Ps are citizens of Saudi Arabia who have used their D certificates to pilot flights abroad, but have not operated Saudi Arabian Airlines flights to the United States in the past nine and four years, respectively. After September 11, 2001, the Transportation Security Administration (TSA) simply promulgated a whole new set of security standards. The new procedures resulted in the revocation of Ps' airman certificates issued by D. This was done without notice and comment. D can now automatically suspend an airman certificate upon notification from the TSA that the pilot posed a security threat. Ps claimed this violated the APA and due process. Ps were designated security threats and claimed that their revocations were not supported by substantial evidence in the record and that they were denied meaningful notice of the evidence against them and a meaningful opportunity to be heard. The NTSB upheld the revocations and Ps appealed.