Report to Congressional Requesters

United States Government Accountability Office

GAO

September 2005 PASSENGER RAIL 

SECURITY 

Enhanced Federal 

Leadership Needed to 

Prioritize and Guide 

Security Efforts 

GAO-05-851 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-851.

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 JayEtta Hecker 

at (202) 512-2834 

Highlights of GAO-05-851, a report to 

congressional requesters 

September 2005

PASSENGER RAIL SECURITY 

Enhanced Federal Leadership Needed to 

Prioritize and Guide Security Efforts 

Within DHS, the Office for Domestic Preparedness has completed 7 risk 

assessments of passenger rail systems around the country, with 12 more 

under way. TSA has begun to conduct risk assessments and to establish a 

methodology for determining how to analyze and characterize risks that 

have been identified but has not yet completed either effort or set timelines 

for doing so. TSA will not be able to prioritize passenger rail assets and help 

guide security investment decisions until these efforts are completed. At the 

department level, DHS has begun developing, but has not yet completed, a 

framework to help agencies and the private sector develop a consistent 

approach for analyzing and comparing risks to transportation and other 

sectors. Until this framework is finalized and shared with stakeholders, it 

may not be possible to compare risks across different sectors, prioritize 

them, and allocate resources accordingly. 

The Federal Transit Administration and Federal Railroad Administration 

within DOT have ongoing initiatives to enhance passenger rail security. In 

addition, in 2004, TSA issued emergency security directives to domestic rail 

operators after terrorist attacks on the rail system in Madrid, Spain, and 

piloted a test of explosive detection technology for use in passenger rail 

systems. However, federal and rail industry officials raised questions about 

the feasibility of implementing and complying with the directives, citing 

limited opportunities to collaborate with TSA to ensure that industry best 

practices were incorporated. In September 2004, DHS and DOT signed a 

memorandum of understanding to improve coordination between the two 

agencies, and they are developing agreements to address specific rail 

security issues. 

Domestic and foreign passenger rail operators we contacted have taken a 

range of actions to help secure their systems. We also observed security 

practices among certain foreign passenger rail systems or their governments 

that are not currently used by the domestic rail operators we contacted, or 

by the U.S. government, and which could be considered for use in the United 

States. For example, some foreign rail operators randomly screen 

passengers, and some foreign governments maintain centralized 

clearinghouses on rail security technologies and best practices.

Source: Developed by GAO with photo provided by Washington Metropolitan Area Transit Authority.

Example of high 

visibility canine sweep 

at mass transit station

The U.S. passenger rail system is a 

vital component of the nation’s 

transportation infrastructure, 

carrying more than 11 million 

passengers each weekday. The 

Department of Homeland Security 

(DHS) and the Department of 

Transportation (DOT) share 

responsibility for ensuring the 

safety and security of rail systems. 

In this report, GAO addressed 

(1) DHS actions to assess the risks 

to the U.S. passenger rail system in 

the context of prevailing risk 

management principles, (2) federal 

actions taken to enhance the 

security of the U.S. passenger rail 

system, and (3) security practices 

that domestic and selected foreign 

passenger rail operators have 

implemented. 

