Leading Edge Strategies

Al-Qaeda “tweets” a panic attack

2011 September 5 by leadingedgestrategies

What does a woman in Mexico tweeting about non-existent school shooting attacks and a government warning about a plot by al-Qaeda to use small, explosives filled aircraft to attack U.S. targets, have in common? They are both efforts to create fear and panic, and to cause us to spend more money to chase our tails.

Click here for story.

Industry reps tell me that the neither the FBI nor DHS have issued guidance or warnings about this latest threat and from the language of the L.A. Times article, it reads similar to previous threats from General Aviation that have been issued.

In the Mexico City incident, individuals falsely tweeted about schools being attacked by gunmen, sending many people into a panic that shut down emergency telephone lines. In the “GA Threats” article, al Qaeda may be trying to achieve the same panic effect. Just by sending out some information that a plan to use GA explosives-laden aircraft to attack U.S. targets is in the works, or even the final stages, while likely not to cause widespread panic, adds to the overall fear factor. It may just fuel a community fire or political fires to put more regulations and restrictions on the GA industry, which alone adds $100 billion in economic impact to the United States.

While regulating general aviation aircraft, or causing higher security requirements (and thus, more cash to be spent) on “securing” general aviation may seem to be a small inconvenience to those outside of the GA industry, it’s one more expense, it’s one more “fear” for us to worry about, it’s one more pinprick, that is slowly eroding our economy and our civil rights.

In 1776 a group of individuals signed a Declaration of Independence. That document proclaimed freedom from oppression. At the time, the oppression was from a specific source. The Declaration though did not come with an expiration date, nor was it specific to one entity doing the oppression. It was a declaration from all forms of oppression, including al Qaeda and any other group or individual that seeks to deny our God given right to choose our destiny.

Removing Security Screening from Airports?

2010 September 21 by leadingedgestrategies

There have been several reports in the news lately of airports across the country having their security screening equipment removed by the TSA.  This is actually pretty common as long as TSA is the owner of the equipment. Prior to 9/11 various entities were responsible for screening and for purchasing screening equipment. The airlines would often buy what they felt was needed, but if the airport wanted more machines than the airlines were willing to pay, then the airport would be footing the bill.

Secrecy is not always bad

2010 April 25 by leadingedgestrategies

There seems to be a bad taste in the public’s mouth anytime someone decides to keep something secret or private. While not condoning the behavior of Tiger Woods or the rest of his ilk (I’m talking about cheaters, not professional golfers here), I’m one of those people that believe that somethings should still be kept private. Particularly when it comes to safety and security.

Even when we were writing the book on aviation security, we knew there were things that were okay to talk about publicly, but there were also things not to include. That’s the case with the recent debate about whether corporate aircraft operators have the right to keep their trips from becoming public. Click here for the USAToday article.

In an editorial response to the article, one citizen wrote in support of making all flight plans public. Others wrote in support of privacy comparing the airways to public roads and noting that we’re not forced to tell people where we’re driving, or when or for what purpose and we shouldn’t be forced to do the same thing when we fly. I agree.

Let’s address the people who think that everything should be public. To the citizen (we’ll call you Sparky, to sort of protect your own name) who talked about how “transparency,” in the post 9/11 world, I say, put your money where your mouth is. Actually, put your personal security where your mouth is. Let’s develop a website that you will be required to update every time you leave your house. You are required to enter the time of departure, where you are going, the time of expected arrival and the duration of your time away from your house. We will name the website, “pleasecomeburlgarizemyhouse.com.”

Sound good Sparky? How’s that transparency thing working out for you now?

The fact is, it’s okay to have some secrets in this world and to keep some things private. Just because someone flies in a private aircraft, doesn’t mean they give up their Constitutional rights, simply because technology is able to track their every movement.

What is the real issue here? An irrational fear that a private aircraft will fall out of the sky on their head if they aren’t able to track it somewhere on the Internet? Hardly. This is likely more about people who don’t have private aircraft or use them, jealous of those who do. Keep in mind, despite the reporting of corporate greed and misdeeds, there are plenty of corporations out there, from small businesses to large multi-national companies, who use private aircraft to save time and money, and likely, are able to employ many more “Sparky’s” of the world, because they are not waiting at a commercial service airport for hours.

