounded

9/11 Closed by Statute


Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 6

6. Published reports indicate that at least nine of the nineteen hijackers were selected
for special security scrutiny prior to boarding the hijacked flights: six by the
computer-assisted prescreening (CAPPS) system, two because of identification
document irregularities, and one because he was traveling with one of the latter
two. Are these reports accurate? Specifically, what triggered each selection? In
each case, what was done as a result of the selection?

Response to Request No. 6. ATA has no information as to whether some of the


September 11th hijackers were selected for special security screening prior to boarding
and, therefore, cannot confirm whether the published reports described in your request
are accurate or what may have occurred prior or subsequent to the purported selections.

7. Please describe the roles and actions of ATA and the individual airlines, as of
September 11, 2001, with respect to aviation security rulemaking, policy
development and implementation. Please provide copies of the airline industry's
comments to the Department of Transportation in response to Notices of Proposed
Rulemaking on issues related to civil aviation security, for the following
rulemaking proceedings:
a. Criminal record checks for all airport employees (NPRM by FAA
published on 2/13/92 in response to recommendation of President's
Commission on Aviation Security and Terrorism; NPRM by FAA
published on 3/19/97 in response to recommendation of White House
Commission on Aviation Safety and Security)
b. Passenger/baggage matching (FAA issued final amendment to ACSSP
effective 12/8/90 in response to recommendation of President's
Commission on Aviation Security and Terrorism)
c. Identification and pre-boarding security procedures for airline passengers
(FAA issued initial proposed agreement to ACSSP on 3/28/97 in response
to recommendation of White House Commission on Aviation Safety and
Security)
d. Revision of federal regulations for airport and air carrier security
(published in the Federal Register of 8/1/97)
e. Certification of screening companies and improvement of screener
performance (Advance NPRM issued by FAA on 3/17/97 in response to
recommendation of White House Commission on Aviation Safety and
Security)
f. FAA rulemaking on Aircraft Operation Security which began with the
issuance of Notice 92-12 to revise Part 108 on August 1, 1997 and
culminated with the issuance of the final rule in the Federal Register of
July 17, 2001 (Docket No. FAA-2001-8725).

Response to Request No 7. As indicated, pre-September 11th, ATA often provided


information about industry practices, operations, and concerns with respect to aviation
security rulemaking, policy development, and implementation. ATA's role included the
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page?

submission of written comments to the Public Docket in formal rulemakings, and


participation in agency/industry work groups and task forces, public "listening sessions,"
and informal and formal industry meetings attended by representatives of the FAA.

Copies of the written comments requested are located in Tabs 3A. (Request 7a.); 3C.
(Request 7c.); 3D./F. (Requests 7d. and/.); and 3E. (Request 7e.) ATA was unable to
locate the document requested in Request 7b,

8. You testified, "The airline industry has long been on record advocating that, over
time, the TSA security system evolve to focus more intensively on looking at
people rather than searching solely for things," and you mentioned the so-called
CAPPS II program TSA is developing. What is your current evaluation of TSA's
work in this regard? Do you have any recommendations for the design of the new
system? How will CAPPS n be better than the original system which was in
place on 9/11? Do you believe the new system will be able to alleviate your
passengers' concerns about both security and privacy?

Response to Request No. 8. ATA cannot evaluate TSA's work in developing the CAPPS
II system because our information about TSA's efforts is limited. To date, ATA has
received only general information about the system's current design and has not been
asked to participate in the formulation of screening criteria, system parameters or testing.
ATA's knowledge about TSA's current efforts to address passengers' privacy concerns is
limited and comes primarily from information contained in the Privacy Act Notice,
Interim Final Rule, and Request for Further Comments in the Federal Register on August
1 (DHSATSA 2003-1, 68 Fed. Reg. 45265 (August 1, 2003). ATA supports TSA's efforts
and currently is reviewing the Notice.

Based on the industry's experience with CAPPS I, I believe it is possible to design a


more sophisticated system using the significantly enhanced intelligence information
gathered by the federal government post-September 11th. This system should better
identify those passengers for whom additional screening is recommended, while
addressing the public's understandable privacy concerns. The federal government, and
not ATA or the airlines, is in the best position to gather information, evaluate the threat
posed by potential airline passengers, and design a highly focused screening system.
ATA would welcome the opportunity to learn about the TSA's progress and offer our
views.

9. For the record, please supply the Commission with a description of the "new and
improved training programs for crew members," you referred to in your
testimony.