What GAO Recommends

GAO is recommending, among 

other things, that the Secretary of 

DHS direct the Assistant Secretary 

of the Transportation Security 

Administration (TSA) to develop a 

plan with timelines for completing 

its methodology for conducting risk 

assessments and develop rail 

security standards that can be 

measured and enforced. The 

Secretary also should consider the 

feasibility of implementing certain 

security practices used by foreign 

operators. DHS, DOT, and Amtrak 

reviewed a draft of this report and 

generally agreed with the report’s 

recommendations. DHS’s detailed 

comments and GAO’s response are 

contained in the report. 
Page i GAO-05-851 Passenger Rail Security 

Letter 1

Results in Brief 4 

Background 8 

DHS Has Taken Steps to Assess Risk to Passenger Rail Systems, 

but Additional Work Is Needed to Guide Security Investments 20 

Multiple Federal Agencies Have Taken Actions to Enhance 

Passenger Rail Security 32 

U.S. and Foreign Rail Operators Have Taken Similar Actions to 

Secure Rail Systems, and Opportunities for Additional Domestic 

Security Actions May Exist 45 

Conclusions 68 

Recommendations for Executive Action 71 

Agency Comments and Our Evaluation 72 

Appendix I Objectives, Scope, and Methodology 79 

Appendix II Elements of a Typical Homeland Security Risk 

Assessment 84 

Appendix III FTA and ODP Passenger Rail Risk Assessments 

Conducted or In Progress 85 

FTA Risk Assessments Conducted 85 

ODP Risk Assessments 86 

Appendix IV Comments from the Department of Homeland 

Security 88 

Appendix V GAO Contacts and Staff Acknowledgments 94 

Tables 

Table 1: Selected Roles and Responsibilities of Federal Agencies 

Related to Risk Management and Critical Infrastructure 

Protection 18 

Contents 
Page ii GAO-05-851 Passenger Rail Security 

Table 2: Selected Steps in ODP’s Risk Assessment Process 22 

Table 3: Examples of Measures Required by TSA Security 

Directives Issued to Passenger Rail Operators and Amtrak 36 

Table 4: Domestic Passenger Rail Agencies We Visited or 

Interviewed for the Purposes of this Review 80 

Table 5: Foreign Passenger Rail and Government Agencies We 

Visited or Interviewed for the Purposes of This Review 82 

Figures 

Figure 1: Geographic Distribution of Amtrak and Rail Transit 

Systems 9 

Figure 2: Risk Management Cycle 14 

Figure 3: Sample ODP Relative Risk Diagram 23 

Figure 4: Status of TSA’s Passenger Rail Risk Assessment Efforts, 

as of July 2005 30 

Figure 5: Summary Information on TSA’s Transit and Rail 

Inspection Pilot Program Phases 41 

Figure 6: Example of Passenger Rail Customer Awareness Poster 49 

Figure 7: Wallet-size Cards Distributed to BART Employees 

Containing Anti-terrorism Information 52 

Figure 8: Selected Security Design Elements Incorporated into 

London’s Underground 58 

Figure 9: Security Design Elements Incorporated into London’s 

Underground 59 

Figure 10: Composite of Selected Security Practices in the 

Passenger Rail Environment 61 
Page iii GAO-05-851 Passenger Rail Security 

Abbreviations

AAR American Association of Railroads 

APTA American Public Transportation Association 

ATSA Aviation and Transportation Security Act 

BART San Francisco Bay Area Rapid Transit 

CCTV closed-circuit television 

DHS Department of Homeland Security 

DOT Department of Transportation 

FRA Federal Railroad Administration 

FTA Federal Transit Administration 

HSPD-7 Homeland Security Presidential Directive-7 

IAIP Information Analysis and Infrastructure Protection 

MBTA Massachusetts Bay Transportation Authority 

MOU memorandum of understanding 

NIPP National Infrastructure Protection Plan 

ODP Office for Domestic Preparedness 

PANYNJ Port Authority of New York and New Jersey 

PATH Port Authority Trans-Hudson 

PDA personal digital assistant 

RATP Regie Autonome des Transports Parisiens 

SLGCP Office of State and Local Government Coordination 

 and Preparedness 

TRIP Transit and Rail Inspection Pilot 

TSA Transportation Security Administration 

TSSP transportation sector-specific plan 

UASI Urban Area Security Initiative 

WMATA Washington Metropolitan Area Transit Authority 

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Page 1 GAO-05-851 Passenger Rail Security 

September 9, 2005 

The Honorable Steven LaTourette 

Chairman 

Subcommittee on Railroads 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Olympia Snowe 

United States Senate 

The Honorable Barbara Boxer 

United States Senate 

The Honorable Michael Castle 

House of Representatives 

The July 7 and July 21, 2005, bomb attacks on London’s subway system, 

which resulted in over 50 fatalities and more than 700 injuries, 

dramatically highlighted the vulnerability of passenger rail systems 

worldwide to terrorist attacks and the need for an increased focus on 

security for these systems. The U.S. passenger rail system is a vital 

component of the nation’s transportation infrastructure, encompassing rail 

transit (heavy rail, commuter rail, and light rail) and intercity rail systems.1

Together, these systems carry more than 11 million passengers each 

weekday. One of the critical challenges facing rail system operators—and 

the federal agencies that regulate and oversee them—is finding ways to 

protect rail systems from potential terrorist attacks without compromising 

the accessibility and efficiency of rail travel. 

 1

The U.S. passenger rail system consists of heavy, commuter, light, and intercity rail 

systems. Heavy rail is an electric railway that can carry a heavy volume of traffic. Heavy 

rail is characterized by high speed and rapid acceleration, passenger rail cars operating 

singly or in multi-car trains on fixed rails, separate rights of way from which all other 

vehicular and foot traffic is excluded, sophisticated signaling, and high-platform loading. 

Most subway systems are considered heavy rail. Commuter rail is characterized by 

passenger trains operating on railroad tracks and providing regional service, such as 

between a central city and its adjacent suburbs. Light rail systems typically operate 

passenger rail cars singly (or in short, usually two-car, trains) and are driven electrically 

with power being drawn from an overhead electric line. Amtrak operates the nation’s 

primary intercity rail system. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-851 Passenger Rail Security 

Several entities play a role in helping to fund and secure the passenger rail 

industry. The Department of Homeland Security’s (DHS) Transportation 

Security Administration (TSA) is the primary regulator of the rail system’s 

security, while DHS’s Office for Domestic Preparedness (ODP) has been 

the primary federal source of security funding for passenger rail systems. 

In addition, the Department of Transportation’s (DOT) Federal Transit 

Administration (FTA) and Federal Railroad Administration (FRA), state 

and local agencies (which operate most rail transit rail systems), and 

Amtrak are responsible for or have been involved in the security and 

safety of the U.S. passenger rail system. 

In the United States, passenger rail systems represent one of many modes 

of transportation—along with aviation, maritime, and others—competing 

for limited federal security resources. Within the passenger rail sector 

itself, there is competition for resources, as federal, state, and local 

agencies and rail operators seek to identify and invest in appropriate 

security measures to safeguard these systems while also investing in other 

capital and operational improvements. Moreover, given competing 

priorities and limited homeland security resources, difficult policy 

decisions have to be made by Congress and the executive branch to 

prioritize security efforts and direct resources to areas of greatest risk 

within the passenger rail system, among all transportation modes, and 

across other nationally critical sectors. 

