Security and the 300-Foot Rule
The Parking Industry is 'Ground Zero'
Following is an interview with Dale Denda, chief of research for the Parking Market Research Company by PT editor John Van Horn. He has been closely following the events dealing with the FAA, the 300-foot rule and the effects of 9/11 on the parking industry in general. The so called 300-foot rule basically says that cars can't be parked within 300 feet of a terminal building without special dispensation from the FAA -- this dispensation varies from airport to airport. Denda can be reached at email@example.com.
PT: Is the 300-foot rule really effective, given that unsearched vehicles commercial and private, can simply drive up to the front of the terminal and given that terrorists are suicidal? Why couldn't a bomb be put in the back of a taxi, driven up to the front of a terminal, parked, and the driver get out, walk 301 feet away, and detonate it? Shades of Oklahoma City.
Denda: That' s right. Federal rules that have come down at airports are nonsense in that they don't take into account the contradictions they involve toward the stated goal which, by the way, is the integrity of the terminal building in the event of an attack. Allowing terminal curbside drop off from vehicles not cleared by the same onerous search requirements that are part of the closure of close-in parking, which hit airport operators so hard, is indefensible. The issue becomes why such a dysfunctional scheme hasn't fallen on its own contradictions, which it has not, and why additional measures for relief will now have to be the focus of airport design for the foreseeable future.
PT: Are the terminal buildings at airports, or airports in general, truly targets give that we have never seen one blown up or even attacked?
Denda: Barring a return of Croatian irredentism which resulted in a series of small bombings at JFK Airport in the late 1970s, the relative risk at an airport is, based on readily available information, no greater than at any one of a very large number of venues. The question refers to federal regulations for airport parking, which occurs on the land side. Other very real targets, in fact, include signature office buildings, monuments, certain prominent landmarks and regional shopping malls.
I think the current focus on airports is an unfortunate distraction, particularly from the parking industry's perspective, because the stakes are really so much greater. What could be termed now as a cottage industry in security planning at virtually every federal office, agency, bureau and center, would, if another attack occurs, burst out into the open, and impact multiple areas of economic activity. In short, wherever the next event occurs will define the next area of federal response.
The question becomes, From what sector of commercial activity is vehicle parking excluded? Put differently, the common denominator in security and design criteria documents I have seen, interestingly enough, is inevitably expressing the blast assumption (an arithmetic value) in terms of the size of the vehicle necessary to hold that amount of explosives. The reason for this is pretty fundamental -- a vehicle is a natural means of concealment of any larger quantity of conventional explosives. However, there is otherwise nothing unique about airport parking. Whether we like it or not, the parking industry is at ground zero in this situation.
PT: If we do agree that airports are targets, isn't searching vehicles and having off-airport parking and drop off sites a better solution than rebuilding all the parking at airports?
Denda: If we assume that a significantly catastrophic threat exists at airports, the day may come when on-airport parking is judged to be too hazardous and is severely restricted. At that point, there will be a potential boom in off-airport facilities. However, in the interim, the piecemeal approach mandated by FAA with regards to airport land side security is the reality. Certain costly provisions now under discussion, such as construction of blast walls around parking garages, clearly are counterproductive, I believe, even under the FAA's own modeling. On the other hand, there is probably a big decision to reach in certain sectors, like airports, about basic garage frame design in terms of blast durability. This is like the point the Port Authority of New York/New Jersey was at in the mid-1990s following the earlier bombing of the WTC, when they opted for a blast (collapse) resistant design in the form of steel framing for parking garages.
PT: Has anyone done a "risk versus value" study? Or are we simply saying that we should take no risk, no matter what the cost?
Denda: That's the realm of the security community folks, and they don't like to be quoted. However, what little specifics they have gone public with clearly suggest that certain conclusions point to risks at places other than airports. In terms of the FAA airport parking rules, one New York-based security analyst who reviewed the requirements said flatly: "The assumptions of the attack (occurring in the parking garage) are incorrect."
PT: What is the appropriate response for the parking industry to this FAA 300-foot rule?