Response to Request No. 9. TSA CONSIDERS THIS TEXT AS SSI AND SUBJECT
TO THE SSI NONDISCLOSURE AGREEMENT. Revised Crewmember Training
I 9 / 1 1 Closed b y S t a t u t e I
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18,2003
PageS

9/11 Closed by Statute

10. At the hearings, you were asked to clarify an apparent discrepancy between pre-
9/11 statements by ATA claiming that the airline industry was spending one
billion dollars a year on security and more recent statements which place this
figure at approximately $300 million a year. You testified that the $1 billion
figure was just an off-hand estimate by an ATA official. Yet press accounts
indicate that ATA submitted this figure in response to an official GAO inquiry.
Please explain this discrepancy and detail for the record what security cost
estimates ATA has developed over the last five years, up to and including the
present. In addition, please provide the Commission with the basis for these
estimates.

Response to Request No. 10. I will try to address the differences in these security cost
estimates as directly as possible because, unfortunately, there is much confusion about
their bases. The contrast between the $1 billion and $300 million cost estimates has been
used by some to suggest bad faith on the part of the airlines. This is not the case. The
differential is understandable due to the components and nature of the estimates.

The origin of the $1 billion estimate was a request from the General Accounting Office
("GAO") in April 2000 concerning airline passenger and baggage screening costs. The
GAO request is located at Tab 5. One of the difficulties in developing cost estimates is
the variances in internal systems among the carriers, including how costs are defined,
interpreted, and accounted for, as well as the scope of security requirements at issue.
Because this data was not specifically tracked in a consistent manner across the industry,
the ATA Security Committee agreed to try to develop an estimate, to the degree possible,
in an effort to assist the GAO. In August 2001, ATA provided a short memorandum to
the GAO based on responses from some, but not all, ATA member airlines.

Extrapolating from the limited and diverse information provided, it estimated costs to the
entire industry to implement all federal security requirements and conduct required
security programs at $1 billion. ATA's memorandum is located at Tab 5. This rough
estimate included, among other items, security equipment funded by the government,
total security program costs, foreign location security screening expenses, training, etc.5
Unfortunately, with the events of September ll lh , this very rough estimate became a
quick reference point for the Congress, the Administration, and the industry. Despite
repeated explanation as to its origin, and the acknowledgment that it was not based on a
comprehensive set of data derived from reliable, complete cost reporting, this "short
hand" $1 billion estimate was cited without the requisite limitations.

5This rough estimate was an attempt to project an industry-wide estimate based on a limited number of
airline responses that, because of the difficulties listed, contained varied data, descriptions, and
components.
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 9

I understand that the origin of the $300 million estimate is the federal government's short
hand reference to the estimated, aggregated security screening costs submitted by the
airlines in response to the requirements of the Aviation Security Infrastructure Fee, 67
Fed. Reg. 7926 (February 20, 2002)(the "Rule"). Under the Rule, the airlines were
required to submit their cost data relating solely to the screening of passengers and
baggage (not all security costs) in the year 2000 to the TSA. The data, used to determine
a carrier's infrastructure fee, was to be submitted in prescribed categories contained in an
appendix to the Rule. ATA and the American Institute of Certified Public Accountants
expressed concerns about the rigid cost categories in the appendix and the ability of the
airlines to segregate the costs in this fashion. Although the TSA issued supplementary
guidance in response to some of the concerns, the cost categories in the appendix were
not altered. It is my understanding that some carriers did not include certain costs because
they were very difficult to determine. In addition, some carriers felt certain costs should
not have been included in the basis of the carrier's infrastructure fee because the TSA had
not assumed responsibility for the security function (and, therefore, carriers would be
paying these costs twice), or for other reasons, and that limitations were noted as such.
Any screening costs omitted for these or other reasons would result in a lower aggregated
amount.

With regard to security cost estimates developed by ATA, in March 2003, ATA released
Airlines in Crisis/The Perfect Economic Storm, a report describing the economic crisis
confronting the airline industry and forecasting the impact of the then expected invasion
of Iraq.6 The report estimates that post-September 11th taxes, fees and unfunded
mandates have added more than $4 billion to the industry's annual burden. This report
includes incremental pretax estimated costs (extrapolated from estimates from twelve
ATA member airlines and six of their regional affiliates) of numerous airport related and
other required security enhancements, new postal service restrictions, increased insurance
costs, DOT fee for passenger screening (approximated according to TSA reports), federal
air marshal opportunity costs, freight restrictions, new security tax, and cockpit door
fortifications.7 A copy of the report is located in Tab 5.

