Report to the Ranking Democratic 

Member, Committee on Transportation 

and Infrastructure, House of 

Representatives 

United States Government Accountability Office

GAO

September 2005 TRANSPORTATION 

SECURITY 

ADMINISTRATION 

More Clarity on the 

Authority of Federal 

Security Directors Is 

Needed 

GAO-05-935 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-935.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Cathleen 

Berrick at (202) 512-8777 or 

Berrickc@gao.gov. 

Highlights of GAO-05-935, a report to the 

Ranking Democratic Member, Committee 

on Transportation and Infrastructure, 

House of Representatives 

September 2005

TRANSPORTATION SECURITY 

ADMINISTRATION 

More Clarity on the Authority of Federal 

Security Directors Is Needed 

TSA has issued guidance that clearly defines FSDs’ roles and responsibilities.

However, TSA’s guidance related to FSDs’ authority is outdated and lacks 

clarity regarding FSD authority relative to other airport stakeholders. TSA’s 

document that delegates authority to FSDs gives them authority to supervise 

and deploy a TSA law enforcement force that was never established. Also, it 

does not clearly address FSD authority during a security incident relative to 

other parties with airport security responsibilities. At airports GAO visited, 

stakeholders said that this information had never been communicated to 

them and they were not always clear on the FSDs’ authority in such 

situations. For example, confusion arose at one airport over whether the 

FSD had the authority to take certain actions during a security incident. In 

August 2005, TSA officials stated that they were updating guidance on FSDs’ 

authority but had not finalized their revisions prior to this report’s issuance.

All of the FSDs and most stakeholders at the airports GAO visited reported 

developing partnerships that were generally working well. Communication 

and coordination were taking place among stakeholders at these airports, 

including meetings, briefings, and training exercises. According to TSA, 

partnerships with airport stakeholders are essential to FSDs’ success in 

addressing aviation security and customer service needs. For example, FSDs 

rely on law enforcement stakeholders during security incidents since they do 

not have their own law enforcement resources. FSDs also rely on air carriers 

for passenger volume information to schedule screeners, and air carriers rely 

on FSDs for efficient screening that minimizes passenger wait times. 

TSA made changes in 2004 to better support or empower the FSD position, 

and most of the 25 FSDs we interviewed generally viewed these changes 

favorably. For example, most of the FSDs we interviewed were satisfied with 

TSA’s new local hiring process that provided more options for FSDs to be 

involved in hiring screeners, and most said that the new process was better 

than the more centralized hiring process it replaced. Most FSDs we 

interviewed also saw value in the headquarters group TSA established to 

provide operational support to the field and a communication link among 

headquarters, field-based Area Directors, and FSDs. 

Number of FSD Positions Dedicated to One Airport or Multiple Airports, as of January 2005 

The Transportation Security 

Administration (TSA) assigned 

Federal Security Directors (FSD) to 

oversee security, including the 

screening of passengers and their 

baggage, at the nation's more than 

440 commercial airports. FSDs 

must work closely with 

stakeholders to ensure that airports 

are adequately protected and 

prepared in the event of a terrorist 

attack. This report addresses (1) 

the roles and responsibilities of 

FSDs and the clarity of their 

authority relative to that of other 

airport stakeholders during 

security incidents, (2) the extent to 

which FSDs formed and facilitated 

partnerships with airport 

stakeholders, and (3) FSDs’ views 

of key changes TSA made to better 

support or empower the FSD 

position. 

What GAO Recommends

GAO recommends that the 

Secretary of Homeland Security 

direct TSA to update its Delegation 

of Authority to FSDs and 

communicate this information to

FSDs and airport stakeholders. 

The Department of Homeland 

Security generally concurred with 

GAO’s findings and 

recommendations and described 

corrective actions that it has 

initiated or plans to take to address 

the issues identified. 
Page i GAO-05-935 Aviation Security 

Letter 1

Results in Brief 3 

Background 6 

Federal Security Directors Have a Range of Responsibilities, but 

TSA’s Guidance Regarding FSDs’ Authority Is Unclear 13 

TSA Provided Opportunities for Some FSDs to Participate in 

Developing TSA Aviation Security Policy 19 

FSDs Formed Partnerships with Key Stakeholders and Participated 

in Communication and Coordination Efforts 21 

TSA Made Changes to Better Support or Empower the FSD 

Position and Was Planning Additional Changes 27 

Conclusions 36 

Recommendations for Executive Action 36 

Agency Comments and Our Evaluation 37 

Appendix I Objective, Scope, and Methodology 39 

Appendix II Responses to Selected Questions from Interviews 

with 25 Federal Security Directors 43 

Appendix III Comments from the Department of Homeland 

Security 53 

Appendix IV GAO Contact and Staff Acknowledgments 55 

Figures 

Figure 1: Transportation Security Administration Organization 

Chart 9 

Figure 2: Commercial Airports by Airport Security Category, as of 

January 2005 11 

Figure 3: Number of FSD Positions with Responsibility for a 

Designated Number of Airports, as of January 2005 12 

Contents 
Page ii GAO-05-935 Aviation Security 

Abbreviations 

ATSA Aviation and Transportation Security Act 

BTS Border and Transportation Security 

CBP Customs and Border Protection 

DHS Department of Homeland Security 

DOT Department of Transportation 

FBI Federal Bureau of Investigation 

FSD Federal Security Director 

ICE Immigration and Customs Enforcement 

MANPADS Man Portable Air Defense System 

TSA Transportation Security Administration 

TSES Transportation Senior Executive Service 

This is a work of the U.S. government and is not subject to copyright protection in the 

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permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-935 Aviation Security 

September 23, 2005 

The Honorable James L. Oberstar 

Ranking Democratic Member 

Committee on Transportation and Infrastructure 

House of Representatives 

Dear Mr. Oberstar: 

Federal Security Directors (FSD) are the ranking Transportation Security 

Administration (TSA) authorities responsible for leading and coordinating 

TSA security activities at the nation’s more than 440 commercial airports. 

During 2002, the first year FSDs were assigned to airports, FSDs worked to 

meet deadlines associated with screening, including deploying over 55,000 

passenger and baggage screeners and screening checked baggage using 

explosive detection systems. As a part of their security responsibilities, 

FSDs must coordinate closely with airport and air carrier officials, local 

law enforcement, and emergency response officials to ensure that airports 

are adequately protected and prepared in the event of a terrorist attack. 

FSDs’ success in sustaining and ensuring the effectiveness of aviation 

security efforts are dependent on their ability to develop and maintain 

effective partnerships with these stakeholders. 

In March 2004, after FSDs had been deployed at airports for over 2 years, 

we surveyed all 155 FSDs at that time and learned that most thought they 

needed certain additional authorities and flexibilities to better address 

airport staffing and security needs. Since that survey, TSA has taken steps 

to enhance FSDs’ authority and provide flexibilities in certain areas. To 

provide additional information on the ability of FSDs to address airport 

security needs, this report addresses the following questions: (1) What are 

the roles and the responsibilities of FSDs and how clear is their authority 

relative to that of other airport stakeholders during security incidents? (2) 

To what extent are FSDs involved in the development of TSA aviation 

security policy? (3) How have FSDs at selected airports formed and 

facilitated partnerships with airport stakeholders, and how are these 

partnerships working? (4) What key changes has TSA made or planned to 

make to better support or empower the FSD position, and how have 

selected FSDs viewed these efforts? 

To address these questions, we interviewed TSA’s Chief Operating Officer 

and officials from TSA’s Aviation Security Program Office, Office of Law 

Enforcement, Office of Compliance Programs, and Office of Human 

 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-935 Aviation Security 

Resources, and we reviewed relevant laws and TSA documentation related 

to the FSD position. To obtain additional views on the role of the FSD and 

FSD-stakeholder partnerships, we met with headquarters officials from the 

Department of Homeland Security’s (DHS) Border and Transportation 

Security Directorate (BTS),1

 and the Federal Bureau of Investigation’s 

(FBI) Counter-Terrorism and Criminal Investigations Divisions. We also 

met with officials from national organizations representing airports (the 

American Association of Airport Executives and the Airports Council 

International), airport law enforcement officials (the Airport Law 

Enforcement Agencies Network), and air carriers (the Air Transport 

Association). We conducted site visits to seven airports. We selected these 

airports because they incorporated all five airport security categories2

—

three airports with an FSD dedicated solely to each airport, and two sets 

of airports where the FSD was responsible for at least two airports. At 

each airport, we met with the FSD (five in total) or the top-ranking TSA 

official, as well as the Assistant FSDs for Law Enforcement and Regulatory 

Inspection, where these positions existed. During our meetings with FSDs, 

we obtained their views on changes TSA made to further enhance the FSD 

position, as well as views on their roles and responsibilities and 

perspectives on their partnerships with local stakeholders. At airports, we 

also met with key stakeholders—airport managers, airport law 

enforcement, station managers representing selected air carriers, and FBI 

Airport Liaison Agents and officials from DHS’s Customs and Border 

Protection (CBP) and Immigration and Customs Enforcement (ICE) (at 

the two international airports we visited) to obtain their views on the roles 

and responsibilities of the FSD and partnerships and communication 

mechanisms with FSDs. 

To corroborate and expand on what we learned from the FSDs we 

interviewed during our site visits, we randomly selected 25 additional 

FSDs and telephoned them to obtain their views on a range of topics 

including recent TSA initiatives and the development of federal aviation 

security policy. We also included selected questions—regarding the 

 1

 BTS, one of five operational directorates within DHS, is tasked with securing the nation’s 

borders and safeguarding its transportation infrastructure. TSA is part of the BTS 

organization. As part of his July 2005 announcement to reorganize the department, the 

Secretary of DHS proposed the dissolution of BTS, pending the enactment of legislation to 

effect this change. 

2

 TSA classifies commercial airports in five airport security categories based on factors 

such as the number of takeoffs and landings, the extent of passenger screening, and other 

security considerations. 
Page 3 GAO-05-935 Aviation Security 

adequacy of the FSDs’ authority and flexibility—that we had posed earlier, 

in a March 2004 Web-based survey of all 155 FSDs in place at that time 

conducted in support of other aviation security reviews. Of the 25 FSDs 

we interviewed by telephone as part of this review, 21 were FSDs at the 

time of that Web-based survey and, as such, responded to both. The 

information we obtained during our seven airport visits and telephone 

interviews with 25 FSDs cannot be generalized to all airports and FSDs 

across the nation. 

We conducted our work from August 2004 through September 2005 in 

accordance with generally accepted government auditing standards. 

Appendix I contains more details about our scope and methodology. 

TSA developed guidance that describes the roles and responsibilities of 

the FSD position, such as ensuring overall aviation security, providing 

regulatory oversight, implementing policy, and managing stakeholder 

relationships. However, the document that specifically describes the FSDs’ 

authority—TSA’s Delegation of Authority to FSDs—is outdated, does not 

clearly address the extent of FSD authority relative to other airport 

stakeholders, and has not been adequately communicated to these 

stakeholders. The document has not been updated since FSDs were first 

assigned to airports and gives FSDs authority to supervise and deploy a 

TSA law enforcement force that was envisioned but never established. 

