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February 2, 2006

Dear Sir:

On behalf of the Global Express Association (GEA), representing the major international express delivery companies, I am responding to an article on air cargo security that appeared in the January 23rd edition of Air Cargo News. This article included certain statements made by Mr. Harald Zielinski, chief of security for Lufthansa Cargo at Frankfurt airport, which, if accurately quoted, are erroneous, dangerously provocative, and not supportive of efforts that governments are making to deal rationally and effectively with terrorist threats to international aviation.
    With respect to persons on board aircraft, there have been many long, detailed discussions within and among governments and with the aviation industry on the risks associated with either passenger/combi aircraft or all-cargo aircraft being hijacked and then used as a missile. This scenario is seen as a significant threat to the industry and, consequently, EU and national aviation security laws on airport and aircraft security are equally applicable to both passenger/combi and all-cargo aircraft. Additionally, carriage of persons on all-cargo aircraft is specifically regulated by the national aviation departments of the countries in which the carriers are registered, and those persons with access to all-cargo aircraft - who are very few - receive significantly more scrutiny than passengers on passenger aircraft.     For the most part, the only persons who are passengers on all-cargo aircraft are employees, approved contractors, and government officials: they are not unknown persons.
    At global and regional forums where governmental aviation experts meet to discuss such issues, they agree that the risk of cargo containing explosive devices being placed on board an all-cargo aircraft is less than the risk of explosives or other devices capable of inflicting mass casualties being used onboard a passenger or combi aircraft.
    This agreed differential is fully reflected in the measures adopted within their aviation security policies, standards and recommended practices. EU legislation also reflects these global and regional expert policies and opinions, and provides different treatment with respect to the security procedures for cargo destined for transportation on an all-cargo aircraft versus cargo that is transported on a passenger/combi aircraft.
    The difference in risks faced by each aviation sector have also been recognized by ICAO, ECAC, the EU Commission, the EU member states, IATA, and many commercial airlines, and are supported by independent empirical studies. (Cf. Aviation Security and the Potential Terrorist Threat to Air Cargo, (Centre for Defence and International Security Studies (CDiSS), December 2005); and Aviation Security and Terrorism: A Reassessment of the Potential Threat to Air Cargo Integrators (Dr. Bruce Hoffman, Director, Centre for Study of Terrorism and Political Violence, University of St. Andrews, Scotland, 1999).
    It is fatuous to argue that there should be only one set of security rules for all air carriers, and that a “dual” security regime defeats the objective to provide an equally secure international air cargo supply chain. In fact, all modern risk assessment models, including those used by customs administrations for anti-terrorism purposes, recognize that different situations present different risks and that to treat all situations the same wastes government resources and reduces the effectiveness of security efforts by diverting them to lower risk situations. As the recent report by CDiSS points out, appropriate security regulations should be put in place that are risk-based and that are standardized across the globe as far as possible.
    Air carriers that choose to carry passengers and cargo on the same aircraft have simply selected a business model that, while producing two streams of revenue, offers different attractions and opportunities to terrorists. It is ineffective and inefficient to subject all-cargo carriers, who forgo passenger revenues, to the same security rules that must be applied to combination passenger-cargo carriers in a misguided effort to level a commercial play field.

Sincerely,
John P. Simpson