While ATA made other attempts to capture and project security costs, none were
successful. In February 2002, ATA attempted to estimate 2000 industry-wide screening
costs, but did not finalize or release any estimate. As with prior efforts, it was
determined that the product would be unreliable since the cost data was submitted by
some but not all ATA member airlines and it was incomplete and subject to
interpretation, as the differences in data designation and collection could not be
overcome. It is marked confidential and was never released. Subject to your execution
of the nondisclosure agreement (as to confidential ATA documents) between ATA and

6 Airlines in Crisis/The Perfect Economic Storm, Air Transport Association.

Airlines in Crisis/The Perfect Economic Storm, Chart 10, p. 16.


Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 10

the Commission attached hereto, a summary table is located at Tab 5. In February 2002,
at FAA's request ATA also attempted to estimate the cost of security office space at
airports, but, again, due to the limited response (four airlines) and difficulty in comparing
costs, the results were considered incomplete and unreliable. The summary results are
marked confidential. Subject to the nondisclosure agreement (as to confidential ATA
documents) between ATA and the Commission, the summary is located at Tab 5. In
October 2001, at FAA's request ATA distributed an FAA survey form requesting an
inventory of screening equipment/personnel to the carriers. ATA forwarded the carrier
submissions directly to the FAA. A copy of the FAA survey form is located at Tab 5
(TSA also has identified this information as SSI).

11. Was ATA contacted by an airline or the FAA on September 11, 2001 prior to the
grounding of all civil aviation? If so, please describe the communications in
detail. Did the ATA play any role in coordinating response to the events on 9/11?
If so, please describe this role, the actions taken and with whom ATA personnel
coordinated.

Response to Request No. 11. It is my understanding that employees at ATA's main


offices in Washington, DC were not contacted by the FAA prior to FAA's issuance of the
nationwide ground stop on September 11, 2001. At some point that morning, ATA
attempted to contact the FAA Administrator to advise that ATA believed all civil aviation
should be grounded, but was able only to leave a message to that effect with the
Administrator's Assistant. After FAA made the decision to issue the nationwide ground
stop, and several minutes before its formal issuance, ATA employees at the Air Traffic
Control System Command Center (ATCSCC) in Herndon, VA were advised by FAA
employees at the ATCSCC that FAA was about to issue an ATCSCC Advisory ordering
the nationwide ground stop.

ATA personnel had no role in FAA's decision to issue the ground stop and did not
coordinate a response to it. When ATA staff at the ATCSSC were advised that FAA was
going to issue the nationwide ground stop within several minutes, they began attempting
to notify ATA member airlines by telephone that the ground stop was imminent. After
the ground stop was issued, ATA contacted the Chief Executive Officers at several
airlines to advise them that it had been issued, and was advised that the FAA had already
notified the airlines.

Prior to the issuance of the nationwide group stop, ATA personnel at its main offices and
at the Command Center were contacted by various ATA member airlines requesting
information about media accounts and status reports.
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18, 2003
Page 11

12. Please submit a copy of ATA's comments or recommendations to the Gore


Commission, including those on profiling.

Response to Request No. 12. Copies of ATA's comments or recommendations to the


Gore Commission are located at Tab 6.

13. Please submit any documents or other records ATA has produced or received
from the airlines with regard to any analysis of the events of 9/11, such as after-
action reports.

Response to Request No. 13. ATA has not produced nor received from the airlines any
document or other record relating to any analysis of the events of September 11th.

14. Please provide a copy of ATA's communications to international bodies,


including the International Civil Aviation Organization (ICAO), on issues related
to civil aviation security from 1995 through 2001. Please provide a copy of
ATA's communications with individuals or organizations representing U.S.
interests to the ICAO from 1995 through 2001.

Response to Request No. 14. ATA has been unable to locate any documents on issues
relating to civil aviation security that it provided to ICAO or to individuals or
organizations representing U.S. interests to ICAO from 1995 through 2001.

15. Please supply all material relating to ATA assessments of the aviation security
systems at Dulles, Logan and Newark Airports from 1998 through 2001.

Response to Request No. 15. ATA has done no assessments of the aviation security
systems at Dulles, Logan or Newark from 1998 through 2001, or at any other time.

16. Please provide a copy of all the audiovisual and written materials for screener
training in effect on 9/11/01, such as "The First Line of Defense" and "Security
Screener."

Response to Request No. 16. Written and audiovisual materials used in the ATA "Train
the Trainer Seminar" are specifically designated as SSI and subject to the SSI
Nondisclosure Agreement. The written materials are located in a separate binder entitled
"Passenger Screening and Advanced Equipment: Train the Trainer Seminar" provided to
the Commission today. Four audiovisual tapes are also provided.
Daniel Marcus, Esq.
National Commission on Terrorist Attacks
August 18,2003
Page 12

17. Please provide all materials concerning communications between ATA and any
ATA representatives at FAA facilities (including all FAA Operations Centers) on
September 11,2001.