Also, the document describes some of the authorities of FSDs but does not 

clearly address the extent of their authority relative to other airport 

stakeholders, including law enforcement agencies, during security 

incidents. Stakeholders at the airports we visited said they were not 

always clear on the authority FSDs had relative to that of other agencies, 

particularly FSDs’ authority in various security incidents, and that such 

information had not been communicated to them. For example, at two 

airports, confusion or conflicting opinions arose over whether the FSD 

had the authority to take certain actions during particular security 

incidents. Stakeholders at the national level also questioned the clarity of 

the FSDs’ authority relative to other agencies, particularly during security 

incidents. For example, FBI headquarters officials stated that past airport 

training exercises revealed that some FSDs thought they were in charge of 

certain situations for which the FBI had authority. According to these 

officials, in an actual security incident, confusion over roles could result in 

conflict, confusion, and increased response time. In addition, 18 of the 25 

FSDs we interviewed by telephone said they believed that TSA needs to do 

more to clarify their roles and responsibilities for the benefit of FSDs and 

stakeholders, and many stated that the authority of the FSD, in particular, 

Results in Brief 
Page 4 GAO-05-935 Aviation Security 

needed clarification. In August 2005, TSA officials stated that they had 

drafted a new Delegation of Authority that clarified FSDs’ authority. 

However, TSA had not completed the revision prior to the issuance of this 

report. 

TSA does not charge FSDs with responsibility for developing federal 

aviation security policy, but it does provide several opportunities for some 

FSDs to be involved in developing some such policies. TSA’s FSD Advisory 

Council provides one mechanism for selected FSDs to be involved in 

TSA’s development of aviation security policy. The FSD Advisory Council 

consists of 22 FSDs who the Administrator selects based on various 

factors, such as airport security category. FSD members provide the 

Administrator their opinions and guidance on establishing and modifying 

TSA policies and procedures when requested and have opportunities for 

input in other areas. On occasion, some FSDs also have had the 

opportunity to provide input on draft federal aviation security policy 

through ad hoc consultation groups organized by TSA’s Aviation Security 

Program Office. Testing new technology and procedures at their airports 

has been another way for some FSDs to be involved in developing federal 

aviation security policy. 

FSDs responsible for the seven airports we visited reported that they had 

entered into partnerships with airport stakeholders, and FSDs and 

stakeholders we contacted at these airports said that their partnerships 

were generally working well. TSA recognizes that building and maintaining 

partnerships with airport stakeholders is essential to FSDs’ success in 

addressing security as well as maintaining an appropriate level of 

customer service. TSA established general guidance for FSDs to follow in 

building stakeholder partnerships but has left it to the FSDs to determine 

how best to achieve effective partnerships at their respective airports. 

FSDs need to partner with law enforcement stakeholders, for example, 

because they do not have a law enforcement body of their own to respond 

to security incidents. Partnerships can be of mutual benefit to FSDs and 

airport stakeholders and can enhance customer service. For example, 

FSDs rely on air carrier data on the number of passengers transiting 

through checkpoints to appropriately schedule screeners, and air carriers 

rely on the FSD to provide an efficient screening process to minimize wait 

times for passengers. At the airports we visited, FSDs and stakeholders 

cited several ways FSDs maintained partnerships, including being 

accessible to their stakeholders to help resolve problems and meeting with 

stakeholders to discuss how to implement new security policies. In 

addition, a variety of communication and coordination efforts were in 

place at the airports we visited, and many of these efforts existed before 
Page 5 GAO-05-935 Aviation Security 

TSA assigned FSDs to airports. Formal mechanisms included security and 

general airport operations meetings, incident debriefings, and training 

exercises to help ensure a coordinated response in the event of a security 

incident. 

TSA made changes in 2004 to better support or empower the FSD position 

by providing FSDs with more authority and flexibility, and FSDs we 

interviewed generally viewed most of these efforts favorably. For example, 

TSA implemented a local hiring initiative designed to vest FSDs with more 

authority to address their screener staffing needs by, among other things, 

giving FSDs the flexibility to select their level of participation in the hiring 

process. Most of the 25 FSDs we interviewed stated that this new hiring 

method addressed their needs better than TSA’s former highly centralized 

approach, although 12 of the 25 FSDs said that to a great or very great 

extent, they still wanted more authority in this area. When we originally 

posed the same question regarding FSD authority in hiring screeners in 

our March 2004 survey of all 155 FSDs, 88 percent of those FSDs stated 

that to a great or very great extent they wanted more authority in selecting 

screeners. In another effort to move more decision making to the field, 

TSA physically relocated its five Area Director positions from 

headquarters to the field and established a group in headquarters to 

provide operational support and a communication link among 

headquarters, field-based Area Directors, and FSDs. FSDs we interviewed 

were split on whether they thought moving the Area Director position to 

the field was helpful, but most considered the group TSA established in 

headquarters to be a valuable resource. TSA had three other efforts under 

way that could significantly affect FSDs—the implementation of a new 

staffing model for allocating screeners at airports, a reassessment of the 

number of management positions allocated to each FSD, and a 

reassessment of which and how many airports are assigned to FSDs. TSA 

took steps to involve at least some FSDs in these efforts. However, most of 

the 25 FSDs we interviewed said that TSA had not involved them. TSA 

headquarters officials said that they acknowledge the importance of FSDs’ 

involvement in agency planning efforts, and when practical and 

appropriate, have attempted to obtain a broad spectrum of FSD input. 

To assist TSA in fully communicating key areas of FSD authority to ensure 

organizational goals and objectives are achieved, we recommend that the 

Secretary of Homeland Security direct the Assistant Secretary of 

Homeland Security for TSA to update the Delegation of Authority to FSDs 

to clearly reflect their authority relative to other airport stakeholders 

during security incidents and communicate this information to FSDs and 

relevant stakeholders. 
Page 6 GAO-05-935 Aviation Security 

We provided a draft of this report to DHS for review. DHS, in its written 

comments, generally concurred with our findings and recommendations 

and agreed that efforts to implement these recommendations are critical 

to enable FSDs to effectively oversee security at the nation’s commercial 

airports. DHS described actions TSA has initiated to revise and update the 

Delegation of Authority to FSDs. Once approved, TSA plans to notify FSDs 

and airport stakeholders of their responsibilities under the new Delegation 

of Authority. A copy of DHS’s comments is included as appendix III. 

A federal position dedicated to overseeing security at commercial airports 

was first established in 1990 under the Federal Aviation Administration 

and was later transferred to TSA. The Federal Aviation Administration 

established the position of Federal Security Manager pursuant to a 

mandate in the Aviation Security Improvement Act of 1990.3

 Federal 

Security Managers, responsible for security at the nation’s largest airports, 

developed airport security plans in concert with airport operators and air 

carriers; provided regulatory oversight to ensure security measures were 

contained in airport plans and were properly implemented; and 

coordinated daily federal aviation security activities, including those with 

local law enforcement. According to TSA officials, regional civil aviation 

security field offices, headed by Civil Aviation Security Field Officers and 

staffed with security inspectors, had been in place at commercial airports 

since the mid-1970s and eventually covered the more than 440 commercial 

airports required to have security programs. In practice, the field office 

staff performed compliance and enforcement inspections and assessed 

penalties, while the Federal Security Managers served in a liaison and 

coordination role as on-site security experts. To avoid duplication of 

effort, Civil Aviation Security Field Officers were not assigned 

responsibilities at airports where Federal Security Managers were 

designated or stationed. 

In November 2001, shortly after the terrorist attacks of September 11, 

2001, the President signed the Aviation and Transportation Security Act 

(ATSA) into law, shifting certain responsibilities for aviation security from 

air carriers to the federal government and the newly created TSA.4

Specifically, ATSA created TSA and granted it direct operational 

 3

 Aviation Security Improvement Act of 1990, Pub. L. No. 101-604, § 104, 104 Stat. 3066, 

3070-71. 

4

 Aviation and Transportation Security Act (ATSA), Pub. L. No. 107-71, 115 Stat. 597 (2001). 

Background 
Page 7 GAO-05-935 Aviation Security 

responsibility for, among other things, passenger and checked baggage 

screening. On February 17, 2002, pursuant to ATSA, TSA assumed 

responsibility from FAA for security at the nation’s commercial airports, 

including FAA’s existing aviation security programs, plans, contracts, 

regulations, orders, directives, and personnel.5

 On February 22, 2002, FAA 

and TSA jointly published a final rule transferring the civil aviation 

security regulations from FAA to TSA and amending those rules to 

comport with ATSA and enhance security as required by the act. 

According to TSA officials, DOT and TSA leadership administratively 

changed the name of the Federal Security Manager to Federal Security 

Director to avoid confusion with the liaison role of the Federal Security 

Manager prior to September 11. The FSD role was more comprehensive 

and had responsibilities that included overseeing passenger and baggage 

screening. Airport operators retained responsibility for the security of the 

airport operating environment, that is, perimeter security, access control 

to secured areas, and other measures detailed in the approved airport 

security plan, while the FSD provided regulatory oversight over these 

efforts. 

FSDs report to one of five Area Directors, based on their geographic 

regions, on administrative matters. However, they report to TSA 

headquarters (the Aviation Security Program Office and Transportation 

Security Operations Center) on operational issues, such as reporting 

security incidents. FSDs are part of the Aviation Security Program Office 

within TSA’s Office of Intermodal Programs, as shown in figure 1. The 

Aviation Security Program Office focuses on specific functions related to 

TSA’s Aviation Security Program, including staffing, training, and 

equipping the federal security work force. The Transportation Security 

Operations Center serves as a single point of contact for security-related 

operations, incidents, or crises in aviation and all surface modes of 

transportation. FSDs are to report any security incident at their airport 

immediately to the center, which is to provide guidance, if needed, as well 

as look for patterns among all incidents that occur throughout the country. 

The center provides FSDs daily intelligence briefings based on incident 

information from FSDs and information from TSA’s Transportation 

Security Intelligence Service. The Transportation Security Intelligence 

 5

 ATSA created TSA as an agency within the Department of Transportation. The Homeland 

Security Act of 2002, Pub. L. No.107-296, 116 Stat 2135, enacted in November 2002, 

transferred TSA to the newly created Department of Homeland Security, where TSA 

presently resides as a distinct entity within the Border and Transportation Security 

Directorate. 
Page 8 GAO-05-935 Aviation Security 

Service provides FSDs, Deputy FSDs, and Assistant FSDs with a classified 

Daily Intelligence Summary containing the most current threat information 

from the intelligence community, law enforcement agencies, and 

stakeholders and provides the FSD staff with an unclassified TSA Field 

Intelligence Summary to be used in briefing screeners and screening 

management about current threats and other issues related to aviation 

security. 
Page 9 GAO-05-935 Aviation Security 

Figure 1: Transportation Security Administration Organization Chart 

Assistant Secretary

Chief Operating 

Officer

Trans. Security Ops. 

Center (TSOC)

Compliance

Programs

Intermodal 

Programs

Aviation 

Security 

Programs

Human 

Resources

- Office of Law 

Enforcement

Comm. and Public Information

Legislative Affairs

Transportation Security Policy

International Affairs

and Program 

Review

International 

Programs

Trans. 

Security

Intelligence

Service

Workforce

Performance

and Training

Chief

Information 

Officer

Security 

Technology

Finance

and

Admin. 

Acquisition

Other (6) 

Intermodal

Programs

Chief Support

Systems Officer

Screening Partnership Prog. (SPP) Model Workplace Program

Transportation 

Vetting and 

Credentialing

Secure 

Flight/Registered 

Traveler

Chief of Staff

- Chief Counsel

- Strategic Management 

and Analysis

- Security

- Civil Rights

- Ombudsman

- Executive Secretariat

- Trans. Security Redress

- Sensitive Security 

Information

- Administrative Appeals

and Review

- National Explosive 

Detection and Canine

Team Program

- Persons with

Disabilities

- Domestic Nuclear 

Detection Office

- Special Operations 

Coordination

Deputy Administrator

TSA components referred to in this report

Source: Developed by GAO based on TSA data.