In this regard, to help federal decision makers determine how to best 

allocate limited resources, we have advocated, the National Commission 

on Terrorist Attacks Upon the United States (the 9/11 Commission) has 

recommended, and the subsequent Intelligence Reform and Terrorism 

Prevention Act of 2004 requires, that a risk management approach be 

employed to guide security decision making. 2 A risk management 

approach entails a continuous process of managing risks through a series 

of actions, including setting strategic goals and objectives, assessing and 

quantifying risks, evaluating alternative security measures, selecting which 

measures to undertake, and implementing and monitoring those measures. 

In July 2005, in announcing his proposal for the reorganization of DHS, the 

Secretary of the Department of Homeland Security declared that as a core 

principle of the reorganization, the department must base its work on 

priorities driven by risk. 

 2

Pub. L. No. 108-458, 118 Stat. 3638. 
Page 3 GAO-05-851 Passenger Rail Security 

You have expressed interest in the progress federal agencies and domestic 

passenger rail operators have made in setting and implementing security 

priorities in the wake of September 11 and terrorist attacks on rail 

systems. In addition, you expressed interest in learning about the security 

practices implemented by foreign passenger rail operators. For this report, 

we analyzed (1) the actions that DHS and its component agencies have 

taken to assess the risks posed by terrorism to the U.S. passenger rail 

system in the context of prevailing risk management principles; (2) the 

actions that federal agencies have taken to enhance the security of the U.S. 

passenger rail system; and (3) the security practices that domestic and 

selected foreign passenger rail operators have implemented to mitigate 

risks and enhance security, and any differences in these practices. 

To perform our analyses, we conducted site visits at, or held 

teleconferences with, a total of 32 passenger rail operators in the United 

States that represent over 95 percent of the nation’s total rail ridership, as 

well as Amtrak. We also conducted site visits or met elsewhere with 13 

passenger rail operators in seven European and Asian countries. During 

our domestic and international visits, we interviewed management and 

security personnel, toured stations and other facilities such as control 

centers, observed security practices, and obtained documentation of 

security procedures. In addition, we interviewed officials from domestic 

and foreign rail industry associations, foreign governments and rail 

operators, and representatives of the European Commission. Because we 

selected a nonprobability sample of both foreign and domestic passenger 

rail operators, the information we obtained from these interviews and 

visits cannot be generalized to all foreign or domestic rail operators. 

We also reviewed risk assessments of U.S. rail systems conducted by the 

federal government. Risk assessments are used to identify and rank risks 

to critical regional or national assets to further identify which would be 

most vulnerable to attack based on various threat scenarios. Risk 

assessments are an integral part of using a broader risk management 

approach to guide investments that help enhance security. While a risk 

management approach entails multiple iterative components, this report 

primarily addresses the risk assessment component of such an approach 

as applied in the homeland security context. (Additional information about 

the risk assessment component is contained in app. II.) Although we 

identified and cataloged security practices of the domestic and foreign 

passenger rail operators we contacted, we did not evaluate the 

appropriateness or effectiveness of these practices. We discussed foreign 

security practices we observed with DHS, DOT, passenger rail industry 

associations, select passenger rail operators, and transportation security 
Page 4 GAO-05-851 Passenger Rail Security 

experts from the RAND Corporation and the Mineta Transportation 

Institute to explore the potential applicability of these practices to U.S. 

passenger rail systems. 3 Our work does not reflect the proposed 

reorganization of DHS and its component agencies announced by the 

Secretary of DHS. We conducted our work from May 2004 through July 

2005 in accordance with generally accepted government auditing 

standards. Appendix I contains more details about our objectives, scope, 

and methodology. 

Two component agencies with different missions within DHS are 

responsible for, and have engaged in, conducting risk assessments for the 

passenger rail industry, in an effort to identify and protect the assets most 

vulnerable to attack and most critical to operations, such as stations, 

tracks, and bridges. The first, the Office for Domestic Preparedness, is 

responsible for, among other things, providing grant funds and technical 

assistance to rail operators and others to improve preparedness at the 

state and local level. As part of this mission, ODP has developed and 

implemented a risk assessment methodology for mass transit agencies and 

port authorities, and used it to complete 7 risk assessments at rail 

facilities, with an additional 12 assessments in progress, as of July 2005. 

According to passenger rail operators we interviewed, ODP’s risk 

management approach has helped them to prioritize and allocate 

resources to protect their systems. For example, one operator 

collaborated with ODP on a risk assessment that resulted in justifying a 

$500 million high-priority security capital investment program, which is to 

fund, among other things, a security operations center for its passenger 

train network, alarm monitoring systems, and an upgraded closed-circuit 

television system. The second agency, TSA, has also recently begun to 

conduct risk assessments of the rail sector as part of a broader effort to 

assess risk to all transportation modes. As of July 2005, while TSA had 

completed an overall threat assessment for mass transit and passenger 

rail, the agency had not yet completed a risk assessment for the passenger 

rail sector or a methodology for determining how to analyze and 

characterize risk (as high, medium, or low) identified through 

assessments, or indicated when this would be done. Until both of these 

efforts have been accomplished, in collaboration with rail industry 

stakeholders, TSA will not be able to prioritize passenger rail assets based 

 3

The institute was established by Congress as part of the Intermodal Surface 

Transportation Efficiency Act of 1991 and focuses on international surface transportation 

policy issues involving research, education, and technology transfer. RAND is a nonprofit 

research organization that analyzes security issues in the rail sector, among other things. 

