LPDs and BDOs, Oh My…

Oct. 12, 2017

For many years, FAA and TSA have required passengers on US carriers to be “profiled” when traveling from foreign locations considered to be high risk, primarily from LPDs, or Last Points of Departure –non-stops into the US. Certainly when an increased threat is perceived, but not necessarily to the same level at all times. It has never been quite clear what was included in profiling, or the criteria by which passengers might be selected for further scrutiny and/or denied boarding. There are typically at least three processes at work: (a) good intelligence work and information sharing among governments and carriers which may (or may not) identify a questionable person; (b) generally highly biased characteristics such as race, religion, and ethnicity, particularly Muslims and Latinos, which are not an indicator of threat, and (c) the now broadly debunked process of behavior detection, determined by numerous recent studies as being no better than a coin toss in identifying a security threat. Indeed, I’ve noted in recent travels that I often exhibit around seven of TSA’s questionable behavior detection criteria just walking in the terminal door. (and my critics nod, “aha…)

Recently, industry sources tell me that by October 26th, driven by new threat information, the TSA is requiring all passengers be profiled from all LDPs to the US on all carriers, (note the emphasis). Airports and airlines worldwide are struggling with how this is to be implemented, by whom, to what criteria?

  • As a new requirement, is the threat the same everywhere, or changing with time and place.
  • Are there new criteria to address the new threat, or is it the same processes just expanded to cover more people and places all the time.
  • Define “high risk” LPDs – does that keep changing as the new threats evolve? How much flexibility, mobility, transferability, oversight and testing for all carriers at all LPDs?
  • Is it truly “profiling,” or just asking more questions while they are in the queue?
  • What’s an airport’s role in other countries? Are their LEOs (who may not even “belong to” the airport) being required to meet US criteria which may not be legal or culturally acceptable in another country. TSA has no jurisdiction in other countries, but can refuse entry to aircraft and countries who don’t play by TSA rules.
  • Similarly, when a carrier does the profiling and “hits” on someone, what are the protocols in each different country…. which can have enormous (and different) down-stream legal, economic and operational consequences for every business, corporate and governmental player.

I’m glad that TSA is seen as the proverbial gold standard for aviation security worldwide, and everybody wants to emulate us to the extent possible, while contributing excellent air service to our economy. But there is a convergence of TSA issues in the US, beginning with a new leadership which is considerably more risk averse than the previous administrations’ risk-based approach to nearly everything.

Consider this: Imagine Airline X departing from Country Z, and either one says “this is against our laws, culture or customs.” TSA may then say ‘don’t launch it to the US’, whereupon several hundred people without appropriate visas are now stranded, perishable and time sensitive cargo is lost, the aircraft and crew are now out of their operational cycles with no aircraft in place for downline service… the list goes on… and on and on. Of course, many of these problems may be addressed days before flight time – but they are every day, for all LPD carriers at all LPD airports, ad infinitum, not just once. Today’s definition of chaos, with plenty of room for a multiplier of unintended consequences as this gets underway.