Federal Security 

Directors (FSD) report to 

TSOC and Aviation 

Security Programs
Page 10 GAO-05-935 Aviation Security 

TSA’s Area Directors are responsible for monitoring and annually 

assessing the performance of FSDs. FSD performance is to be assessed in 

terms of successful accomplishment of organizational goals as well as 

specific performance metrics associated with aviation security within the 

FSD’s area of responsibility. Area Directors are required to follow DHS’s 

performance management guidance for FSDs who are part of the 

Transportation Senior Executive Service (TSES) and TSA’s performance 

management guidance for FSDs who are not part of the TSES (non-TSES). 

According to TSA Human Resources officials, about one-third of the FSDs 

are part of the TSES, and they are generally assigned to larger airports. 

FSDs are responsible for overseeing security operations at the nation’s 

commercial airports—443 airports as of January 2005—which TSA 

classifies in one of five airport security categories (X, I, II, III, IV). 6 These 

categories are based on various factors such as the total number of 

takeoffs and landings annually, the extent to which passengers are 

screened at the airport, and other special security considerations. In 

general, category X airports have the greatest number of passenger 

boardings and category IV airports have the fewest. These airports can 

vary dramatically, not just in passenger and flight volume, but in other 

characteristics, including physical size and layout. Figure 2 identifies the 

number of commercial airports by airport security category, as of January 

2005. 

 6

 According to TSA, the total number of commercial airports regulated for security in the 

United States varies depending on various factors such as the type and level of commercial 

operations that an aircraft operator conducts at that particular airport, the time of year or 

season where a particular airport is located, and the economic stability of that airport’s 

region. 
Page 11 GAO-05-935 Aviation Security 

Figure 2: Commercial Airports by Airport Security Category, as of January 2005 

Note: TSA periodically reviews and updates airport security categories to reflect current operations. 

We used the categories in place in January 2005 to conduct the above analysis. Percentages do not 

total 100 because of rounding. 

TSA had 157 FSD positions at commercial airports nationwide, as of 

January 2005.7

 Although an FSD is responsible for security at every 

commercial airport, not every airport has an FSD dedicated solely to that 

airport. Most category X airports have an FSD responsible for that airport 

alone. Other airports are arranged in a “hub and spoke” configuration, in 

which an FSD is located at or near a hub airport but also has responsibility 

over one or more spoke airports of the same or smaller size that are 

generally located in geographic proximity.8

 At spoke airports, the topranking TSA official located at that airport might be a Deputy FSD, 

Screening Manager, or even Screening Supervisor, although the FSD has 

 7

 The number of FSDs was based on the most current list TSA had at the time of our 

review. 

8

 In contrast to how TSA uses the terms “hub airport” and “hub and spoke,” airlines refer to 

an airline hub as an airport that an airline uses as a transfer point to get passengers to their 

intended destination. It is part of a hub and spoke model, where travelers moving between 

airports not served by direct flights change planes en route to their destination. 

Total: 443

X

Source: GAO analysis of TSA data.

27

Number

of airports

Airport

category

I

II

III

IV

54

61

120

181

12.2%

13.8%

27.1%

40.9%

6.1%
Page 12 GAO-05-935 Aviation Security 

overall responsibility for the airport. 9 Figure 3 identifies the number of 

FSDs responsible for specific numbers of airports. For example, figure 3 

shows that 44 FSDs are responsible for a single airport, 37 are responsible 

for two airports (one hub and one spoke), and 1 is responsible for nine 

airports (one hub and eight spokes). 

Figure 3: Number of FSD Positions with Responsibility for a Designated Number of 

Airports, as of January 2005 

FSDs rely on their management staff to help carry out their responsibilities 

at airports, but the exact FSD management positions vary by airport. At 

larger airports, FSDs might have four Assistant FSDs—one for Law 

Enforcement, one for Regulatory Inspection, one for Screening, and 

another for Operations. However, not every FSD or airport has these 

Assistant FSD positions. Assistant FSDs for Law Enforcement coordinate 

law enforcement activities at the airport and often work with local Joint 

Terrorism Task Forces. Assistant FSDs for Regulatory Inspection are 

responsible for matters related to the enforcement of, and compliance 

 9

 A Screening Manager is responsible for individuals at screening checkpoints and 

maintains communication with supervisors regarding any issues that might reveal a 

weakness or vulnerable area of security screening that is discovered during the course of 

screening duties. A Screening Supervisor is responsible for supervising personnel 

performing preboard security screening of persons and their carry-on and checked 

baggage. 

Source: GAO analysis of TSA data.

0 10 20 30 40 50 0 2 4 6 8 10

Number of FSDs

1

2

3

4

5

6

7

8

9

44

37

28

22

14

4

6

1

1

Number of 

airports 

Responsible for:
Page 13 GAO-05-935 Aviation Security 

with, approved security plans and directives pertaining to airport and 

aviation security. These responsibilities include a key function of the 

oversight of airport compliance with regulatory requirements and security 

measures contained in approved security plans and security directives. 

Assistant FSDs for Screening are responsible for passenger and baggage 

screening and managing all screener staff, and Assistant FSDs for 

Operations are responsible for managing nonscreening operations (e.g., 

exercise planning and execution, crisis management, and vulnerability 

assessments) and designated aspects of administrative support. An FSD 

responsible for a large airport may also have a Deputy FSD, and that 

position could be located at a hub airport where the FSD is located or at a 

spoke airport. Other FSD management staff positions vary by airport and 

airport size, but may include a Stakeholder Manager, Customer Support 

Manager, Training Coordinator, Human Resource Specialist, Financial 

Specialist, Scheduling Operations Officer, Screening Supervisors and 

Managers, administrative support personnel, as well as other positions. 

TSA developed guidance that describes the many roles and responsibilities 

of the FSD position, most of which is associated with securing commercial 

airports from terrorist threats. However, its guidance addressing FSD 

authority is outdated and does not clearly describe the FSDs’ authority 

relative to other airport stakeholders during a security incident. 

Furthermore, some of the stakeholders at airports we visited said that the 

FSDs’ authority relative to others was not always clear during a security 

incident, and that the FSDs’ authority in such cases had not been 

communicated to them. Most of the 25 FSDs we interviewed by telephone 

said that TSA needed to do more to clarify the roles and responsibilities of 

the FSD position for the benefit of FSDs and stakeholders, with the 

majority of these FSDs stating that their authority needed further 

clarification. 

The FSD is the ranking TSA authority responsible for the leadership and 

coordination of TSA security activities at the nation’s commercial airports. 

As such, the FSD is responsible for providing day-to-day operational 

direction for federal security at the airport or airports to which the FSD is 

assigned. ATSA established broad authorities of the FSD, while specific 

responsibilities of the FSD are laid out in TSA Delegation Orders, the FSD 

Federal Security 

Directors Have a 

Range of 

Responsibilities, but 

TSA’s Guidance 

Regarding FSDs’ 

Authority Is Unclear 

FSDs Have a Range of 

Responsibilities Related to 

Airport Security 
Page 14 GAO-05-935 Aviation Security 

position description, and TSA’s 2004 Executive FSD Guide, 10 and include 

the following: 

Overseeing security screening of passengers, baggage, and air cargo. 

FSDs are responsible for providing direct oversight of passenger and 

baggage screening by managing the local screening force, which is 

typically composed of federal employees.11 To carry out this responsibility, 

FSDs engage in activities that include ensuring implementation of required 

screener-training programs, anticipating and preparing for training on new 

screening technologies and procedures, and developing local training 

initiatives to test and improve screener performance. In accordance with 

regulations, aircraft operators perform their own security screening of air 

cargo, and FSDs are responsible for overseeing operators’ performance in 

implementing required security measures. 

Providing regulatory oversight of all U.S. air transportation facilities 

and operations. FSDs are responsible for ensuring that airports, airlines 

(foreign and domestic), air cargo carriers, and indirect air carriers comply 

with TSA regulations and security directives governing such things as 

perimeter security, access controls, procedures for challenging 

questionable identification documents, aircraft searches, and general 

security procedures.12 This is accomplished through administering 

appropriate compliance and enforcement actions with the goal of 

discovering and correcting deficiencies and vulnerabilities in aviation 

security. FSDs oversee civil enforcement activities at their airports 

involving findings of noncompliance with security requirements by 

 10 TSA’s Executive FSD Guide: A Tool for Development (August 2004). 

11 As of August 2005, five airports rely on a private screening contractor instead of a federal 

TSA screening force, and two additional airports have applied to TSA to use private 

screeners. Section 108 of ATSA required TSA to establish a pilot program permitting a 

small number of commercial airports to use private screening contractors to conduct 

passenger and baggage screening operations rather than federal screeners. Beginning on 

November 19, 2004, all commercial airports with federal security screening became eligible 

to apply to opt out of using federal screeners through the Screening Partnership Program. 

According to TSA guidance, the FSD at a privately screened airport would not have direct 

administrative control over the screening workforce but would still be responsible for 

overall security at the airport. For more information see GAO, Aviation Security: 

Preliminary Observations on TSA’s Progress to Allow Airports to Use Private Passenger 

and Baggage Screening Services, GAO-05-126 (Washington, D.C.: Nov. 19, 2004). 

12 Indirect air carriers, sometimes referred to as freight forwarders, consolidate cargo 

shipments and deliver them to air carriers and cargo facilities of passenger and all-cargo air 

carriers that store cargo until it is placed aboard an aircraft. 
Page 15 GAO-05-935 Aviation Security 

airlines, airports, and individuals, including passengers. To carry out their 

regulatory oversight responsibilities, FSDs and staff engage in activities 

that include conducting stakeholder meetings with all regulated parties to 

discuss regulatory changes or educate them on current aviation threats. 

Analyzing and addressing security threats. FSDs are responsible for 

conducting analyses of security threats and vulnerabilities in and around 

their airports. To carry out this responsibility, FSDs seek intelligence from 

sources external to TSA, build systems to analyze the information received 

from intelligence organizations and apply it to the local airport security, 

and direct TSA regulatory agents to test security measures and procedures 

and identify potential security weaknesses. 

Building and managing relationships with airport stakeholders. FSDs 

are responsible for building and managing relationships with local 

stakeholders (e.g., airport management, airlines, and concessionaires) to 

ensure that security operations run smoothly. To carry out this 

responsibility, FSDs engage in activities that include collaborating with 

airlines to identify and resolve issues of efficient passenger flow and 

customer service while maintaining security standards. FSDs also 

coordinate with airport and airline management; federal, state, and local 

governments; law enforcement agencies; and relevant private sector 

entities to organize and implement a Federal Security Crisis Management 

Plan at each airport. The plan is essentially a protocol for what TSA 

employees and airport stakeholders should do in the event of an 

emergency, including a terrorist incident, within the airport. 