Results in Brief 
Page 5 GAO-05-851 Passenger Rail Security 

on risk and help guide investment decisions about protecting them. A 2003 

presidential directive required DHS to, among other things, establish 

uniform guidelines and methodologies for integrating federal 

infrastructure protection and risk management activities within and across 

entire economic sectors, such as transportation (including rail), energy, 

and agriculture. To address this requirement, at the department level, DHS 

has been developing a broad framework intended to help federal agencies, 

the private sector, and state and local governments develop a consistent 

approach to analyzing risk to critical infrastructure within and across 

sectors. This framework is intended to enable risks across sectors to be 

compared as a means of guiding resource allocation and emergency 

response planning. Because DHS has not yet finalized this framework, it is 

not known what impact, if any, it may have on risk assessment efforts now 

under way by TSA, ODP, and other federal agencies with critical 

infrastructure protection responsibilities. Until DHS finalizes this 

framework, it may not be possible to compare risks across different 

sectors, prioritize them, and then allocate resources accordingly. 

A number of federal departments and their component agencies have 

taken actions to strengthen passenger rail security. FTA and FRA were the 

primary federal agencies involved in passenger rail security matters prior 

to the creation of TSA, and both undertook numerous initiatives both 

before and after September 11, 2001. For example, FTA conducted 

security readiness assessments, sponsored security training, and 

developed security guidance for transit agencies. FRA conducted security 

inspections of commuter railroads and researched various rail security 

technologies. After taking over as the lead federal agency responsible for 

transportation security, TSA issued security directives to the passenger 

rail industry in May 2004, after terrorists attacked the commuter rail 

system in Madrid, Spain. The directives—based upon industry best 

practices, according to TSA—required rail operators to implement a 

number of security measures, such as conducting frequent inspections of 

stations, terminals, and other assets, or utilizing canine explosive 

detection teams, if available. According to TSA officials, because of the 

need to act quickly, the rule-making process for these security directives 

did not include a public comment period. As a result, stakeholder input 

was limited. The rapid issuance of these directives has posed challenges to 

TSA and rail operators. For example, while rail operators are required to 

implement the measures, and TSA has hired rail inspectors to enforce 

them, operators told TSA they were unsure how to comply with the 

directives because, for example, the directives include instructions 

requiring them to perform “frequent inspections” of key facilities, without 

defining relevant parameters. TSA told rail operators when the directives 
Page 6 GAO-05-851 Passenger Rail Security 

were issued that additional performance-based guidance would be 

provided to clarify the directives requirements, but this information has 

not been supplied. Further, TSA has not yet developed criteria or 

procedures for rail inspectors to use in enforcing compliance with the 

directives. In addition, stakeholders we contacted questioned the extent to 

which the security directives reflected industry best practices. For 

example, one requirement of the directives was that the doors of the rail 

engineer’s compartment be locked, which conflicts with an existing FRA 

safety regulation calling for these doors to remain unlocked for escape 

purposes. In September 2004, in response to our prior recommendation, 

DHS and DOT signed a memorandum of understanding (MOU) intended to 

identify ways to improve coordination and collaboration between and 

among federal and rail industry stakeholders. 4 As of July 2005, the 

departments were developing agreements within the framework of this 

memorandum to delineate specific security-related roles, responsibilities, 

and resources for mass transit, rail, research and development, and other 

matters.5

 However, none of the agreements have been finalized and 

timelines have not been established for doing so. Completing these 

agreements could help to ensure that federal activities to secure passenger 

rail systems are coordinated and that stakeholders are appropriately 

involved in the development and implementation of these activities. 

Domestic and foreign passenger rail operators we contacted or visited 

have generally taken similar actions to help secure their systems against 

the risk posed by terrorism. Specifically, most U.S. and foreign operators 

we contacted had implemented customer awareness programs to 

encourage passengers to remain vigilant and report suspicious activities, 

increased the number and visibility of their security personnel, increased 

the usage of canine teams to detect drugs and explosives, enhanced 

employee training programs, upgraded security technology, tightened 

access controls, and made system design improvements to enhance 

security. However, we observed security practices among certain foreign 

passenger rail systems or their governments that were not in use, at the 

 4

GAO, Mass Transit: Federal Actions Could Help Transit Agencies Address Security 

Challenges, GAO-03-263 (Washington, D.C.: Dec. 13, 2002), and Transportation Security: 

Federal Action Needed to Help Address Security Challenges, GAO-03-843 (Washington, 

D.C.: June 2003). 

5

The Safe, Accountable, Flexible, and Efficient Transportation Equity Act of 2005 (P.L. 109-

59) enacted on August 10, 2005, requires DOT and DHS to complete an agreement within 45 

days of enactment to define and clarify their respective roles related to public 

transportation security. 
Page 7 GAO-05-851 Passenger Rail Security 

time we completed our fieldwork in June 2005, by the domestic rail 

operators we contacted or the U.S. government. For example, we found 

that 2 of 13 foreign rail operators we contacted utilize covert testing to 

help keep employees alert to security threats. In one type of covert test, 

suspicious items are placed throughout the rail system and employees are 

observed to see how long it takes them to find the objects. In addition, 2 of 

13 foreign rail operators we visited randomly screen passengers and their 

baggage. After the July 7, 2005, London bombings, four domestic 

passenger rail operators began randomly screening passengers and their 

baggage on a limited basis. Further, in five countries we visited, national 

governments have centralized research on security technologies and 

maintain clearinghouses on these technologies and security best practices, 

giving rail operators a single source for identifying and comparing, among 

other things, chemical sensors, closed-circuit television, and intrusion 

detection systems. Introducing any of these security practices into the U.S. 

rail system may pose political, legal, fiscal, and cultural challenges, but 

may nevertheless warrant examination to determine whether they could 

enhance the security of domestic rail systems. 