Suicide by Small Plane

2010 February 19 by leadingedgestrategies

We’re heard the term before – suicide-by-cop. This is where someone threatens the police with a gun to get the police to kill the individual. On February 18, we witnessed suicide-by-small-plane.

We did not witness a terrorist attack. We barely witnessed an attack on a government building. Had Stack intended on causing mass casualties, he certainly did not pick an effective tool for the job.

He did manage to start a pretty good fire and cause damage to the structure, but a good question to ask here is, what does this say about general aviation security? People throughout the country are asking themselves if they should be worried about threats from small aircraft. Will they become a tool for terrorist attacks?

Let’s answer that by comparing the goals of terrorism and whether they match up with what we saw in Austin?

1. Mass casualties… no.

2. Destruction to an element of the infrastructure, or symbolic or economic target… not really. He hit the IRS building and while it caught fire, this isn’t a symbolic target like the Statue of Liberty, nor does it cause great damage to our nation’s infrastructure. If the target had been the Statue of Liberty, or a large office building on Wall Street. . . well, we can fix the Statue, and firefighters and sprinkler systems can put out a fire of the size we saw yesterday. This was not a Boeing 757 jet.

3. Instill fear in the public… depends on how much fear we want to add.

4. Gain widespread media attention…yes. But then again, Hollywood celebs going through rehab manage to do that all the time. We can decide how much attention we want to give to this.

5. Erode our liberties, change our way of life and cause us to mistrust that our government can protect us. This is where the rubber meets the road. We will have to wait and see whether this type of attack would achieve this objective. Fortunately, whether this objective is achieved is up to us, not the bad guys. The ball is back in our court.

Already Representative Michael McCaul, a Republican from Austin who is on the House Homeland Security Committee is saying that small airplane threats are “…weakness we hope terrorists don’t exploit…this has been on the radar of al-Qaeda and others…it can be done and they may attempt to do the same thing…”

However, the Homeland Security Department’s inspector general last year stated that: private aviation “does not present a serious homeland security vulnerability…” a conclusion that Homeland Security Secretary Janet Napolitano disputes.

Whether we see further erosions of our civil liberties as a result of this is up to our elected officials. I’ve read numerous DHS IG reports and feel they are very well informed and have a good perspective on this issue, despite what Napolitano or Congressman McCaul feel. I don’t believe there is a plan on the terrorist books to use numerous numbers of small general aviation aircraft in some sort of massive attack on the United States.

Let’s keep this in perspective. A guy who was unhappy with life, took his private plane and committed suicide. While tragic, certainly, this type of attack does not achieve the objectives of terrorism, unless we let it.

So what is the solution?

Most people will not like the solution because it is not a simple fix. Nor does the solution lie primarily in aviation security.

In every one of these incidents, whether they are school shootings, business shootings, or what have you, there are pre-incident indicators. In the coming weeks, information will surely come forth from friends, business associates and possibly family members about the problems Stack was having. The pre-incident indicators will manifest and everyone will start putting the pieces together. Hindsight will become 20/20 and many people will start to wonder why he wasn’t red flagged before.

As I told a reporter today, general aviation security is not new. We were teaching airport operators back in the 1980s and 1990s to watch for signs of aircraft being used in drug smuggling. In fact, I still have my old drug investigators guide — the only thing that’s really changed is the threat. Rather than drug smuggling airport operators, airport employees and tenants need to be trained to recognize suspicious activity. But this may still not stop the next suicide-by-plane, or even a potential attack from a GA airport. Keep in mind that there are many small airports throughout the U.S. that are not regularly staffed with any sort of airport manager. Many of these smaller airports are operated by cities and counties and may have a public works employee assigned to occasionally drop by to make sure things are okay.

So, we get back to pre-incident indicators. Basic workplace violence recognition training just may well be the solution to this “threat.” There are always signs. There are always pre-incident indicators. There are always opportunities to identify the threat ahead of time and report it to authorities.

Is this the 100% perfect solution? No. Of course not. But it’s better than throwing billions of dollars into small aircraft security measures that ultimately are not only ineffective but help fulfill the goals of terrorism.

OIG’s New Report on general aviation security threats

2009 June 19 by leadingedgestrategies

The Office of the Inspector General released it’s report on TSA’s Role in General Aviation Security (click here for copy). In it, the Inspector General noted that the terrorism threat posed by general aviation aircraft is “limited and mostly hypothetical…the current status of [general aviation] operations does not present a serious homeland security vulnerability requiring TSA to increase regulatory oversight of the industry.”