Other FSD responsibilities include communicating information received 

from TSA headquarters to appropriate stakeholders, maintaining quality 

customer service for airlines and passengers, providing leadership to the 

TSA employee population, managing and coordinating their direct staff, 

and overseeing management of TSA facilities and equipment resources. In 

addition, TSA has directed FSDs to conduct outreach and liaison with the 
Page 16 GAO-05-935 Aviation Security 

general aviation community in their areas, although it has not given FSDs 

regulatory oversight responsibility over general aviation airports.13

FSDs’ roles and responsibilities have been fairly well documented, but 

their authority relative to other airport stakeholders during security 

incidents has not been clearly defined. Section 103 of ATSA addressed 

FSD authority at the broadest level by giving FSDs responsibility for 

overseeing the screening of passengers and property and for carrying out 

any other duties prescribed by the TSA Administrator.14 TSA’s Executive 

FSD Guide, discussed earlier, describes FSD responsibilities, but it does 

not address the FSDs’ authority in security incidents. That authority is 

addressed more specifically in TSA’s June 2002 Delegation of Authority to 

Federal Security Directors (Delegation Order), which gives FSDs the 

authority to provide for overall security of aviation, including the security 

of aircraft and airports and related facilities to which they are assigned.15

The Delegation Order is outdated in that it gives FSDs the authority to 

train, supervise, equip, and deploy a TSA law enforcement force that was 

never established. Officials from TSA’s Aviation Security Program Office 

acknowledged that the document is outdated and has not been updated 

since FSDs were first assigned to airports. According to officials from 

TSA’s Office of Law Enforcement, TSA originally envisioned that all FSDs 

would be federal law enforcement officers (e.g., GS-1811—criminal 

investigators) and would command a TSA police force. However, the force 

was never established, and FSDs were not given federal law enforcement 

status. TSA has assigned an Assistant FSD for Law Enforcement to about 

half the FSDs in the country, but this is the only law enforcement position 

 13 General aviation includes a wide range of on-demand activities such as pilot training, 

flying for business and personal reasons, delivery of emergency medical services, and 

sightseeing. Most of the responsibility for determining vulnerabilities and enhancing 

security at general aviation airports lies with airport operators. For more information on 

TSA activities related to general aviation, see GAO, General Aviation Security: Increased 

Federal Oversight Is Needed, but Continued Partnership with the Private Sector Is 

Critical to Long-Term Success, GAO-05-144 (Washington, D.C.: Nov. 10, 2004). 

14 Pursuant to ATSA, the head of TSA was referred to as the Under Secretary of 

Transportation for Security. Since TSA transferred to DHS, the head of TSA is now referred 

to as the Assistant Secretary of Homeland Security for TSA. This position is also referred to 

as the TSA Administrator. 

15 TSA’s Delegation of Authority to FSDs was issued on June 14, 2002. 

TSA’s Guidance Regarding 

Aspects of FSDs’ Authority 

Is Outdated, Lacks Clarity, 

and Has Not Been 

Adequately Communicated 

to Stakeholders 
Page 17 GAO-05-935 Aviation Security 

on their staff. Instead, airport police or state or local law enforcement 

agencies primarily carry out the law enforcement function at airports.16 

Furthermore, the Delegation Order does not clearly address the extent of 

FSD authority relative to other parties with responsibilities related to 

airport security, including law enforcement agencies. For example, the 

Delegation Order gives the FSD authority to clear, close, or otherwise 

secure facilities under certain circumstances, and after taking such action, 

requires the FSD to provide feedback to the airport operator on the 

reasons the security action was taken. The document also provides that, 

under certain circumstances, the FSD has the authority to cancel, delay, 

return, or divert flights and search and detain persons or property. 

However, it does not clearly address what authority, if any, FSDs have 

over other parties, such as airport law enforcement personnel, on which it 

would need to rely to take these actions. In August 2005, TSA officials told 

us that they had drafted a revised Delegation Order that clarified the 

authority of FSDs and that it is was being reviewed internally. They stated 

that the revised document restates some of the FSDs’ previous authority 

and provides for some new ones, such as entering into interagency 

agreements. 

Stakeholders at some of the airports we visited told us that the FSDs’ role, 

particularly regarding their authority relative to other parties, was not 

sufficiently clear, and at least one stakeholder at every airport we visited 

said such information had never been communicated to them. At three of 

the seven airports, stakeholders said that aspects of the FSD’s authority 

during a security incident lacked clarity. For example, at two airports, 

confusion or conflicting opinions developed over whether the FSD had the 

authority to take certain actions during particular security incidents. 

Furthermore, six stakeholders at two of the airports we visited were also 

unclear about the FSD’s authority regarding control over airport law 

enforcement personnel and canine teams, access to secured information, 

and specific operational changes. Additionally, at least one stakeholder at 

each of the seven airports we visited said he or she had never been briefed 

or given information on the role of the FSD. Among these stakeholders 

was an airport manager who said he had specifically sought out 

documents detailing the FSD’s roles and authority, including how the FSD 

 16 Some airports have their own independent airport police forces; others rely on state and 

city police forces. Still others have contractual agreements for airport security with local 

sheriff’s departments. 
Page 18 GAO-05-935 Aviation Security 

would fit into the airport’s incident command system. At another airport, 

airport management officials said they had to take the initiative, in 

conjunction with the FSD and law enforcement stakeholders, to develop a 

matrix identifying first responders and the lead agency for various types of 

incidents after a potential hijacking situation highlighted the need to 

document and share such guidance. 

Several stakeholders at the national level also raised questions regarding 

the clarity of the FSD’s authority relative to that of other parties, including 

FSDs’ authority in particular security incidents. Specifically, FBI 

headquarters officials and representatives of two industry associations 

representing airports and airport law enforcement officials voiced concern 

about the clarity of FSDs’ authority, noting that initially some of the first 

FSDs attempted to assert control over airport stakeholders, such as the 

airport police department. FBI headquarters officials were concerned, on 

the basis of past airport exercises, that relationships between FSDs and 

the FBI had not been explicitly delineated. Officials stated that if a conflict 

with local FBI authorities occurred during an actual security incident, it 

might create confusion and result in a longer response time. As of October 

2004, FBI headquarters officials informed us that the FBI was attempting 

to enter into a memorandum of understanding with TSA to clarify certain 

aspects of each agency’s authority. TSA officials said that, as of August 

2005, TSA and the FBI had not entered into a memorandum of 

understanding and were not able to provide us any additional information 

on this issue. 

Our telephone interviews with selected FSDs also indicated a need for a 

clearer statement of their authority. Most (18) of the 25 FSDs we 

interviewed said, to varying degrees, that TSA needed to do more to clarify 

the role and responsibilities of the FSD position—not just for the benefit 

of FSDs and their staff, but for the benefit of airport stakeholders as well. 

(These and other responses to selected questions we posed during our 

interviews with 25 FSDs are contained in app. II.) More specifically, when 

we asked those 18 FSDs what needed further clarification, 11 said that 

their authority needed to be further defined. Among these 11 were 6 FSDs 

who believed TSA should develop a document that delineates the 

authority of the position or update the Delegation Order. For example, 

FSDs told us that other agencies do not understand the authority of the 

FSD or TSA, and have asked for a document to be made widely available 

to federal agencies, state and local law enforcement, emergency 

responders, and other airport stakeholders. Four FSDs explained that 

clarification of the FSDs’ authority is needed with respect to critical 

incident response. 
Page 19 GAO-05-935 Aviation Security 

TSA does not charge FSDs with responsibility for developing TSA aviation 

security policy. However, TSA does expect FSDs to provide input on draft 

policy from TSA headquarters when called upon and to recommend 

policies and procedures for addressing emerging or unforeseen security 

risks and policy gaps. According to TSA officials, the agency provides 

several opportunities for some FSDs to be involved in developing some 

TSA aviation security policies through the FSD Advisory Council, ad hoc 

consultation groups, and the piloting of new security procedures and 

technology. 

The FSD Advisory Council provides a mechanism for selected FSDs to be 

involved in TSA’s efforts to develop aviation security policy, according to 

TSA officials. The FSD Advisory Council was originally established as a 

way for the Aviation Security Program Office to conduct outreach among 

the FSDs. However, in May 2004, the TSA Administrator recast the council 

as an advisory board reporting directly to him and, for the most part, 

responding to his agenda items. The council consists of 22 FSDs who the 

Administrator selects based on factors such as geographic location, airport 

security category, and strong FSD leadership, according to a TSA official 

responsible for council coordination. Most FSDs do not serve on the 

council for more than 1 year, but their term is ultimately left to the 

Administrator’s discretion. Council meetings occur over a 3-day period in 

Washington, D.C., generally on a monthly basis. According to TSA 

officials, during council meetings, the FSDs provide the Administrator 

their opinions and guidance on establishing and modifying TSA policies 

and procedures and have opportunities for input in other areas. Four of 

the five FSDs at airports we visited, including two who were council 

members, saw the council as an effective way for the Administrator to 

gather input on new TSA policy initiatives and issues confronting FSDs. 

The fifth FSD commented that most of the issues discussed by the council 

appeared to be more relevant to airports larger than his. 

On occasion, some FSDs have the opportunity to provide input on draft 

TSA aviation security policy through ad hoc consultation groups organized 

by the Aviation Security Program Office, according to TSA officials. For 

instance, when TSA establishes a new standard operating procedure, it 

typically consults a selected group drawn from, perhaps, 9 or 10 airports. 

These groups are ad hoc and may include different combinations of FSDs, 

FSD staff, and airport stakeholders. For example, TSA formed a group of 

FSDs, screeners, and airport and air carrier staff from multiple airports to 

address anticipated increases in the 2004 summer travel season. According 

to the TSA officials, TSA typically consults such groups on most significant 

policy developments. However, the more urgent or sensitive a new policy, 

TSA Provided 

Opportunities for 

Some FSDs to 

Participate in 

Developing TSA 

Aviation Security 

Policy 
Page 20 GAO-05-935 Aviation Security 

the less likely TSA will have time to obtain input outside of headquarters. 

The official stated that TSA does not involve every FSD in every policy it 

develops but added that he could not think of any policy in the last 6 

months that had not involved at least some FSDs in its development. 

Participating in pilots of new technology and procedures at their airports 

is another way FSDs can be involved in developing TSA aviation security 

policy. TSA has a variety of ongoing pilot programs that it generally 

characterizes as either technology- or procedure-based. For example, TSA 

has tested and evaluated at multiple airports a technology pilot—the 

Explosive Trace Detection Portal Program—that is designed to analyze the 

air around a passenger for traces of explosive material. TSA’s procedurebased pilots include the Registered Traveler Program, which identifies 

participating travelers through biometric identifiers, such as fingerprints, 

and helps to expedite these passengers through required security 

screening for weapons and explosives. In addition, TSA has piloted other 

program initiatives, such as its Next Generation Hiring Program, which 

TSA reported provides a more localized approach to screener hiring that 

enables FSDs to influence the hiring process for their airports. TSA first 

piloted this initiative at Boston Logan International Airport and gradually 

expanded testing to other airports, continuing to make changes before 

implementing the program nationwide. 

Not all FSDs or their airports have been involved in piloting new 

technologies and procedures. According to TSA headquarters officials, 

TSA decided to limit the airports at which it conducts these types of pilots 

to a selected group of “model” airports, although it does conduct pilots not 

involving technology or procedures at other airports. As such, in 

December 2004, in an effort to streamline the airport selection process for 

technology pilots, TSA identified 15 airports and recommended they be 

used for such pilots on an ongoing basis.17 According to these officials, the 

selected airports provide diversity in geography, demographics, and 

baggage and materials to be screened. Ten of the 25 FSDs we interviewed 

said TSA had offered their airports opportunities to pilot a new program or 

technology (collectively, more than 20 such opportunities), and all of them 

subsequently participated. 

 17 TSA may add other airports to its recommended model airport list on a case-by-case 

basis on the recommendation of the Assistant Administrator for Aviation Security 

Programs. 
Page 21 GAO-05-935 Aviation Security 

Although TSA officials told us that opportunities exist for some FSDs to be 

involved in developing TSA aviation security policy, most of the FSDs (21 

of 25) who we interviewed characterized themselves as not involved in 

developing such policy. Three of the five FSDs at airports we visited 

suggested that TSA should consult FSDs on security policies before 

issuing them, although some noted time may not permit this on urgent 

security measures. Two of these FSDs said it would be helpful if TSA 

allowed FSDs a comment period for new policy, and another said that 

because TSA does not involve FSDs in developing policy, its weekly 

national conference calls with FSDs are filled with questions and 

discussions about new security directives. 