To help ensure that the federal government has the information it needs to 

prioritize passenger rail assets based on risk, and in order to evaluate, 

select, and implement commensurate measures to help the nation’s 

passenger rail operators protect their systems against acts of terrorism, we 

are making several recommendations. Among them, we recommend that 

TSA establish a plan with timelines for completing its methodology for 

conducting risk assessments, develop security standards that reflect 

industry best practices and can be measured and enforced, and set 

timelines for completing memorandum of understanding agreements. In 

addition, we are recommending that the Secretary of DHS determine the 

feasibility, in a risk management context, of implementing certain security 

practices used by foreign rail operators. These recommendations should 

be implemented in collaboration with DOT and the passenger rail industry. 

We provided DHS, DOT, and Amtrak a draft of this report for review and 

comment. DOT and Amtrak generally agreed with our findings and 

recommendations and provided technical comments, which we have 

incorporated where appropriate. DHS generally concurred with the 

report’s recommendations. However, DHS raised questions about, among 

other things, the extent to which the report reflected the agency’s efforts 

to involve federal and rail industry stakeholders in the development of 

security directives and criticality assessments. According to TSA, the 

emergency circumstances under which the directives were issued allowed 

for only limited input and review by federal and rail industry stakeholders. 

However, we believe that using the federal rule-making process as a means 
Page 8 GAO-05-851 Passenger Rail Security 

of establishing permanent standards would make the process more 

transparent and could help TSA in developing standards that are most 

appropriate for the industry and which can be measured, monitored, and 

enforced. These stakeholders will be involved in administering, 

implementing, and/or enforcing TSA standards and stakeholder buy-in 

would be critical to the success of such initiatives. DHS’s comments 

appear in appendix IV. 

Each weekday, 11.3 million passengers in 35 metropolitan areas and 22 

states use some form of rail transit.6

 Heavy rail systems—subway systems 

like New York City’s transit system and Washington, D.C.’s Metro—

typically operate on fixed rail lines within a metropolitan area and have 

the capacity for a heavy volume of traffic. Commuter rail systems typically 

operate on railroad tracks and provide regional service (e.g., between a 

central city and adjacent suburbs). Commuter rail systems are traditionally 

associated with older industrial cities, such as Boston, New York, 

Philadelphia, and Chicago. Light rail systems are typically characterized by 

lightweight passenger rail cars that operate on track that is not separated 

from vehicular traffic for much of the way. All types of rail transit systems 

in the United States are typically owned and operated by public sector 

entities, such as state and regional transportation authorities. 

Amtrak operates the nation’s primary intercity passenger rail service over 

a 22,000-mile network, primarily over leased freight railroad tracks.7

Amtrak serves more than 500 stations (240 of which are staffed) in 46 

states and the District of Columbia, and it carried more than 25 million 

passengers in 2004. According to Amtrak, about two-thirds of its ridership 

is wholly or partially on the “Northeast Corridor,” between Boston and 

Washington, D.C. Amtrak owns about 650 miles of track, primarily on the 

Northeast Corridor. Stations are owned by Amtrak, freight carriers, 

municipalities, and some private entities. Amtrak also operates commuter 

rail services in certain jurisdictions on behalf of state and regional 

 6

The American Public Transportation Association compiled this fiscal year 2003 ridership 

data from FTA’s National Transit Database. These are the most current data available. Rail 

transit systems in the District of Columbia and Puerto Rico are included in these statistics. 

7

The Alaska Railroad Corporation also operates intercity passenger rail service. 

Background 

Overview of the U.S. 

Passenger Rail System 
Page 9 GAO-05-851 Passenger Rail Security 

transportation authorities. Figure 1 identifies the geographic location of 

rail transit systems and Amtrak within the United States. 

Figure 1: Geographic Distribution of Amtrak and Rail Transit Systems 

Source: Amtrak and National Transit Database.

Amtrak train stations

Number of light rail systems in city

Amtrak rail network

Number of Heavy rail systems in city

Number of commuter rail systems in city

Miami

Atlanta

Baltimore

New York

Philadelphia

New Jersey cities

Boston

Chicago

St. Louis

Dallas

Houston Galveston

New Orleans

Cleveland

Memphis

Harrisburg

Detroit Pittsburgh

Washington, DC

New Haven

San Diego

Los Angeles

Tampa

San Jose

San Juan

San Francisco

Sacramento

Seattle

Tacoma

Portland

Denver

Salt Lake City

#

#

1

1 1

1

1 1

1

1

2

1

1

1

1

1

3 3

2 1

1

1 2

1

1 1 1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

Buffalo

Kenosha

Minneapolis

1

1

1

1

1

1

1

1

1

1

3

#
Page 10 GAO-05-851 Passenger Rail Security 

To date, U.S. passenger rail systems have not been targets of terrorist 

attacks. However, worldwide, public transportation in general and 

passenger rail in particular, have been attacked multiple times, sometimes 

with grave results. According to a database of worldwide terrorist 

incidents maintained by the RAND Corporation, from 1995 to June 2005, 

there have been over 250 terrorist attacks worldwide against rail targets, 

resulting in almost 900 deaths and over 6,000 injuries.8

 Among them were 

the fatal 1995 sarin gas attack on the Tokyo subway system by the Aum 

Shinri Kyo doomsday cult, resulting in 12 deaths and 5,000 injuries; the 

December 2003 bomb attack by Chechen rebels on a Russian commuter 

train, resulting in 46 fatalities and 165 injuries; and the March 2004 

terrorist bombing attacks on commuter trains in Madrid, for which an al 

Qaeda affiliate organization claimed responsibility, and in which 191 

people were killed and 600 were injured. 