Further: ”Although [TSA's Office of Intelligence] has identified potential threats, it has concluded that most [general aviation] aircraft are too light to inflict significant damage, and has not identified specific imminent threats from [general aviation] aircraft,” the IG stated.

The report comes at a good time for those in the general aviation industry. With the recent controversy over the Notice of Proposed Rulemaking on the Large Aircraft Security Program (LASP) and a record-setting 7,500+ comments that were received, most all opposing the program, general aviation operators were looking for validation that their aircraft do not pose a significant security threat. Part of that evidence may have been found in TSA’s throw-weight study, which looked at fuel loads and aircraft weight and speed to determine the potential for damage from GA planes. The results of that study have been classified by TSA and not released to the public. However, independent investigations have demonstrated that the majority of GA aircraft pose a significantly lesser risk than the larger commercial service aircraft – a finding that would certainly weaken the LASP argument to apply  commercial service level security requirements to general aviation operations.

Currently, aircraft charter or scheduled service operators using planes that weigh more than 12,500 lbs are required to adhere to TSA approved security programs and take certain measures as outlined in Title 49 CFR Part 1544 and 1550. The LASP would add privately operated aircraft the list of those requiring TSA approved security programs and practices. However, of debate is the weight threshold of 12,500 lbs itself. The selection of 12,500 lbs is based not on a security concern. The FAA considers large aircraft to be above 12,500 lbs and a pilot of such an aircraft must have  type rating. I guess this seemed like a convenient number to use at the time since it was not based on scientific research on what combination of weight, size and speed are capable of causing significant damage to a structure.

While the report largely exonerates the GA industry from a security threat perspective, the OIG report also stated: “…the potential for a terrorist group to use GA aircraft to conduct an attack remains a possibility that cannot be ignored.” That said, the report concluded by saying:  ”…there is no specific, credible information of ongoing plots to use GA in an attack in the near future.”

Page 3 of the OIG report notes: In its November 2004 review, General Aviation:  Increased Federal Oversight Is Needed, but Continued Partnership with the Private Sector Is Critical to Long-Term Success (GAO-05-144), the Government Accountability Office (GAO) concluded that “the small size, lack of fuel capacity, and minimal destructive power of most general aviation aircraft make them unattractive to terrorists, and thereby, reduce the possibility of threat associated with their misuse.

In January 2008, the Congressional Research Service reported that typical GA aircraft are too light to use as a platform for conventional explosives.  Moreover, heightened vigilance among airport operators and pilots would make it difficult to load the necessary quantity of explosives without detection.”

Page 14 notes: “Although OI has identified potential threats, it has concluded that most GA aircraft are too light to inflict significant damage, and has not identified specific imminent threats from GA aircraft.  OI has also concluded that there is no credible threat of crop-dusting aircraft being used to spread chemical or biological agents.  However, OI noted that various intelligence sources have identified helicopters as aircraft of ongoing interest to terrorists. OI also stated that the potential for a terrorist group to use GA aircraft to conduct an attack remains a possibility that cannot be ignored. “

SPECIAL NOTE: this author recently completed an article on helicopter and heliport security for Aviation Security International magazine. I will make a copy of the report available soon.

So what does this all mean? Should we now ignore any risk from general aviation? No. The OIG report states that there is potential and individuals and groups have attempted and assessed the use of GA as a weapon. But, it should mean that the NPRM on the LASP is either largely unnecessary or in need of serious revision. My understanding from my sources tell me that TSA is likely to sit down with industry and begin work on a new program altogether. TSA has been insistent that their systems, methods and procedures are based on risk assessments. I believe now it is time to see if they will practice what they preach.

Keep in mind that with this report, some may look at it from the perspective of “now that their guard is down, let’s figure out how to do something with general aviation.” The OIG report did stress that airport and aircraft operators should continue to follow the best practices guidance for securing their respective facilities and aircraft.

NOTE: General aviation accounts for 77% of all flights in the United States and is a vital component of the national economy.  It includes the very large air cargo transport sector, air medical-ambulance operations, flight schools, corporate aviation, and privately owned aircraft.  General aviation activity frequently takes place alongside scheduled airline operations at large commercial airports, as well as at more than 5,000 public use airports, almost all of which serve general aviation exclusively.