FSDs reported they entered into these partnerships at the seven airports 

we visited, and FSDs and stakeholders stated that these partnerships were 

generally working well. Furthermore, FSDs initiated communication and 

coordination efforts with stakeholders or were involved in efforts already 

established—such as meetings and briefings—to address a range of issues, 

including airport security, operations, and coordination. 

As discussed earlier, TSA has given FSDs responsibility for building and 

managing relationships with airport stakeholders and has generally left it 

to the FSDs to determine how to develop effective stakeholder 

relationships. According to TSA’s Executive FSD Guide, building and 

maintaining stakeholder partnerships is a major responsibility of FSDs, 

and these partnerships can create capabilities at airports where the sum is 

greater than the parts. TSA further reinforces the importance of FSDs’ 

building and managing partnerships by including this activity as a standard 

rating element on their annual performance assessments. TSA addressed 

the importance of partnerships in connection with planning for increased 

passenger traffic during the summer months of 2004 in its best practice 

guide—the Aviation Partnership Support Plan.18 This document recognized 

the need for FSDs and airport stakeholders to work together toward 

achieving security and customer service. For example, the plan addressed 

the importance of TSA and air carrier station managers working together 

to identify a process for communicating, handling, and destroying 

 18 TSA Aviation Partnership Support Plan (May 14, 2004). 

FSDs Formed 

Partnerships with Key 

Stakeholders and 

Participated in 

Communication and 

Coordination Efforts 

TSA Views Stakeholder 

Partnerships with FSDs as 

Essential 
Page 22 GAO-05-935 Aviation Security 

sensitive passenger load data, and it encouraged FSDs to develop formal 

working groups to bring together local stakeholders. 

According to parties at the airports we visited and TSA guidance, 

developing partnerships with airport stakeholders is essential for FSDs to 

effectively do their job. First, according to FSDs, FSD staff, and law 

enforcement stakeholders at the airports we visited, FSDs lack law 

enforcement personnel to respond to a security incident and, therefore, 

must rely on federal, state, and local law enforcement agencies in these 

instances. TSA also recognizes that, for example, FSDs would have to 

work with the FBI and other law enforcement agencies to respond to a 

security incident on an aircraft where the door has been closed for 

embarkation, because FSDs do not have the resources needed to respond 

to such an incident. Second, developing partnerships can provide benefits 

to FSDs and airport stakeholders. For example, FSDs need air carrier data 

on the number of passengers transiting airport checkpoints to 

appropriately schedule screeners. At the same time, air carriers seek an 

efficient screening process to minimize wait times for their customers. 

Various parties we interviewed, including airport stakeholders, BTS and 

FBI officials, and an industry representative, recognized the importance of 

partnerships in helping the airport operate smoothly. For example, one 

industry representative said that airport management needs security and 

threat information from the FSD, and the FSD needs to understand 

nonsecurity issues that affect the FSD’s job, such as an upcoming local 

event that may increase passenger traffic. 

FSDs and most of the stakeholders at the seven airports we visited said 

that they had developed partnerships, and they described these 

partnerships as generally working well. The FSDs responsible for these 

airports reported having positive partnerships with airport stakeholders. 

More specifically, one FSD said that having common goals with 

stakeholders, such as ensuring security, enhanced their partnerships. 

Another FSD saw himself as a catalyst for partnerships at his airport and 

as a facilitator among stakeholders who did not always get along. At most 

of these airports, stakeholders also reported that FSD-stakeholder 

partnerships were working well and identified examples of successful 

practices. Some spoke of the value of an FSD being accessible to 

stakeholders to help resolve problems by, for example, being visible at the 

airport and maintaining an open-door policy. Seven stakeholders stated 

FSDs and Stakeholders 

Reported Partnerships 

Were Generally Working 

Well 
Page 23 GAO-05-935 Aviation Security 

that the FSDs at their airports discussed TSA security directives and 

worked with them when it was not clear how to interpret or implement 

them.19 At one airport, the FSD, airport management, and air carriers 

teamed together to look for opportunities to enhance security and 

customer service. To this end, they formed a working group and developed 

a proposal for TSA that addressed issues involving technology, 

infrastructure, transportation assets, and local budgetary control for the 

FSD. Finally, at another airport, in an effort to manage stakeholders’ 

concerns about wait times and customer service, the FSD arranged for 

staff to help screen all of the airport vendors and concessionaires, as 

required, but at an established time to ensure passengers were minimally 

affected. 

Partnerships at airports across the country were generally working well or 

better at the time of our review than when TSA first assigned FSDs to 

airports, according to several federal agency officials and industry 

representatives at the national level. Some airport stakeholders and 

industry representatives stated that some FSDs’ authoritative management 

style and lack of airport knowledge contributed to tensions in earlier FSDstakeholder relationships. However, during the course of our review, TSA 

officials said they received very few complaints about FSDs from airport 

stakeholders, and industry representatives and officials from BTS (which 

oversees CBP and ICE), and the FBI said that partnerships were generally 

working well or had improved. For example, FBI officials had queried 27 

of their Airport Liaison Agents in October 2004 about their relationships 

with FSDs, and 20 of the 22 agents who responded characterized these 

relationships as generally good. FBI officials told us that at one airport 

where coordination and partnerships stood out as being particularly 

strong, the FSD met with stakeholders every morning. 

TSA established 80 Assistant FSD for Law Enforcement positions across 

the country to help FSDs partner and act as liaison with law enforcement 

stakeholders and to conduct certain criminal investigations. This position 

is always filled by a federal law enforcement officer (a criminal 

investigator), and is the only law enforcement officer assigned to an FSD. 

Office of Law Enforcement officials stated that this position is essential 

for interacting with local law enforcement stakeholders, and they would 

 19 According to TSA officials, FSDs are responsible for ensuring affected parties receive 

security directives, but they do not expect FSDs to hand-deliver every security directive to 

every stakeholder. 
Page 24 GAO-05-935 Aviation Security 

like to see every FSD have at least one Assistant FSD for Law 

Enforcement and more than one at larger airports. Assistant FSDs for Law 

Enforcement report directly to their respective FSDs, and at smaller 

airports without this position, the FSD takes on responsibility for 

coordinating with law enforcement stakeholders.20 Given the number of 

positions authorized, not all FSDs have Assistant FSDs for Law 

Enforcement on their staff. Of the 25 FSDs we interviewed, 13 reported 

having this position on their staff, and 12 reported not having this position. 

Regardless of whether these FSDs had this position, almost all (23) said it 

was important to have the position on their staff to coordinate with the 

law enforcement and intelligence community and perform criminal 

investigations.21 An Assistant FSD for Law Enforcement explained during 

one airport visit that his familiarity with legal processes and procedures 

facilitated his working relationship with the FBI and U.S. Attorneys. FBI 

headquarters officials also reported that the Assistant FSD for Law 

Enforcement position has helped improve coordination between TSA and 

the FBI at airports. TSA did not provide an agency-level position on 

whether every FSD needs an Assistant FSD for Law Enforcement. 

Although most of our contacts reported that partnerships between FSDs 

and airport stakeholders were generally working well, about half (13) of 

the 25 FSDs we interviewed said that it is challenging to foster 

partnerships with the parties they are responsible for regulating. Several 

FSDs stated that while it may be hard to partner with those one regulates, 

having good communication and relationships with stakeholders and a 

mutual understanding of the responsibility of regulating airport security 

makes such partnering possible. According to officials from TSA’s Office 

of Compliance Programs, the office has articulated a policy of compliance 

through cooperation, which has helped FSDs foster partnerships with 

airport stakeholders while achieving TSA’s regulatory oversight mission. 

For example, TSA established a Voluntary Disclosure Program that allows 

 20 According to TSA Office of Law Enforcement officials, if a specific need should arise at 

an airport without an Assistant FSD for Law Enforcement, the Office of Law Enforcement 

will instruct the nearest Assistant FSD for Law Enforcement to respond to the situation. 

21 About half (13) of the 25 FSDs said they had a criminal investigator as part of their 

management staff (when FSDs have criminal investigators on their staff, they hold the 

position of an Assistant FSD for Law Enforcement), and all of those FSDs considered this 

position to be important in addressing their airports’ security needs—12 of the 13 

considered it very important—and several added that they needed more than one of these 

positions on their staff. In addition, 10 of the 12 FSDs who did not have this position on 

their staff considered it a position that would be important in supporting their airports’ 

security needs. 
Page 25 GAO-05-935 Aviation Security 

stakeholders to forgo civil penalty actions by bringing violations to the 

attention of TSA and taking prompt corrective action. The philosophy 

behind this program is that aviation security is well served by providing 

incentives to regulated parties to identify and correct their own instances 

of noncompliance and to invest more resources in efforts to preclude their 

recurrence.22 According to Office of Compliance Program officials, 75 

percent of issues of noncompliance were closed by administrative action 

rather than civil enforcement during the past 2 fiscal years. Furthermore, 

in half the cases reported, FSDs were able to address the discovered 

security gaps and close the issue with a note to the inspection files, instead 

of writing a formal investigation report. 

At one airport we visited, not all stakeholders agreed that partnerships 

with the FSD were working well. Airport management, airport law 

enforcement, and air carriers at this airport said the FSD was not 

accessible, often did not attend meetings to which he had been invited, 

and sometimes did not send FSD staff to meetings in his place. These 

stakeholders also criticized the FSD for not distributing security directives 

and meeting to discuss their implementation. However, local federal 

stakeholders at this airport (representing the FBI, CBP, and ICE) said that 

the FSD had established positive partnerships with them and had 

communicated well. 

According to TSA’s Executive FSD Guide, FSDs are responsible for 

conducting group or one-on-one meetings with airport managers and air 

carriers. FSDs and stakeholders at all seven of the airports we visited told 

us that they were involved with these and other communication and 

coordination efforts. FSDs and stakeholders described a variety of such 

mechanisms, including meetings and training exercises, noting that many 

of these were in place before FSDs were assigned to airports. A BTS 

official explained that at larger airports, FSDs inherited coordination 

mechanisms and relationships established between federal agencies and 

other stakeholders. In contrast, at smaller airports, FSDs had to educate 

 22 TSA’s voluntary disclosure policy directive relates to information and guidance that may 

be used by aircraft operators (except individuals), indirect air carriers, foreign air carriers, 

airports, and flight training providers when voluntarily disclosing to TSA apparent 

violations of TSA regulations (applicable regulations include 49 C.F.R. parts 1542, 1544, 

1546, 1548, and 1552). The TSA Voluntary Disclosure program does not apply to violations 

or apparent violations committed by individuals serving as agents of covered regulated 

entities. 

FSDs and Stakeholders 

Said They Participated in 

Many Communication and 

Coordination Efforts 
Page 26 GAO-05-935 Aviation Security 

stakeholders on involving and communicating more with federal officials. 

At two of the larger airports we visited, stakeholders said that the FSDs 

initiated communication and coordination efforts on their own, such as 

holding routine intelligence briefings and meetings with law enforcement 

agencies and representatives of U.S. Attorneys’ Offices. Aside from the 

more formal communication and coordination mechanisms, FSDs and 

some of the stakeholders at all seven airports we visited said they 

frequently shared information and developed partnerships informally 

through telephone calls, e-mails, and face-to-face interactions. 