According to passenger rail officials and passenger rail experts, certain 

characteristics of domestic and foreign passenger rail systems make them 

inherently vulnerable to terrorist attacks and therefore difficult to secure. 

By design, passenger rail systems are open (i.e., have multiple access 

points, hubs serving multiple carriers, and, in some cases, no barriers) so 

that they can move large numbers of people quickly. In contrast, the U.S. 

commercial aviation system is housed in closed and controlled locations 

with few entry points. The openness of passenger rail systems can leave 

them vulnerable because operator personnel cannot completely monitor 

or control who enters or leaves the systems. In addition, other 

characteristics of some passenger rail systems—high ridership, expensive 

infrastructure, economic importance, and location (e.g., large 

metropolitan areas or tourist destinations)—also make them attractive 

targets for terrorists because of the potential for mass casualties and 

economic damage and disruption. Moreover, some of these same 

characteristics make passenger rail systems difficult to secure. For 

example, the numbers of riders that pass through a subway system—

especially during peak hours—may make the sustained use of some 

security measures, such as metal detectors, difficult because they could 

result in long lines that could disrupt scheduled service. In addition, 

multiple access points along extended routes could make the cost of 

securing each location prohibitive. Balancing the potential economic 

 8

These statistics do not include the July 2005 London attacks, which resulted in over 50 

fatalities and over 700 injuries. 

Passenger Rail Systems 

Are Inherently Vulnerable 

to Terrorist Attacks 
Page 11 GAO-05-851 Passenger Rail Security 

impacts of security enhancements with the benefits of such measures is a 

difficult challenge. 

Securing the nation’s passenger rail systems is a shared responsibility 

requiring coordinated action on the part of federal, state, and local 

governments; the private sector; and rail passengers who ride these 

systems. Since the September 11 attacks, the role of federal government 

agencies in securing the nation’s transportation systems, including 

passenger rail, have continued to evolve. Prior to September 11, DOT—

namely FTA and FRA—was the primary federal entity involved in 

passenger rail security matters. In response to the attacks of September 

11, Congress passed the Aviation and Transportation Security Act (ATSA), 

which created TSA within DOT and defined its primary responsibility as 

ensuring security in all modes of transportation.9

 The act also gave TSA 

regulatory authority for security over all transportation modes. ATSA does 

not specify TSA’s roles and responsibilities in securing the maritime and 

land transportation modes at the level of detail it does for aviation 

security. Instead, the act broadly identifies that TSA is responsible for 

ensuring the security of all modes of transportation. With the passage of 

the Homeland Security Act of 2002, TSA was transferred, along with over 

20 other agencies, to the Department of Homeland Security.10

With the creation of DHS in 2002, one of its components, ODP, became the 

primary federal source for security funding for passenger rail systems. 11

ODP is the principal component of DHS responsible for preparing the 

United States for acts of terrorism and has primary responsibility within 

the executive branch for assisting and supporting DHS, in coordination 

with other directorates and entities outside of the department, in 

 9

Pub. L. No. 107-71, 115 Stat. 597 (2001). 

10Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

11The Department of Justice established ODP in 1998 within the Office of Justice Programs. 

ODP was subsequently transferred to DHS’s Directorate of Border and Transportation 

Security upon DHS’s creation in March 2003 (Homeland Security Act of 2002, section 

403(5), 6 U.S.C. 203(5)). In March 2004, the Secretary of Homeland Security consolidated 

ODP with the Office of State and Local Government Coordination to form the Office of 

State and Local Government Coordination and Preparedness (SLGCP). SLGCP, which 

reports directly to the DHS Secretary, was created to provide a “one-stop shop” for the 

numerous federal preparedness initiatives applicable to state and local governments. The 

proposed reorganization of DHS may result in transferring portions of ODP to a newly 

established Directorate of Preparedness. 

Multiple Stakeholders 

Share Responsibility for 

Securing Passenger Rail 

Systems 
Page 12 GAO-05-851 Passenger Rail Security 

conducting risk analysis and risk management activities of state and local 

governments.12 In carrying out its mission, ODP provides training, funds 

for the purchase of equipment, support for the planning and execution of 

exercises, technical assistance, and other support to assist states, local 

jurisdictions, and the private sector to prevent, prepare for, and respond to 

acts of terrorism. Through the Urban Area Security Initiative (UASI) grant 

program, ODP has provided grants to urban areas to help enhance their 

overall security and preparedness level to prevent, respond to, and recover 

from acts of terrorism. In 2003 and 2004, $65 million and $50 million, 

respectively, were allocated to rail transit agencies through the UASI 

program. In addition, the DHS Appropriations Act of 2005 appropriated 

$150 million for rail transit, intercity passenger rail, freight rail, and transit 

