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International Air Transport Association

By:  David O'Connor

International Air Transport Association

There are several points below I would ask you to consider as you review Recommended Practice (RP) 1740c, which is pending in Docket OST-2001-9583. As you know, RP 1740c recommends using a radio frequency of 13.56 MHz to identify and track bags. RFID tags will be a substantial improvement over the current bar-coded paper tags, which aren't readable if the paper gets wet, the ink is weak or the label is upside down.

As new technologies emerge in the years to come, IATA airlines could choose to update this recommendation as they can with all of our standards. But it has taken nine years-and many IATA meetings around the world-for the global airline industry to reach agreement on this frequency standard. They reviewed and debated many factorsreliability and costs chief among them-before finally selecting this recommended standard.

The FAA official in Atlantic City who was invited to participate in the IATA RF Working Group meetings has been privy to reams of test data that substantiate the airlines' choice of frequency. He has even contributed to that information. If he now has suddenly obtained disparaging information about the use of 13.56 MHz, he should make that information available to IATA and its member airlines who have worked so diligently on this worthy project. Otherwise, we would respectfully ask that he refrain from his secretive and destructive tactics to undo what has taken years to complete.

Aviation security and convenience has never been more critical, especially if positive baggage matching is mandated. This project needs to move forward. We would urge you to act quickly on all provisions contained in this agreement, which was submitted to the Department last April. If this particular provision will continue to delay issuance of an order, we would ask that you sever it from the package and act on it separately so as not to further delay action on the other Resolutions and Recommended Practices that were adopted.

By:  Wanda Warner

International Air Transport Association

By:  Read Van de Water

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