At all of the airports we visited, FSDs and stakeholders reported that 

meetings to discuss improvements to airport security and operations and 

coordination meetings were held, although the type of participants and 

frequency of these meetings varied. FSDs and stakeholders reported that 

some of these meetings were held on a weekly, monthly, or quarterly 

basis, while others were held on an impromptu basis when FSDs or 

stakeholders had an issue to discuss. According to an FBI official, most of 

the Airport Liaison Agents they had queried were having monthly meetings 

with their FSDs. Similarly, a BTS official said that all FSDs had monthly 

meetings with representatives from other BTS agencies (ICE and CBP) to 

improve coordination of law enforcement and security efforts among 

these agencies at airports.23 Although five of the seven airports we visited 

had standing formal meetings, two of the smaller airports did not. Rather, 

at these airports, the FSD and stakeholders reported interacting daily and 

holding meetings on an as-needed basis. 

In addition to meetings, incident debriefings and training exercises to 

ensure a coordinated response in the event of a security incident were 

conducted at most of the airports we visited. Stakeholders at three of the 

airports mentioned that debriefings occurred after an actual incident to 

address questions and discuss how the incident had been handled. For 

example, at one airport, a stakeholder explained that a debriefing helped 

alleviate concerns he had regarding his lack of involvement during a 

particular incident. According to TSA, response to an actual event is 

typically only as good as the training for it; hence, TSA requires FSDs to 

hold quarterly training exercises at their airports. Training exercises 

 23 In August 2004, the Under Secretary of BTS directed all DHS agencies with an airport 

presence to establish a formal committee to ensure that senior operational managers were 

communicating across agency lines and fully coordinating law enforcement and security 

efforts. The FSD was tasked with coordinating the establishment of these committees. 
Page 27 GAO-05-935 Aviation Security 

included tabletop simulation exercises,24 hijacking scenarios, and Man 

Portable Air Defense Systems (MANPADS)25 vulnerability assessments to 

identify areas where a MANPADS attack could be launched. Sometimes 

protocols or security directives are written as a result of airport incidents 

and debriefings. At all seven airports we visited, protocols for responding 

to incidents existed, according to FSDs, their staff, or stakeholders, and at 

most of these airports, protocols were written into the Airport Security 

Plan. However, a TSA headquarters official explained that a protocol 

cannot exist for every possible incident, given that security incidents are 

often unique. 

TSA has made a number of changes intended to provide FSDs with more 

authority and flexibility in carrying out their responsibilities, and most 

FSDs we interviewed responded favorably to these changes. In addition, 

TSA was planning additional efforts during our review that could affect 

FSDs, and the majority of the 25 FSDs we interviewed said they were not 

involved in these efforts. 

To further support or empower the FSD position, TSA increased FSDs’ 

authority to address performance and conduct problems, established a 

local hiring initiative, increased flexibility to provide screener training, 

relocated Area Director positions to the field, and established a report 

group and a mentoring program. The majority of FSDs we interviewed had 

positive views of most of these changes.26

 24 A tabletop exercise is a focused practice activity that places the participants in a 

simulated situation requiring them to function in the capacity that would be expected of 

them in a real event. Its purpose is to promote preparedness by testing policies and plans 

and by training personnel. 

25 MANPADS are shoulder-launched surface-to-air guided missiles that are accurate, 

concealable, transportable, and designed to be user-friendly. DHS, in partnership with 

other federal agencies, is working to counter the threat of MANPADS to civilian 

commercial aircraft. As part of its overall MANPADS strategy, TSA is performing airport 

vulnerability assessments to identify and map the areas around an airport from which a 

MANPADS attack could be initiated, and it is working with surrounding communities to 

coordinate the efforts of agencies responsible for responding to this type of threat. 

26 Some of the changes we discussed with FSDs during airport visits had just recently been 

implemented by TSA. 

TSA Made Changes to 

Better Support or 

Empower the FSD 

Position and Was 

Planning Additional 

Changes 

Most FSDs We Interviewed 

Viewed the Changes TSA 

Made Favorably 
Page 28 GAO-05-935 Aviation Security 

Local hiring initiative. TSA developed a local screener hiring initiative 

that, among other things, vested more hiring authority with FSDs to 

address airport staffing needs. To meet a post-September 11 statutory 

deadline, TSA brought a workforce of 57,000 federal screeners on board 

within 6 months using a highly centralized approach of recruiting, 

assessing, hiring, and training.27 With this accomplished, TSA began 

piloting a reengineered local hiring initiative, called Next Generation 

Hiring, in June 2004. Its goal was to ensure the involvement of FSDs and 

their staff in the hiring process, streamline the process, and make the 

process more responsive to the full range of airport needs. The program 

was designed to give FSDs and their staff the flexibility to determine 

which aspects, or phases, of local hiring they wish to participate in, and 

how much contractor support they need.28 TSA incorporated modifications 

as a result of lessons learned from its pilot and initial implementation sites 

as it gradually rolled out this initiative to additional locations. By March 

2005, TSA had established 12 fully operational local hiring centers around 

the country, with locations based on various factors, including geography 

and operational need. 

When we asked all 155 FSDs in our March 2004 survey if they wanted more 

authority in selecting screeners, 136 (88 percent) said they wanted more 

authority to do this to a great or very great extent, and another 9 percent 

said they wanted more authority in this area to a moderate extent. When 

we interviewed 25 FSDs during this review, approximately 1 year after 

TSA began rolling out the Next Generation Hiring program, 12 reported 

that they wanted more authority in selecting screeners to a great or very 

great extent, even given their participation options under Next Generation 

Hiring, and another 8 said they wanted more authority in this area to a 

moderate extent.29

 27 We previously reported that TSA’s hiring process hindered the ability of some FSDs to 

adequately staff passenger and baggage screening checkpoints. See GAO, Aviation 

Security: Challenges Exist in Stabilizing and Enhancing Passenger and Baggage 

Screening Operations, GAO-04-440T (Washington, D.C.: Feb. 12, 2004). 

28 For each of the three basic phases of hiring (recruiting, interviewing, and job offer and 

acceptance), FSDs may choose whether they want to conduct the phase primarily on their 

own, work in partnership with the TSA contractor, or turn the execution over to the 

contractor. Joint execution is not an option for the third phase—job offer and orientation. 

29 Of the 25 FSDs we interviewed in the spring of 2005 as part of this review, 21 had 

responded to our Web-based survey of all FSDs, which we conducted in March 2004 as part 

of other GAO reviews. 
Page 29 GAO-05-935 Aviation Security 

Nevertheless, 18 of the 25 FSDs stated that Next Generation Hiring 

provided for their airports’ screener staffing needs better than TSA’s 

former hiring process to a very great, great, or moderate extent. In 

addition, 14 of the 25 FSDs stated that, overall, they were satisfied with the 

new program’s ability to meet their screener staffing needs, but 7 said they 

were not satisfied.30 Comments from those dissatisfied FSDs included 

statements that the contractor had not done a good job in the recruiting 

aspect of the process and that the new hiring process still takes too long—

a comment echoed by some FSDs we interviewed during our airport visits 

earlier in the program’s rollout. 

TSA officials stated that the goal of Next Generation Hiring was not 

necessarily to reduce the time it takes to bring a new screener on board at 

every airport. Rather, the goal was to be more responsive to all local hiring 

needs—not just the needs of the largest airports. According to a program 

official, early data on Next Generation Hiring have been positive, though 

limited. For example, data from a nonscientific sample of several airports 

showed that under Next Generation Hiring, fewer screeners resigned 

within their first month than before the program was in place (about 18 

percent resigned in the first month before Next Generation Hiring; about 

7.5 percent resigned in the first month after the program was initiated at 

those airports). Officials also concluded, on the basis of their limited data 

and anecdotal information, that candidates selected at airports where the 

FSD and staff were conducting the hiring process were more selective in 

accepting offers because they had more knowledge of what the job would 

entail than contractors did when they handled the hiring process. 

Increased flexibility to provide screener training. TSA expanded FSDs’ 

flexibility to offer training locally to screeners in two respects in April 

2004. First, TSA developed and implemented a new basic screener training 

program to cover the technical aspects of both passenger and checked 

baggage screening, and allowed FSDs to choose whether new screeners 

would receive instruction in one or both of these screening functions 

during initial training. According to TSA officials, this approach provides 

the optimum training solution based on the specific needs of each airport 

and reflects the fact that, at some airports, the FSD does not need all 

screeners to be fully trained in both passenger and checked baggage 

screening. Second, TSA offered FSDs the flexibility to deliver basic 

screener training using either contractors or local TSA employees as 

 30 The remaining 4 FSDs said they had no opinion on this issue.
Page 30 GAO-05-935 Aviation Security 

instructors, provided they have experience as instructors and are 

approved by TSA.31

Prior to TSA providing FSDs with more training flexibility, 110 of the 155 

FSDs (71 percent) who responded to our March 2004 survey said that they 

wanted more flexibility to design and conduct local training to a great or 

very great extent.32 A year later, when we asked 25 FSDs during this review 

about their satisfaction with the flexibility they had in offering training 

locally to screeners, 21 said they were satisfied. Several noted this was an 

area where they had seen improvement in the flexibility TSA had given 

them. 

Increased authority to address performance and conduct problems. TSA 

expanded FSDs’ authority to address employee performance and conduct 

problems over time, beginning in 2003 when FSDs were delegated 

authority to suspend employees for up to 3 days. In July 2004, FSDs were 

delegated the authority to take the full range of disciplinary actions, 

including removal, in accordance with TSA policy. In September 2004, TSA 

again increased the authority of FSDs by allowing them to use a 

streamlined, one-step process in taking certain disciplinary actions, such 

as the termination of employment for screeners involved in theft or the use 

of drugs or alcohol.33 During our telephone interviews with FSDs, 

conducted more than 6 months after the last of these increases in FSD 

authority, 24 of the 25 FSDs said they were satisfied with their current 

authority to address employee performance and conduct problems. 

 31 For local employees to be approved as instructors by TSA, they must be nominated by an 

FSD and have a current or prior instructor certification by a recognized training and 

development organization or have at least 2 years of experience as an instructor. In 

addition, local TSA instructors must have successfully completed the course of instruction 

they will be teaching and demonstrate instructional skills by assisting a TSA-approved 

instructor in classroom instruction and monitoring actual classroom instruction. We 

reported this and other information related to TSA screener training and performance 

issues in GAO, Aviation Security: Screener Training and Performance Measurement 

Strengthened, but More Work Remains, GAO-05-457 (Washington, D.C: May 2, 2005). 

32 The question posed in that survey asked FSDs about their need for more flexibility to 

design and conduct local training and did not specify screener training. 

33 In addition, the one-step process may be used to suspend screener personnel for 3 days 

or less; suspend, remove, or reduce pay band or rate of pay for any employee serving a trial 

period; and to indefinitely suspend screeners for serious misconduct that necessitates 

immediate action under certain designated conditions. All indefinite suspensions must be 

reviewed for legal sufficiency by a TSA counsel and may be coordinated with a designated 

Employee Relations Specialist prior to issuance. 
Page 31 GAO-05-935 Aviation Security 

Moreover, 2 of the 5 FSDs we interviewed during our airport visits said 

that their increased authority in this area was an important change that 

exemplified TSA’s efforts to further empower FSDs. 

Relocation of Area Director positions. In September 2004, as part of an 

overall reorganization effort, TSA physically relocated its five Area 

Director positions from the Aviation Security Program Office in 

headquarters to the field. According to TSA headquarters officials, the goal 

was to move more TSA authority and decision making from headquarters 

to the field and to create efficiencies in TSA’s processes and procedures. 

In making this change, TSA named five existing FSDs—one in each of 

TSA’s five geographic areas—to assume the responsibility of being Area 

Directors in addition to continuing to serve as FSDs of major airports. 