Okay, now panic

2009 April 7 by leadingedgestrategies

The Denver Post reported today about the impacts of Security Directive 08F on several small commercial service airports in Colorado. To view the article, click here.

DISCLOSURE: Since 08F is a Security Directive and by nature, is Sensitive Security Information, I will not divulge any information here that has not already appeared in the Denver Post article, but will use what is now in the public domain, combined with what is in the Practical Aviation Security book, to explain what is happening to the small commercial service airports.

The article focused on the fact that TSA is now requiring small airports with fixed-base operators and private aircraft operations to badge personnel and start escorting un-badged transient pilots and passengers in certain Security Areas, as a result of 08F. Essentially, this extends the badging requirement normally associated with the Secured Area and the Security Identification Display Area to the Air Operations Area (AOA) with some exceptions.

At many commercial service airports the general aviation areas such as private hangars, fixed-base operators, maintenance shops, flight schools, etc., are designated to be in the AOA, while the commercial service areas are designated to be in the Secured Area. Airport operators were required to use systems, methods and procedures approved by the TSA to ensure that personnel in the AOA do not transit into the Secured Area. And, up until now, AOA’s did not have badging requirements unless so desired by the airport operator. For full descriptors of the aforementioned Security Areas and their baseline regulatory requirements, please see Chapter 5 in Practical Aviation Security. I have also included a vocabulary lesson at the end of this entry for those less familiar with the terminology.

Under the new requirements, now, commercial service airports of any size with designated Security Areas, will be required to badge and conduct Security Threat Assessments on personnel working in the AOA’s. Not part of the requirement is a full fingerprint-based Criminal History Record Check (which is the requirement for badges in the Secured Area and SIDA), which would be far more costly. As it is, the cost of badging hundreds of personnel who normally would not have to be badged, may prove to be burdensome on the small commercial airport operator. This is definitely causing administrative burdens to the smaller airports that generally have much smaller staffs.

Some airports may be able to get relief by switching to supporting security programs (without Security Areas), but it depends on the size and nature of their commercial aircraft operations. Larger aircraft require the complete security programs, which require Security Areas to be designated. 

Background and Clarification: for those of you who are less familiar with airport security, here is a basic primer to help you understand what’s going on here.

First, most commercial service airports have general aviation areas. Despite what the Post article says, even Denver International Airport has a general aviation area. Signature Flight Support has been DIA’s fixed-base operator since the airport opened in 1995. A fixed-base operator (FBO) is similar to a truck stop for private aircraft. Somewhere to get fuel, minor services such as catering, oils, drop off and pick up passengers, etc. Other private operators include flight schools, private corporate operators, charters, and small personal aircraft hangars. 

Previous to this change (08F), GA operators on commercial service airports would usually be in an area designated as an AOA – Air Operations Area. This meant that there were lesser security requirements in those areas, versus the higher requirements associated with activities surrounding the commercial service operations. This change means that operations in the AOA will now have increased security requirements, costs, etc.

Also, an individual in the Post article questioned why there cannot be a universal badge. This has been a long time industry challenge. Nearly all airport access control systems are proprietary and unique in nature – a badge issued at one airport will not work at another. A security benefit to this is that a badge stolen or lost at one airport, only works at that one airport, not throughout the entire aviation system. Since most badges are not (presently) biometric, badging systems do not know who is actually using a badge. However, TSA is encouraging that airport badges incorporate biometrics.

In the Aviation and Transportation Security Act of 2001, the Transportation Worker Identification Credential (TWIC) was promulgated. TWIC is intended to be a universal IDENTIFICATION (note: not ACCESS but I.D.) system for those working in the transportation industry. TWIC has not gotten traction in the aviation industry due to the numerous access control systems that may have to be modified to accept this new identification. However, if TWIC is truly just for ID and not access, then most of the commercial service airports would only have to accept the new ID without changing their access control systems. There are other examples of this such as with the FAA 110A identification form, TSA inspection personnel, air carrier personnel and others.

TWIC has gained traction in the maritime industry and aviation rumor mills say it’s coming to the airport industry at some point.