agency security grants. 13 This funding has allowed ODP to build upon the 

work under way through the UASI program and create and administer two 

new programs focused specifically on transportation security, the Transit 

Security Grant Program and the Intercity Passenger Rail Security Grant 

Program. These programs provide financial assistance to address security 

preparedness and enhancements for transit (to include commuter, heavy, 

and light rail systems, intracity bus, and ferry), and intercity rail (Amtrak) 

systems. The grant programs specifically provide funding for the 

prevention and detection of explosive devices and chemical, biological, 

radiological, and nuclear agents. About $108 million was provided to rail 

transit agencies and $7.1 million to Amtrak through these grant programs 

in 2005.14

While TSA is the lead federal agency for ensuring the security of all 

transportation modes, FTA conducts nonregulatory safety and security 

activities, including safety- and security-related training, research, 

technical assistance, and demonstration projects. In addition, FTA 

promotes safety and security through its grant-making authority. FTA 

provides financial assistance to rail transit agencies to plan and develop 

new systems and operate, maintain, and improve existing systems. FTA 

stipulates conditions of grants, such as certain safety and security 

statutory and regulatory requirements, and FTA may withhold funds for 

 12At the time of our review, DHS was undertaking a departmentwide reorganization that 

will affect both the structure and functions of DHS directorates and component agencies. 

13Pub. L. No. 108-334, 118 Stat. 1298 (2004). 

14The remaining funds were used to provide security grants for intracity bus and freight rail 

systems and for technical assistance and management and administration purposes. 49 

USC 5307 (d)(1)(J)(i). 
Page 13 GAO-05-851 Passenger Rail Security 

noncompliance with the conditions of a grant.15 While FTA cannot regulate 

safety and security operations at transit agencies,16 FRA has regulatory 

authority for rail safety over commuter rail operators and Amtrak, and 

employs over 400 rail inspectors that periodically monitor the 

implementation of safety and security plans at these systems.17

State and local governments, passenger rail operators, and private industry 

are also important stakeholders in the nation’s rail security efforts. State 

and local governments play a vital role, in part, because they may own or 

operate a significant portion of the passenger rail system. Even when state 

and local governments are not owners and operators, they are directly 

affected by passenger rail systems that run within and through their 

jurisdictions. Consequently, the responsibility for responding to 

emergencies involving the passenger rail infrastructure often falls to state 

and local governments. 

Passenger rail operators, which can be public or private entities, are 

responsible for administering and managing passenger rail activities and 

services, including security. Passenger rail operators can directly operate 

the service provided or contract for all or part of the total service. 

Although all levels of government are involved in passenger rail security, 

the primary responsibility for securing passenger rail systems rests with 

the passenger rail operators. We discuss actions taken by federal agencies 

and passenger rail operators to enhance security in more detail later in 

this report. 

 15For example, transit agencies must spend 1 percent of their urbanized area formula funds 

on security improvements. FTA is to verify that agencies comply with this requirement and 

may withhold funding from agencies that it finds are not in compliance. Agencies are not 

required to comply with this spending rule if a valid justification can be documented, such 

as state and local funds for security are inadequate or security trend data do not warrant 

security spending. 

1649 U.S.C. 5324(c). FTA has regulatory authority for state safety oversight of rail fixedguideway systems and a drug and alcohol program. DOT is responsible for regulating the 

safety of transit agencies. 

17FRA administers and enforces the federal laws and related regulations that are designed 

to promote safety on railroads, such as track maintenance, inspection standards, 

equipment standards, and operating practices. FRA exercises jurisdiction over all areas of 

railroad safety under 49 U.S.C. 20103. 
Page 14 GAO-05-851 Passenger Rail Security 

In recent years, we, along with Congress (most recently through the 

Intelligence Reform and Terrorism Prevention Act of 2004),18 the executive 

branch (e.g., in presidential directives), and the 9/11 Commission have 

required or advocated that federal agencies with homeland security 

responsibilities utilize a risk management approach to help ensure that 

finite national resources are dedicated to assets or activities considered to 

have the highest security priority. We have concluded that without a risk 

management approach, there is limited assurance that programs designed 

to combat terrorism are properly prioritized and focused. Thus, risk 

management, as applied in the homeland security context, can help to 

more effectively and efficiently prepare defenses against acts of terrorism 

and other threats. 

A risk management approach entails a continuous process of managing 

risk through a series of actions, including setting strategic goals and 

objectives, performing risk assessments, evaluating alternative actions to 

reduce identified risks by preventing or mitigating their impact, selecting 

actions to undertake by management, and implementing and monitoring 

those actions. Figure 2 depicts a risk management cycle that is our 

synthesis of government requirements and prevailing best practices 

previously reported. 

Figure 2: Risk Management Cycle 

 18Pub. L. No. 108-458, 118 Stat. 3638. 

Assessing and Managing 

Risks to Rail Infrastructure 

Using a Risk Management 

Approach 

Strategic goals,

objectives and constraints

Risk

assessment

Alternatives

evaluation

Management

selection

Implementation

and

monitoring

Source: GAO.
Page 15 GAO-05-851 Passenger Rail Security 

Setting strategic goals, objectives, and constraints is a key first step in 

implementing a risk management approach and helps to ensure that 

management decisions are focused on achieving a strategic purpose. 