Response to Request No. 17. Prior to the FAA's issuance of the nationwide ground stop,
there were telephone conversations between ATA employees at ATA's main offices and
at the ATCSCC in Herndon, VA about media accounts and updates on events. After the
ground stop was issued, and throughout the day, ATA employees at the ATCSCC in
Herndon telephoned employees at ATA's main offices (and at homes in the Washington
area where ATA employees had gathered after the offices were evacuated) every twenty
to thirty minutes with status reports. ATA employees at the ATCSCC also faxed to
ATA copies of the FAA's ATCSCC advisories and various FAA NOTAMs (Notices to
Airmen) concerning information as to when certain airports would reopen to ATA
employees in Washington. Copies of the advisories are located in Tab 7. Although ATA
does not have copies of the NOTAMs, the FAA may have copies of NOTAMs it issued
on September 11th.

The ATCSCC in Herndon is the only FAA operations center where ATA employees were
located.

I would like to reiterate that ATA wishes to cooperate fully with the Commission's
efforts. Please contact me if you have any questions about these responses or would like
to discuss any issues further.
CONFIDENTIAL ATA Documents

Nondisclosure Agreement

I understand that ATA considers the following documents created by ATA as


CONFIDENTIAL, incomplete, and not for public dissemination or discussion:

• 2000 Screening Costs (February 2002 estimate) marked "CONFIDENTIAL


- NOT FOR PUBLIC RELEASE"; summary table located at Tab 5.
• Cost of Security Space at Airports (February 2002 estimate) marked
"CONFIDENTIAL - NOT FOR PUBLIC RELEASE"; summary results
located at Tab 5.

I agree not to discuss these documents, or their contents, with anyone other than
the members of the Commission and members of the Commission staff, and I agree
not to disclose such documents, or their contents, to anyone other than members of
the Commission and members of the Commission staff.

Signature

Printed Name

Date

Please return signed form to: Air Transport Association, John Meenan, Fax (202)
626-4166.
ATA RESPONSE TO NCTA REQUEST
Dated July 18, 2003

INDEX

Tab 1 (Response to Request 1)

• ATA Summary and Individual Carrier Results from ACSSP Change 57 Review

Tab 2 (Response to Request 5)

• COG pages 4-1 through 4-13, 3 pages numbered 4-, and pages 5-1 through 5-8

Tab 3 (Response to Request 7)

A.
• ATA Comments/Docket 26763 filed May 15, 1992
• ATA Comments/Docket 28859 filed May 19, 1997
C.
• ATA Letters to Adm. Flynn dated May 23, 1997
• ATA Letters to Adm. Flynn dated October 10, 1997
D./F.
• ATA Comments/Docket 28978 dated December 1, 1997
E.
• ATA/FAA Comments/Docket 1999-6673 dated May 1, 2000
• ATA Comments/Docket 1999-6673 dated May 11, 2001
• ATA Comments/Docket 28852 dated May 1,1997

Tab 4 (Response to Request 9)

• AOSSP Change 72, 03/01/2003 (4 pages) and Appendix XHI (6 pages); "Crew
Training Common Strategy, Detailed Guidance"

Tab 5 (Response to Request 10)

• GAO Letter to Doubrava dated April 6, 2000


• Doubrava Memo to GAO dated August 22, 2001
• ATA-Summary of Domestic Security Screening Costs Calendar Year 2000
"Confidential-Not for Public Release"
• DOT Security Screening Survey re Security Office Space "Confidential-Not for Public
Release"
• DOT/FAA Form re Security Equipment (Blank)
• Airlines in Crisis/The Perfect Economic Storm

August 18, 2003


Tab 6 (Response to Request 12)

• Letter from Hallett to Loh dated August 23, 1996 (two attachments)
• Hallett testimony dated September 5, 1996
• Letter from Hallett to VP Gore dated September 13, 1996
• Letter from Hallett to Moran dated October 16, 1996
• Letter from Hallett to Kauvar dated December 17, 1996
• Letter from Hallett to VP Gore dated February 3, 1997

Tab 7 (Response to Request 17)

• Advisory 037 9/11/01


• Advisory 036 9/11/01
• Advisory 031 9/11/01
• Advisory 032 9/11/01
• Advisory 033 9/11/01

August 18, 2003

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