FSDs in each of the new Area Directors’ geographic regions report to their 

respective Area Director on administrative matters. However, they report 

to TSA headquarters (the Aviation Security Program Office and 

Transportation Security Operations Center) on operational issues, such as 

reporting security incidents. To support these “dual hatted” FSDs with 

their additional Area Director responsibilities, TSA authorized each to hire 

five additional staff. 

The 25 FSDs we interviewed were divided on whether they thought having 

Area Directors in the field was helpful—12 said it was helpful and 12 said 

it was not helpful—and some offered comments.34 On one hand, several 

FSDs said that field-based Area Directors who were also FSDs had a much 

better understanding of what FSDs encounter each day. On the other 

hand, several said that FSDs were better served by Area Directors located 

at headquarters because they were more aware of everything that was 

taking place and had more staff to support them. Views on this topic were 

also mixed among the five FSDs we interviewed during our airport visits. 

Two Area Directors were among the 25 FSDs we interviewed, and both 

thought the change to field-based Area Directors was helpful but thought 

that the position should be further empowered. One explained that the 

Area Directors should be involved in operational issues in addition to 

administrative matters, although he would need additional staff if he also 

had this responsibility. The other Area Director said that, as one of only 

five Area Directors, he is responsible for too many airports. 

 34 One FSD had no opinion. 
Page 32 GAO-05-935 Aviation Security 

Report Group.35 In conjunction with moving the Area Director positions 

out of headquarters, TSA established this group in September 2004 to 

conduct some of the duties previously performed by Area Directors when 

at headquarters. It was also intended to provide operational support and a 

communication link between TSA headquarters and field-based Area 

Directors, and in turn, FSDs and their staff. The group manages and 

standardizes communications (including sending daily recaps of each 

day’s business), continually updates point-of-contact lists that identified 

who FSDs and their staff should contact when a problem arises, and 

serves as a troubleshooter for unresolved issues. For example, FSDs and 

their staff may call the Report Group for assistance if they have already 

contacted the appropriate headquarters contacts and their issue or 

question was not resolved. 

Of the 25 FSDs we interviewed, 16 considered the Report Group to be a 

valuable resource, and 7 said they did not consider it valuable. Although 

TSA established the group just prior to our airport visits, FSDs we 

interviewed at that time saw the potential value of the group and noted 

that its daily recaps were already helpful in consolidating and sharing 

consistent information, as were the point-of-contact lists. 

Mentoring Program. TSA began offering an optional mentoring 

experience to newly appointed FSDs and Deputy FSDs in April 2004 to 

support their transition into their new positions. Under this program, 

mentor coordinators match new FSDs and Deputy FSDs (mentoring 

colleagues) with more experienced counterparts (mentors) at other 

airports somewhat comparable in size and complexity. As TSA names new 

FSDs and Deputies, the coordinators offer them a choice of prescreened 

volunteer mentors, give participants suggested steps for proceeding with 

the mentoring relationship, and provide a list of frequently asked questions 

and answers about the program. 

Only 2 of the 5 FSDs we visited and 4 of the 25 FSDs we interviewed had 

participated in the Mentoring Program—either by being a mentor or by 

being mentored—and all but one saw it as having value.36 One FSD, who 

 35 This group was named the Communications Liaison Group when it was initially 

established in September 2004 and was later renamed the Report Group. When established, 

the group was composed of former Area Directors and their staff. 

36 Of the 25 FSDs we interviewed by telephone, only 4 were named FSDs after TSA 

established the Mentoring Program. 
Page 33 GAO-05-935 Aviation Security 

had been mentored, explained that having a mentor helped him learn a 

very challenging job and provided the opportunity to bounce ideas off of 

an experienced FSD. About half (13) of the 25 FSDs said that they were 

not familiar with TSA’s mentoring program. 

At the time we interviewed FSDs, TSA was planning the following three 

additional initiatives that could affect at least some FSDs. The majority of 

the 25 FSDs we interviewed said they were not involved in these efforts. 

TSA’s Screening Allocation Model. TSA has been developing a model for 

determining screener staffing levels after initially deploying its federal 

screener workforce in 2002 based on estimates of screeners performing 

screening functions under privatized agencies, instead of a model. In 

September 2003, in an effort to right-size and stabilize its screener 

workforce, TSA hired a consultant to conduct a study of screener staffing 

levels at the nation’s commercial airports. Among other things, the 

consultant was tasked with (1) developing a comprehensive modeling 

approach with appropriate details to account for the considerable 

variability that occurs among airports, (2) creating a staffing analysis 

model to be used as a management tool to determine daily and weekly 

staffing levels and deploying the model to commercial airports nationwide, 

and (3) developing user-friendly simulation software to determine 

optimum screener staffing levels for each commercial airport with federal 

screeners. In March 2004, while awaiting the completion of this model, 

TSA established specific airport staffing limits to meet a congressionally 

mandated cap for screeners set at the level of 45,000 full-time-equivalent 

positions. In the summer of 2004, the model was selected, developed, and 

deployed for airport data input. That fall, TSA officials told us they 

expected the model, which was being validated with airports at the time, 

would demonstrate TSA’s need for screeners beyond the mandated cap. 

FSDs we interviewed during our airport visits shared this view and the 

expectation that many airports would see increases in their screener 

allocations. In July 2005, TSA finalized and submitted to Congress its 

TSA Was Planning 

Additional Initiatives That 

Could Affect FSDs 
Page 34 GAO-05-935 Aviation Security 

standards for determining aviation security staffing for all airports at 

which screening is required.37 

The Screening Allocation Model does not give FSDs the authority to 

determine the number of screeners authorized for their airports, nor was it 

intended to do so. When asked if they would like to have greater authority 

in determining screener staffing levels for the airports they oversee, 23 of 

the 25 FSDs we interviewed answered that, to a great or very great extent, 

they would like greater authority. One FSD commented, for example, that 

there will always be a need for FSDs to have a way to adjust screener 

numbers and that the screener staffing system needs to have sufficient 

flexibility to address sudden changes in screening demands. This view was 

fairly consistent with what FSDs had said a year earlier in our March 2004 

survey, when we posed the same question to all FSDs. At that time, 145 of 

154 FSDs (94 percent) answered in the same way when asked if they 

wanted more authority in determining the number of screeners for their 

airports. 

Although TSA officials said that they had obtained a variety of data from 

FSDs during the course of the development of its Screening Allocation 

Model, not all of the FSDs we contacted saw themselves as having been 

involved in the model’s development. Of the 25 FSDs we interviewed, 14 

said that TSA had not involved them or provided them with the 

opportunity to have input into the development of the model. Of the 14 

FSDs who said they were not involved, 11 were dissatisfied regarding their 

lack of involvement. Furthermore, among the 11 FSDs who said they were 

involved in developing the model, 5 were dissatisfied regarding their level 

of involvement.38 According to TSA officials, FSDs provided information 

for the model regarding their respective airports, and headquarters 

validated the numbers the model generated for each airport. 

 37 The Intelligence Reform and Terrorism Prevention Act of 2004, Pub. L. No. 108-458, 118 

Stat. 3638, required TSA to develop and submit, to the Committee on Commerce, Science 

and Transportation of the Senate and the Committee on Transportation and Infrastructure 

of the House of Representatives, standards for determining aviation security staffing at 

commercial airports no later than 90 days after December 17, 2004, the date of the act’s 

enactment, and GAO to conduct an analysis of these standards. TSA’s submission of its 

Report to Congress—Aviation Security Staffing Standards—constituted TSA’s submission 

to meet this reporting requirement of the law. 

38 Ten of the 25 FSDs pointed out that the model, as modified, functions under a 45,000 

screener cap, which is too low and does not take into account real-life factors such as 

screener vacation time, military time, training time, or sick leave. As a result, according to 

one FSD, security lines are longer and service is poorer. 
Page 35 GAO-05-935 Aviation Security 

Reassessments of airport hub and spoke configurations and FSD 

management staff. TSA began two related reviews in June 2004: (1) a 

reassessment of the hub and spoke configurations of commercial airports 

and (2) a reassessment of the number of management and administrative 

positions allocated to each FSD.39 The hub and spoke reassessment could 

result in changes to the number or the specific airports for which some 

FSDs are responsible. According to TSA headquarters officials, TSA 

undertook this reassessment because some FSDs had airports in more 

than one state, and complexities arose when working with multiple state 

laws and regulations, as well as U.S. Attorneys and police departments 

from multiple state jurisdictions. Officials anticipated that after TSA 

completes its review, a few situations will continue in which FSDs have 

responsibility for airports in more than one state, but only when the 

distance between certain airports necessitates. 

Related to its review of hub and spoke configurations, TSA undertook a 

reassessment of FSD management staff levels, recognizing that some 

airports—typically smaller ones—were overstaffed, while others—

typically larger airports—were understaffed. According to TSA officials, 

TSA initially distributed FSD staff based on the security classification of 

the airport and, to a lesser extent, the size or annual number of aircraft 

boardings. This, coupled with resource constraints that resulted in fewer 

positions being authorized than were needed, resulted in an imbalance in 

FSD staff among airports. Authorizations for the FSD staff positions 

ranged from 1 position at category III and IV airports with a minimum 

threshold of boardings, to 16 positions at category X and large category I 

airports. TSA made decisions regarding some of these positions (e.g., 

whether a particular FSD should be assigned a Deputy FSD or an Assistant 

FSD for Law Enforcement), while FSDs were left to make decisions about 

other positions (e.g., whether to include a Training Coordinator or a 

Human Resources Specialist as one of the FSD’s management staff). 

Although TSA made adjustments to some FSDs’ staff levels over time, 

officials recognized that an across-the-board reassessment was needed. 

The majority of the 25 FSDs we interviewed said that they were not 

involved in either of these two reassessment efforts, and most who were 

not involved were dissatisfied with their lack of involvement. Fourteen of 

 39 According to TSA officials, the hub and spoke reconfigurations and new FSD staffing 

numbers were rolled out to the field in late July 2005—about 1 year after TSA began the 

reassessment and several months after we conducted telephone interviews with FSDs. 
Page 36 GAO-05-935 Aviation Security 

the 25 FSDs said they had not been involved in TSA’s reassessment of 

airport hub and spoke configurations, and 19 of the 25 FSDs said they had 

not been involved the reassessment of FSD management staff levels. TSA 

headquarters officials said that they acknowledge the importance of FSDs’ 

involvement in agency planning efforts, and when practical and 

appropriate, TSA has attempted to obtain a broad spectrum of FSD input. 

They said that in conducting these two particular reassessments, they 

formed a team that included three FSDs and three Deputy FSDs. 

For FSDs to carry out their responsibilities effectively, FSDs, their staff, 

and airport stakeholders need a clear statement of the FSDs’ authority, 

relative to other stakeholders, in the event of security incidents. TSA’s 

primary document outlining FSDs’ authority is outdated, and neither it, 

nor other statements TSA has issued, delineates the authority of the FSD 

in various security situations relative to other parties. The absence of a 

clear understanding of the authority of the position has reportedly resulted 

in confusion during past security incidents and has raised concerns among 

some stakeholders at both the national and airport levels about possible 

ambiguity regarding FSDs’ authority during future incidents. Updating 

TSA’s Delegation of Authority to FSDs to clarify their authority relative to 

others and developing other documents, as warranted, would benefit FSDs 

by further enabling them to communicate and share consistent 

information about their authority with their staff and airport stakeholders, 

including law enforcement agencies. Stakeholders need to be clear on 

which agency has authority or lead responsibility in the event of various 

types of security incidents to reduce the likelihood of confusion or a 

delayed response. 

