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On Monday of this week, DHS released details on the Final Rule for private aircraft departing and arriving in the US.  Focused on ‘general aviation,’ which encompasses everything outside of military and commercial aircraft (private pilots, small charters, etc.), the new rule is designed to close the long-open gap of who is coming and going from these smaller aircraft.

As any post-9/11 flier knows, when buying your airline ticket you need to provide your full name as well as other pertinent information before you are ticketed or get to board your flight.  That has not been the case with general aviation where persons could come and go with little to no hassle or paperwork to impugn their movement.  This rule changes that.

As presented in Sec. Chertoff’s CSIS Remarks and in the Bloggers Roundtable in which he and TSA Administrator Kip Hawley participated at TSA Headquarters, the actions being taken are designed to proactively remove/reduce the ability of terrorists to use such aircraft as another means to do the homeland harm. Whether using it to deliver a bomb or other WMD, DHS is looking to this rule to help close one of the last major aviation vulnerabilities remaining in the homeland.

A key point the Secretary stressed in his CSIS speech and in his remarks to the assembled Bloggers was the fact that this vulnerability had not received more attention or concern than he thought it warranted and deserved.  Given the volatile debate we have seen over cargo container scanning, he’s right.  It doesn’t take a Hollywood screenwriter or videogame developer to come up with a scary scenario of a single aircraft unleashing horror upon the homeland.  We’ve lived that nightmare before and no one wants to line up to see the sequel.

It’s great to see the Department being proactive in taking another option off of the table for terrorists to use against us.  That’s what we want them to do.  We want them to be creative and imaginative about how the Bin Laden bunch might use our open society against us.  The actions they are taking are the direct converse of the “failure of imagination” that the 9/11 Commission identified in its final report.  While it is impossible to identify every means, mechanism and method by which terrorists might utilize to unleash hell upon us, it’s a good sign when the Department’s leadership is able to point out an avenue that they are looking to close off to keep us safe.

What remained unanswered in the Secretary’s CSIS remarks and the Bloggers session that followed was: What does an action like this cost, and who pays for it?

How much does this Final Rule cost the general aviation industry?  How much does this cost the private pilot, or the charter company that operates as a small business?  Every action we undertake in homeland security, no matter what it is, costs someone, somewhere something.  The majority of the time those costs are placed on the private sector who has to find some where to pay for it.

Nowhere in the issued Fact Sheet on the Rule, the Press Release announcing it, the Fact Sheet on General Aviation or in the Secretary’s remarks does it detail what this rule costs or how we are paying for it.

We know that since 9/11, TSA has spent in excess of $40 billion on aviation security efforts.  Many of these costs have been covered by the 9/11 ticket fees/surcharges; DHS’ annual appropriation as well as the fees and costs that the nation’s airports, airline industry and passengers have paid.  There is no doubt that because of these expenditures we are safer flying public today.

TSA for all of the criticism and griping it gets for making us take off our shoes at the check-in line and put our deodorant and toothpaste in a clear one-quart bag deserves enormous credit for its work on all of our behalf.  What bothers me though is our lack of acknowledgement or understanding of how we pay for these actions; the impacts of these costs; and our (lack of) willingness to discuss such costs.

In the Q&A period following Secretary Chertoff’s CSIS remarks, not one question from the assembled attendees or mainstream reporters asked, “How much does this cost?” or “How are we paying for this?”

When I had the opportunity to ask those two questions to Secretary Chertoff and Administrator Hawley in the Bloggers Roundtable, they seemed surprised such questions were being asked.  Neither Secretary Chertoff nor Administrator Hawley had the answer to either of the questions.

While I don’t expect either of these gentlemen to have every number committed to memory given everything that they have on their minds, I was surprised that neither of them, nor the Department-issued materials, did anything to communicate the costs of these actions nor how we pay for these new steps to safeguard the nation.

I do not doubt the actions they are undertaking for general aviation are worthwhile and necessary, but in an era where our financial resources are becoming more and more constricted, we need to be upfront about what our homeland security actions cost and how we will pay for them.  We’ve not done that with this rule – at least not in the actions of this week.

I guess when you compare the costs of this Final Rule and its implementation to the ever-growing costs of bailing out bad mortgages, banking and insurance giants and US automakers, it’s just small change. Unfortunately, all of the small change (the costs of rules such as this) begins to add up after a while.

If we don’t start talking about these costs and acknowledge their impact (particularly on small businesses and individual citizens), we will never fully comprehend the long-term costs of our actions (loss of businesses, small/regional airports, individual liberties, etc.).

Life teaches us all that there will always be a day when the bill comes due.  Prior to getting that bill, we owe it to ourselves and the generations that follow to ask at the outset of actions such as this one (and every other one to come after it): “How are we going to pay for it?” and “What’s it going to cost?”

No one has answered these questions yet on the new General Aviation Rule, but I hope they will.  We deserve answers because we’re the ones who get stuck with the bill.

Rich Cooper blog primarily on emergency preparedness and response, management issues related to the Department of Homeland Security, and the private sector’s role in homeland security. Read More