Denda: The specifics of that, of course, need to be addressed. But I think we will get to that point a lot quicker if we understand the cost of not acting. Allowing the FAA mandates to stand will basically set a tone in all FAA contacts -- i.e., the rules of engagement down there are pretty one-sided as it stands. It appears as if the new TSA may have even more power. Any argument that says avoid a public challenge to this just does not add up--and sounds a lot like a fig leaf for business as usual, toward maintaining access to useful contacts.
PT: Should the parking industry or airports expect compensation from the government for losses based traffic reductions after 9/11? And as a follow- up question, should the parking operators/airports expect compensation for losses due to the imposition of the 300- foot rule or other security requirements?
Denda: No, and yes. The situation immediately following the attacks was, by all accounts, unique. The real threat level was not known, and virtually every conceivable measure probably was justified. Losses due to the resulting dramatic drop in air travel were and continue to be unavoidable and should not be compensated. Once the situation was assessed, however, probably by late November, that condition changed. I believe that losses taken by airport parking operators due to federal mandates as of that date should be subject to compensation. The current proposal in the November law is too modest.
PT: Doesn't the airport security issue seem to take on a political tone, more to cover one's rear, than a practical discussion about security at America's airports?
Denda: A time-honored Washington bureaucratic tradition is to wrap oneself in the mantel of "the public good" -- read "public safety" -- when a tenuous policy needs to be justified. More fundamentally, this is business as usual in Washington. The given agency, in this case the FAA and now the emerging TSA, has one requirement: Protect itself. That is, it needs to be able to point to a policy or action to justify itself should another event occur and any number of people perish. Whether those measures proposed are rational or sound, how-ever, is an entirely different question.
Look, this situation has all the qualities of a "Do something, do anything, but do it now" policy. Certain agencies felt extremely vulnerable on September 12 because of the nearly decade long debate on air travel safety which bore so little fruit. That debate, it should be noted, did not include shutting down close-in terminal parking as a permanent measure.
Actually, the terminal perimeter parking policy is part of the same paradigm that put National Guardsmen, some without ammunition in their weapons, into airports. That was virtually pure window-dressing to mollify the traveling public. Likewise the parking limits are designed, at least in part, to make people feel more secure while in terminals.
This is very regrettable because there are bright and good-intentioned people at FAA; however, they are operating in a "limit-liability mode" and that mindset can take on a life of its own.
PT: If the parking industry wants to do something about the 300-foot rule and perhaps compensation, what would be the best tact to take?
Denda: We need to ensure that what has happened -- rule making without input from those who understand the practical reality and costs of implementing this stuff -- never happens again. The federal response to terrorist threats runs the risk of dwarfing the direct costs of Sepember 11. Disclosure of those costs, and other economic implications which ultimately will be borne by the consumer without a demonstrable increase in security to the public, is the only way in which this rule making will be stopped. That message has to be delivered to the right ears in Washington.
It is the same pot we at the mercy of for capital construction is being dipped into for at least a portion of the security measures. We need to ensure that the money is being rationally spent, as opposed meeting some PR or political requirement for "enhanced security" on the part of a public agency.
We've heard the refrain recently, "Price of freedom, cost of liberty". We need to make sure that the real numbers associated with federal policy do not exact a lopsided cost from the parking industry for whatever Washington has in mind. Getting that message in the right door will take some skill.
The first step for the industry may be to revisit our own mindset. The first reaction by some after September 11 was "Let's sit tight. We've seen this before. It'll blow over." In other words, the assumption was that the restrictions would go away once the excitement dies down. The wake up call came when we heard that these restrictions are viewed as minimal measures and, at least as a baseline policy, are not going away.
At a minimum, a task force should be set up to respond to, or more to the point, initiate contact regarding the vacuum of information in which this rule making is taking place at the federal level. This has to be a one-step process that anticipates new wrinkles will come up in a complex, evolving situation. It should be for a minimum one-year term, with the endorsement of the associations. There are, in fact, airports right now out there looking for such an industry response.
PT: How's the industry response been so far?
Denda: That's not a fair question... because it's loaded. But I guess one has to acknowledge that it's loaded in favor of a few firms that have taken the lead in looking at this federal rule making nonsense.
Article Abstract from February, 2002