To clarify the authority of the Federal Security Director during various 

security incidents and help ensure a consistent understanding of the 

authority of FSDs among FSDs, their staff, and airport stakeholders, we 

recommend that the Secretary of Homeland Security direct the Assistant 

Secretary of Homeland Security for the Transportation Security 

Administration to take the following two actions: 

• update TSA’s Delegation of Authority to FSDs to clearly reflect the 

authority of FSDs relative to other airport stakeholders during security 

incidents and 

• communicate the authority of the FSD position, as warranted, to FSDs 

and all airport stakeholders. 

Conclusions 

Recommendations for 

Executive Action 
Page 37 GAO-05-935 Aviation Security 

We provided a draft of this report to DHS for its review and comment. On 

September 15, 2005, we received written comments on the draft report, 

which are reproduced in full in appendix III. DHS, in its written comments, 

generally concurred with our findings and recommendations, and agreed 

that efforts to implement these recommendations are critical to enable 

FSDs to effectively oversee security at the nation’s commercial airports. 

Regarding our recommendation that TSA update its Delegation of 

Authority to FSDs and communicate this information to FSDs and relevant 

stakeholders, DHS stated that a new restatement of the Delegation Order 

has been drafted by a working group composed of FSDs from the FSD 

Advisory Council and the Office of Chief Counsel. The Delegation Order 

has a new concise format that restates some of the FSDs’ previous 

authorities and proposes some new authorities, such as entering into 

interagency agreements and administering oaths, consistent with the 

evolving operational requirements in the field. DHS further stated that the 

Delegation Order is being internally coordinated for comment and 

clearance and will be presented for consideration of senior leadership and 

the Administrator. At that time, FSDs and airport stakeholders will be 

notified of their responsibilities under the new Delegation Order. 

TSA also provided additional technical comments on our draft report, 

which we have incorporated where appropriate. 

As agreed with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from the 

date of this report. At that time, we will send copies to appropriate 

congressional committees and subcommittees, the Secretary of Homeland 

Security, the Assistant Secretary of Homeland Security for TSA, and other 

interested parties. We will also make copies available to others upon 

request. In addition, the report will be available at no charge on GAO’s 

Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-3404 or at berrickc@gao.gov. Contact points for our Offices of 

Agency Comments 

and Our Evaluation 
Page 38 GAO-05-935 Aviation Security 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix IV. 

Sincerely yours, 

Cathleen A. Berrick 

Director, Homeland Security and Justice Issues 
Appendix I: Objective, Scope, and 

Methodology 

Page 39 GAO-05-935 Aviation Security 

To examine the role of the Federal Security Director (FSD), we addressed 

the following questions: (1) What are the roles and the responsibilities of 

FSDs and how clear is their authority relative to that of other airport 

stakeholders during security incidents? (2) To what extent are FSDs 

involved in the development of federal aviation security policy? (3) How 

have FSDs at selected airports formed and facilitated partnerships with 

airport stakeholders, and how are these partnerships working? (4) What 

key changes has the Transportation Security Administration (TSA) made 

or planned to make to better support or empower the FSD position, and 

how have selected FSDs viewed these efforts? 

To address aspects of each of these objectives, we interviewed TSA’s Chief 

Operating Officer and other TSA officials from headquarters offices, 

including the Aviation Security Program Office, Office of Law 

Enforcement, Office of Compliance Programs, and Office of Human 

Resources. We reviewed the Aviation and Transportation Security Act, and 

other relevant laws, as well as TSA documents related to the FSD position, 

including delegations of authority, position descriptions, the Executive 

FSD Guide, performance management guidance, and the FSD Advisory 

Council Charter. We also reviewed TSA documents related to its recent 

operational changes, such as the Next Generation Hiring Guide, 

Communication Liaison Group Mission Statement,1

 and the TSA 

Management Directive on Addressing Performance and Conduct 

Problems. We met with Department of Homeland Security (DHS) 

headquarters officials from the Border and Transportation Security 

Directorate, which oversees TSA, and Counter-Terrorism Division and 

Criminal Investigations Division officials within the Federal Bureau of 

Investigation (FBI) headquarters. To address all but the fourth objective, 

we also met with representatives of four national associations—the 

American Association of Airport Executives, Airports Council 

 1

 The Communications Liaison Group was subsequently renamed the Report Group, but the 

original mission statement remained in effect. 

Appendix I: Objective, Scope, and 

Methodology 
Appendix I: Objective, Scope, and 

Methodology 

Page 40 GAO-05-935 Aviation Security 

International, Air Transport Association, and Airport Law Enforcement 

Agencies Network. 2

In addition, to address all of this report’s objectives, we conducted field 

visits to seven airports. We selected these airports because they were 

close to our staff and incorporated all five airport security categories—

three airports with an FSD dedicated to a single airport and two sets of 

airports where the FSD was responsible for at least two airports. 

Specifically, we visited three category X airports (Los Angeles 

International Airport, California; Washington Dulles International Airport, 

Virginia; and Ronald Reagan Washington National Airport, Virginia); Bob 

Hope Airport, California (category I); Long Beach-Daugherty Field Airport, 

California (category II); Charlottesville-Albemarle Airport, Virginia 

(category III); and Shenandoah Valley Airport, Virginia (category IV). 

At each airport we visited, we met with local TSA officials and key airport 

stakeholders to discuss the role of the FSD and FSD-stakeholder 

partnerships and communication mechanisms. We met with the FSD (at 

the three airports with dedicated FSDs and the two hub airports) or the 

top-ranking TSA official (at the two spoke airports), as well as the 

Assistant FSDs for Law Enforcement and Regulatory Inspection, where 

these positions existed. During our meetings with FSDs, we also obtained 

their views on changes TSA had made or planned to make to enhance the 

FSD position. We also met with key airport stakeholders, including airport 

managers, airport law enforcement officials, station managers 

representing selected air carriers (15 representatives of 12 air carriers and, 

additionally, two air carrier representative groups specific to two airports 

we visited), and FBI Airport Liaison Agents and officials from DHS’s 

Customs and Border Protection as well as Immigration and Customs 

 2

 The American Association of Airport Executives, which represents over 800 airports 

(mostly domestic) and has approximately 4,000 members, works to shape federal policy 

governing aviation and ensure that the airport perspective is included as legislation and 

regulations are developed. The Airports Council International, with 567 members 

operating over 1,540 airports in 175 countries and territories, is an international association 

of airports whose primary purpose is to advance the interests of airports and to promote 

professional excellence in airport management and operations. The Air Transport 

Association is the only trade association of principal U.S. airlines. Among other things, it 

works with its members to support measures that enhance airport safety and security. The 

Airport Law Enforcement Agencies Network is composed of domestic and foreign airport 

law enforcement agencies, or port authorities and their associated national law 

enforcement, regulatory, or intelligence agencies. Its mandates include facilitating the 

exchange of information concerning airport-related crimes among member agencies and 

providing insight and experience to governmental agencies. 
Appendix I: Objective, Scope, and 

Methodology 

Page 41 GAO-05-935 Aviation Security 

Enforcement (at the two international airports we visited). At each airport, 

we conducted a single joint interview with representatives from multiple 

air carriers, and we selected air carriers through different means. At 

airports with an air carrier council, we asked the council head to identify 

approximately three carriers. Although we left the final decision to the 

council head, we suggested that he or she include the largest or one of the 

largest carriers (according to the percentage of the airport’s passenger 

travel) at the airport, an independent air carrier, and an international 

carrier, if it was an international airport. At airports without an air carrier 

council, the Air Transport Association or the airport operator 

recommended the air carriers. At the smallest airports, we met with all air 

carriers because of the small numbers. Because we selected a 

nonprobability sample of airports to visit, the information we obtained 

during these visits cannot be generalized to all airports or FSDs across the 

nation. 

To corroborate what we learned from the five FSDs during our field visits, 

we telephoned 25 additional FSDs to obtain their views on a range of 

topics including recent TSA initiatives and federal aviation security policy. 

We also included selected questions—regarding their need for greater 

authority and flexibility—that we had posed in our March 2004 Web-based 

survey of all 155 FSDs, conducted to support other GAO aviation security 

reviews. This allowed us to make a rough comparison between the 2004 

responses and 2005 responses to these questions. We selected a random 

sample of FSDs in place since September 1, 2004, to ensure they had an 

experience base from which to answer our questions.3

 We excluded from 

the list the five FSDs we interviewed during our airport visits and 

individuals who were no longer FSDs. 4 TSA reviewed our selection 

procedures but did not know the identities of the specific 25 FSDs we 

interviewed. The 25 FSDs were from a cross section of all five airport 

security categories. A GAO survey specialist who was involved in 

designing the Web-based survey, along with GAO staff knowledgeable 

about issues facing FSDs developed the structured telephone interview 

 3

 Twenty-one of the 25 FSDs we interviewed had responded to our March 2004 survey of all 

FSDs. Twenty of the 21 FSDs were named as FSDs in 2002, and the other 1 became an FSD 

in 2003. The 4 FSDs who were not included in the March 2004 survey were not named as 

FSDs until later in 2004, after we conducted the initial survey. 

4

 We based our sample on a September 2004 list of FSDs. We subsequently updated this list 

based on our review of TSA press releases of new FSD assignments made from September 

2004 through March 2005, and then verified our revised list with TSA for accuracy and 

completeness before drawing our sample of FSDs. 
Appendix I: Objective, Scope, and 

Methodology 

Page 42 GAO-05-935 Aviation Security 

instrument. We conducted pretest interviews with 3 FSDs to ensure that 

the questions were clear and concise, and subsequently conducted the 25 

telephone interviews from late April to early May 2005. Although the 

telephone interviews were conducted with a random sample of FSDs, the 

sample is too small to generalize the interview results to all FSDs across 

the nation with reliable statistical precision. 

The practical difficulties of conducting interviews may introduce errors, 

commonly referred to as nonsampling errors. For example, difficulties in 

how a particular question is interpreted, in the sources of information that 

are available to respondents, or in how the data were analyzed can 

introduce unwanted variability into the results. We took steps in the 

development of the questions, the data collection, and the data analysis to 

minimize these nonsampling errors. For example, a survey specialist 

helped develop the interview questions in collaboration with GAO staff 

with subject matter expertise. Then, as mentioned earlier, the draft 

questions were pretested to ensure that the questions were relevant, 

clearly stated, and easy to comprehend. Interviews were conducted by 

GAO staff familiar with the subject matter and proper interviewing 

procedures. Finally, when the data were analyzed, a second, independent 

analyst checked to make sure that the results were correct. 

We conducted our work from August 2004 through September 2005 in 

accordance with generally accepted government auditing standards. 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 43 GAO-05-935 Aviation Security 

Appendix II: Responses to Selected 

Questions from Interviews with 25 Federal 

Security Directors 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 44 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 45 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 46 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 47 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 48 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 49 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 50 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 51 GAO-05-935 Aviation Security 
Appendix II: Responses to Selected Questions 

from Interviews with 25 Federal Security 

Directors 

Page 52 GAO-05-935 Aviation Security 
Appendix III: Comments from the Department 

of Homeland Security 

Page 53 GAO-05-935 Aviation Security 

Appendix III: Comments from the 

Department of Homeland Security 
Appendix III: Comments from the Department 

of Homeland Security 

Page 54 GAO-05-935 Aviation Security 
Appendix IV: GAO Contact and Staff Acknowledgments 

Page 55 GAO-05-935 Aviation Security 

Cathleen A. Berrick, (202) 512-8777 or berrickc@gao.gov

In addition to the contact mentioned above, Glenn Davis, Assistant 

Director; David Alexander; Grace Coleman; Tracey Cross; Wayne Ekblad; 

David Hancock; Stuart Kaufman; Janice Latimer; Thomas Lombardi; and 

Lori Weiss made key contributions to this report. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(440322) 
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