Make international travel simpler, AOPA tells DHS

September 9, 2010

It’s only a two-hour flight from where Neil Mathison hangars his Cessna 180 floatplane in Wisconsin to his cabin to the north, but the Canadian border in between makes routine fishing trips complicated.

Mathison files passenger manifests for each outbound and return flight using the Customs and Border Protection’s Electronic Advance Passenger Information System (eAPIS). Plus, he must file much of the same information when he requests an international “no transponder” waiver from the Transportation Security Administration.

“There’s no reason why you should have to do the duplication. … They know everything about you when you file that APIS [Advance Passenger Information System],” said Mathison, who said he has been flying across the border regularly for more than three decades and has seen international travel procedures become more and more complicated since 9/11.

But the TSA and CBP do not share passenger and flight information, so general aviation operators must duplicate efforts. AOPA asked the two agencies Sept. 7 to remove the redundancies between their programs.

The Department of Homeland Security took a step forward in coordinating between its agencies to streamline international GA travel in July, when it announced a process that eliminated redundancies for non-U.S.-registered aircraft flying into the United States at EAA AirVenture. This announcement, while affecting a very small number of GA pilots, demonstrated the department’s commitment to improving efficiency of the systems, said AOPA Manager of GA Security and Borders Brittney Miculka.

“AOPA asks that you expand this streamlined system one step further, by exploring ways to assist those general aviation aircraft that must apply for an International-‘No Transponder’ waiver,” Miculka wrote in a letter to TSA General Manager for GA Brian Delauter. “Currently, both the TSA ‘No Transponder’ waiver and the CBP eAPIS manifest must be generated and submitted to the appropriate agency, causing very redundant tasks for the aircraft operator. The value of general aviation is that of on-demand availability and flexibility. Reducing the redundancy of these federal requirements, while still maintaining a high level of general aviation security, would be invaluable.”

eAPIS manifests must be filed online before each flight, and “no transponder” waivers are good for 90 days. Currently, the international waiver online system requests almost identical information to that submitted through eAPIS. Both ask for information about the pilot; departure; destination; and passengers, such as birth date, Social Security number, and passport number.

Because Mathison flies to his cabin frequently to hunt and fish—he said he has flown about 85 hours this summer—he doesn’t always know ahead of time who will join him for fishing trips over the coming three months. Passenger information filed through the CBP’s eAPIS isn’t shared with the TSA, so he must also list every passenger who might accompany him over three months in the waiver application. “I said wait a minute now, I’m already doing this with APIS,” he said.

Streamlining the “no transponder” waiver/eAPIS process would affect many more pilots than DHS’ July announcement about foreign-registered aircraft. Mathison’s aircraft has a transponder, but he still must request a waiver because distance and terrain make radio contact with flight service or Minneapolis Center unreliable; he cannot count on filing a flight plan or getting a squawk code for the border crossing.

AOPA urged the two agencies to continue their cooperation to streamline international procedures, cooperation that is important to allow the efficient flow of GA traffic and commerce.