With TSA’s movement towards the Large Aircraft Security Program, and now including Security Threat Assessments for individuals in the AOA (general aviation areas), I’m going to make a bold prediction. I believe that eventually we will see TWIC in the aviation industry and that it will be grudgingly welcomed as a solution to many of the problems the small airports are now seeing with these new requirements. 

Stay tuned.

Don’t Panic!

2009 April 2 by leadingedgestrategies

Seems the GA community is in an uproar because some GA Fixed-Base Operators at some commercial service airports have experienced TSA’s new Playbook program. 

See the article here: http://www.avjobsweekly.com/enews/content.asp?bm=472

What the operators have experienced is a common anti-terrorism measure that is used by police agencies, security personnel and counterterrorism agencies throughout the world. Often known as Random Anti-Terrorism Measures (RAM – the term we used in the textbook) are used to disrupt surveillance and possibly disrupt actual criminal activity. You won’t get a copy of any RAM program – or “Playbook” as TSA has termed it, because to make public these procedures would be the eqivalent of handing out the security code for your home alarm security system.

While the GA world may be worried about this perceived invasion, it is part of an approved security program under Title 49 CFR Part 1542 and the Airport Security Program for a commercial service airport. The FBO’s on a commercial service airport sit either in the Air Operations Area, the Security Identification Display Area or the Secured Area of the airport and are therefore subject to regulatory influences.

Before you panic too much about this incident occurring at a General Aviation airport, keep in mind that currently, commercial service airports are not regulated under Part 1542 the way commercial service airports are. Granted, if the Large Aircraft Security Program goes through, then that could change at some GA airports.

What are the real problems with regulating private aircraft?

2009 February 1 by leadingedgestrategies

With the mantra, “in the name of homeland security,” still frequently being hauled out to justify both good and bad ideas, let’s look at the latest measures proposed by the TSA – the Large Aircraft Security Program. 

Many who do not own private aircraft have no problem at all with the government restricting their use. However, let’s take a look at the issues at stake.

If you’re not familiar with what the LASP will do, this paragraph from Aviation Week’s website, sums it up nicely:

If implemented, LASP will expand commercial air carrier-like security requirements to apply to all Part 91 operations of U.S.-registered private aircraft with maximum takeoff weights greater than 12,500 lb. Operators would have to develop an approved security program, fingerprint and conduct background checks for pilots, vet each passenger prior to each flight against a TSA terrorist threat watch, undergo a 24-month audit performed by a third-party auditor, prohibit carriage of most tools, equipment and sporting gear in the cabin, and even carry armed sky marshals in some cases.

http://www.aviationweek.com/aw/generic/story_channel.jsp?channel=busav&id=news/TSA01279.xml 

First, the United States remains one of the few countries in the world where general aviation is affordable. With powered flight being invented here in the U.S. we’re still pretty tied into the ability of Joe Aviator being able to fly a private aircraft, just the way everyone else drives a car. GA is vital to flight training, the livelihood of many businesses, and the way in which it draws our future aviators. If you’re looking for justification about why GA should continue to exist in the U.S., read my book. Let’s assume you either have, or are on board that GA needs to continue thriving in the U.S.

So, why then should we oppose the regulation of private aircraft? Seems like a good enough idea on it’s surface but is it really? After all, we regulate the commercial airline industry – what’s the difference? Allow me to illustrate. Most of us drive a car and many of us own our own cars. The government provides us a licensing process and rules of the road and then pretty much let’s us go from there. They don’t even require us to come in and prove we can still drive for the rest of our lives. With the exception of a few “can’t use your cell phone while driving” laws some of the states have passed this is about the extent of regulations on what goes on in a private car. You can carry who you want, when you want and where you want without the government interfering in the process. You do not need to pass a criminal history background check to receive your license either (keep in mind that pilots already need to prove their citizenship and receive annual flight checks to ensure they can still fly a plane safely). 

Also remember that it was a rental truck that was used to vaporize half a building in Oklahoma City in 1995, not a small plane, and it was a rental van that was used to attack the World Trade Center the first time. Yet, there was no push for sweeping regulations in the rental truck industry – like criminal background checks for renters, screening of passengers and cargo carried on board, etc.

If we were to apply the regulations outlined in the LASP to driving your car, let’s see what driving your car would look like. First, if your car was under a certain weight, you’d be exempt from the regulations. If you had a large car, like an SUV or pick-up truck, then you would have to pass a fingerprint-based criminal history record check in order to drive (in addition to your drivers’ test), and a security threat assessment – either of which could come back negative and you would not be allowed to drive. 

