Letter

27 September 2007

ACTE’s Commentary to Department of Transportation regarding Secure Flight Program

-- Commentary from:
Susan Gurley
Executive Director
Association of Corporate Travel Executives
September 20, 2007

Remarks Regarding The Secure Flight Program

Airport security and traveler safety remain the highest priority in the business travel management industry. The Association of Corporate Travel Executives (ACTE) stands ready to endorse any program or plan that advances a security and traveler safety agenda -- offering every conceivable safeguard for the smooth interchange of international and domestic business travel.

In the past, this has meant taking an analytic look at previously conceived security programs and evaluating their potential impact on the business travel industry. Prior ACTE positions have focused on the costs that would be generated by various programs in relation to the security they would have provided. It was our conclusion that earlier programs would have penalized the industry through extensive delays and cancellations -- without substantially improving airport and traveler security.

These programs included CAPPS II (Computer Assisted Passenger Pre-Screening System II) and an earlier version of Secure Flight. The association did not endorse the ATS (Automatic Targeting System) as there was little or no information available about the program.

The new Secure Flight program represents the latest stage in the evolution of security programs developed by the federal government that rely on data bases, compiled through various means during the last six years. As the program appears to incorporate some characteristics of earlier programs combined with new features, it must undergo broader study by the business travel industry and cannot be regarded as a stand-alone program, separate from its background.

Therefore, our position on the newly revised Secure Flight program has been broadened accordingly. It now extends beyond the cost issue to include an individual's right to see what information is in a data base that could prevent them from boarding a commercial flight, and to change that data if it is incorrect. In the current environment of suspicion, ACTE has determined that being denied access to travel can impact an executive's corporate standing.

ACTE previously stated that it will not endorse any security program without a redress vehicle for passengers on the "No Fly" list. This includes Secure Flight. Despite the creation of the DHS "TRIPS" program, our position has not changed. There is little information on the success of the TRIPS program with regard to the number of situations that were resolved, or the number of passengers who have had unrestricted travel privileges restored.



In the last four years, the travel industry learned of improper usage of PNR (Passenger Number Record) information, social security numbers published on the internet, that Congress denied funding for CAPPSII, that Secure Flight was withdrawn before the last Presidential election, of the ATS (Automatic Targeting System), of a new government traveler data base that was to be exempted from key provisions of the Privacy Act, and of various challenges faced by the Registered Traveler program.

Last week, the Government Accountability Office (GAO) published a report that stated the DHS did not meet more than half of the 171 objectives the agency has set for itself. Even more glaring was the conclusion that improvements in critical areas like aviation security was lagging.

Considering that Secure Flight is based on previous programs, ACTE's review of it includes the same evaluation process that was applied to its predecessors, plus additional criteria.

On behalf of more than 2500 members in 50 countries, and 1300 representatives from corporations in the United States, ACTE is compelled to ask these questions.

1) What is the performance record for the DHS TRIPS program? (Specifically, how many cases have been resolved and what is the average length of time it takes to resolve a case?)
2) How and from where was the current traveler data derived?
3) What is the purpose in denying travelers access to their information and the option to change incorrect data?
4) Who has access to the data? (Specifically, do foreign governments and licensing agents have access to this data?)
5) What role does the ATS have in compiling this data?
6) Is this the same data used for the Registered Traveler Program?

Any security program implemented by the federal government must include an effective passenger redress process, which offers access to individual's information and the ability to change inaccurate data. The data collected should consist of the minimum amount of information required to establish an individual's identification. As in Europe, the information should be strictly limited to a minimum number of security agencies, and used solely to prevent acts of terrorism. There should be one data base used for the purpose of establishing identification for all travel purposes, including the Registered Traveler program.

Airport and passenger security are critical links in global commerce and national economic growth. It should not be approached in a piecemeal fashion, nor with the hopes that one automated system will protect us forever, or for even a short while. The objectives of the TSA and the DHS are also the objectives of our industry. They should be fulfilled jointly.




Susan Gurley
Executive Director
Association of Corporate Travel Executives