Next, your passengers would have to be screened. You or someone that works for you would have to be trained in screening. You would have to have a security program approved by the TSA. The TSA could at any time come inspect your procedures to make sure you are in compliance – without due process and without warning. The government would restrict you from carrying certain items in your car – things that could be used as a weapon but things you may need in case of an emergency. Federal marshals could be placed in your private car and you would not have a say in the matter. If one of your passengers, like your kids, had to be bumped out of the seat for a FAM to sit there, well, so be it– you can either drive or not. Your choice. By the way, this process may violate the Third Amendment to the U.S. Constitution regarding the quartering of troops. All of this would be at your own cost.

A third-party would also be used to come verify that you are following the proper procedures. You will pay for this periodic assessment too.

Next, places that you visit, like grocery stores, your friends and families homes, would have to be equipped with expensive security screening technology so that they could screen passengers that you would carry upon leaving those locations – including the people you brought with you in the first place. They may also have to take additional security measures because you want to drive your truck to their house or place of business. You would also have to bear some or all of this cost. 

Okay – get the point yet? I know, I know, you’re still arguing that there is a difference with airplanes versus trucks. I’m the first to agree that small planes could and have been used in attacks, real, fictional and plotted, so we should do something – and we have been. We’ve done quite a bit. But the regulations in the LASP would likely cause thousands of people to park their planes and possibly close airports – job losses would be in the tens of thousands and possibily hundreds of thousands when you take into account all of the businesses that benefit from airports and air travel . There goes essential economic drivers and key services like doctors using the private aircraft to service remote towns; sales people using private aircraft to service accounts – they can always get a another job, right? There goes the youth learning to fly so they can have a career in the airline or air cargo industry – which incidentally, connects us to the global economy.

 We’re talking about private conveyance here. Not commercial conveyance. In commercial conveyance, you largely do not know who you are carrying and that makes all the difference.

I’m not going to debate whether TSA has information that suspects there could be an attack from general aviation. We’ll assume they either do, or that it’s a good idea to protect our industry, before something bad happens that is tied into GA and Congress moves to shut down our industry.

What I am encouraging is that TSA go back to the drawing board and just like they did with the Security Guidelines for General Aviation Airports, sit down with the industry and work together on a set of regulations that are both affordable, effective and make sense.

Olislagers Speaks at TSA LASP Forum

2009 January 30 by leadingedgestrategies

Speaking on behalf of the American Association of Airport Executives, the State of Colorado and Centennial Airport (the nation’s 3rd busiest general aviation airport), airport director Robert Olislagers spoke at the TSA public forum in Houston on the Large Aircraft Security Program.

Olislagers took issue that the GA industry is mostly unregulated and that it presents a risk necessitating the LASP rulemaking. He noted that it appears that TSA issued the NPRM without a comprehensive vulnerability assessment of the GA industry; an assessment that also takes into account the security measures that the GA industry has voluntarily taken.

Another significant issue is that the TSA’s cost analysis on implementation of the program is not based on any actual airport or aircraft operator. AAAE has conducted such analysis and has come up with costs far exceeding TSA’s estimates.

Finally, another point of contention, particulary from the airport side, is that compliance with the LASP may force some airports to become non-compliant with their grant assurances and lose their federal funding.

What we do not know is whether any of this commentary, here and elsewhere, will have any significant impact on the NPRM, or will TSA just nod politely, say thanks for the input and then implement this rule later this year.

So where do I sit on this? First, Robert Olislagers is a rock star in the airport industry. When he speaks, people listen, or at least they should. He is a expert on general aviation security and the director of one of the biggest GA airports in the country where they have pioneered several security initiatives.  We know that no system is 100% secure; however, even knowing that we still must apply security measures and systems to try to make the bad guys go somewhere else. The real question here, is: does the Large Aircraft Security Program actually do that?

Obama puts the brakes on LASP NPRM…for now

2009 January 22 by leadingedgestrategies

With a memorandum issued this morning, President Barack Obama has put the brakes on all regulations and rulemaking that is in progress, until an Obama appointee or designee reviews and approves any new or pending regulations.

The White House memo did not specifically call out the GA LASP but it looks like this will at least extend the comment period by another 60 days.