These decisions should take place in the context of an agency’s strategic 

plan that includes goals and objectives that are clear, concise, and 

measurable. 

Risk assessment, a critical element of a risk management approach, helps 

decision makers identify and evaluate potential risks so that 

countermeasures can be designed and implemented to prevent or mitigate 

the effects of the risks. Risk assessment is a qualitative and/or quantitative 

determination of the likelihood of an adverse event occurring and the 

severity, or impact, of its consequences. Risk assessment in a homeland 

security application often involves assessing three key elements—threat, 

criticality, and vulnerability: 

• A threat assessment identifies and evaluates potential threats on the 

basis of factors such as capabilities, intentions, and past activities. 

• A criticality or consequence assessment evaluates and prioritizes assets 

and functions in terms of specific criteria, such as their importance to 

public safety and the economy, as a basis for identifying which 

structures or processes are relatively more important to protect from 

attack. 

• A vulnerability assessment identifies weaknesses that may be exploited 

by identified threats and suggests options to address those weaknesses. 

Information from these three assessments contributes to an overall risk 

assessment that characterizes risks on a scale such as high, medium, or 

low and provides input for evaluating alternatives and management 

prioritization of security initiatives.19 Additional details on these 

assessment elements can be found in appendix II. The risk assessment 

element in the overall risk management cycle may be the largest change 

from standard management steps and is central to informing the remaining 

steps of the cycle. 

 19GAO, Transportation Security: Systematic Planning Needed to Optimize Resources, 

GAO-05-357T (Washington D.C.: Feb. 15, 2005); Homeland Security: A Risk Management 

Approach Can Guide Preparedness Efforts, GAO-02-208T (Washington, D.C.: Oct. 31, 

2001); and Combating Terrorism: Threat and Risk Assessments Can Help Prioritize and 

Target Program Investments, GAO/NSIAD-98-74 (Washington, D.C.: April 9, 1998). 
Page 16 GAO-05-851 Passenger Rail Security 

The next step in a risk management approach—alternatives evaluation—

considers what actions may be needed to address identified risks, the 

associated costs of taking these actions, and any resulting benefits. This 

information is then to be provided to agency management to assist in the 

selection of alternative actions best suited to the unique needs of the 

organization. An additional step in the risk management approach is the 

implementation and monitoring of actions taken to address the risks, 

including evaluating the extent to which risk was mitigated by these 

actions. Once the agency has implemented the actions to address risks, it 

should develop criteria for and continually monitor the performance of 

these actions to ensure that they are effective and also reflect evolving 

risk. 

A number of federal departments and agencies have risk management and 

critical infrastructure protection responsibilities stemming from various 

requirements. The Homeland Security Act of 2002, which created DHS, 

directed the department’s Information Analysis and Infrastructure 

Protection (IAIP) Directorate to utilize a risk management approach in 

coordinating the nation’s critical infrastructure protection efforts. This 

includes using risk assessments to set priorities for protective and support 

measures by the department, other federal agencies, state and local 

government agencies and authorities, the private sector, and other entities. 

Homeland Security Presidential Directive 7 (HSPD-7) defines critical 

infrastructure protection responsibilities for DHS, sector-specific agencies 

(those federal agencies given responsibility for transportation, energy, 

telecommunications, and so forth), and other departments and agencies. 

The President instructs federal departments and agencies to identify, 

prioritize, and coordinate the protection of critical infrastructure to 

prevent, deter, and mitigate the effects of terrorist attacks. The Secretary 

of DHS is assigned several responsibilities by HSPD-7, including 

establishing uniform polices, approaches, guidelines, and methodologies 

for integrating federal infrastructure protection and risk management 

activities within and across sectors. To ensure the coverage of critical 

sectors, HSPD-7 designated sector-specific agencies for 17 critical 

infrastructure sectors.20 These agencies are responsible for infrastructure 

 20Sector-specific agencies have been designated for the following sectors: transportation; 

agriculture and food; public health and health care; drinking water and wastewater 

treatment; energy; banking and finance; national monuments and icons; defense industrial 

base; information technology; telecommunications; chemical; emergency services; postal 

and package shipping; dams; government facilities; commercial facilities; and nuclear 

reactors, materials, and waste. 

Federal Agencies with Risk 

Management 

Responsibilities 
Page 17 GAO-05-851 Passenger Rail Security 

protection activities in their assigned sectors, including coordinating and 

collaborating with relevant federal agencies, state and local governments, 

and the private sector to carry out their responsibilities and facilitating the 

sharing of information about vulnerabilities, incidents, potential protective 

measures, and best practices. 

Pursuant to HSPD-7 and the National Infrastructure Protection Plan 

(NIPP), DHS was designated as the sector-specific agency for the 

transportation sector, a responsibility the department has delegated to 

TSA.21 As the sector-specific agency for transportation, TSA is required to 

develop a transportation sector-specific plan (TSSP) for identifying, 

prioritizing, and protecting critical transportation infrastructure and key 

resources that will provide key input to the broader NIPP to be prepared 

by IAIP. DHS issued an interim NIPP in February 2005 that was intended 

to serve as a road map for how DHS and stakeholders—including other 

federal agencies, the private sector, and state and local governments—

should use risk management principles for determining how to prioritize 

activities related to protecting critical infrastructure and key resources 

within and among each of the 17 sectors in an integrated, coordinated 

fashion. DHS expects the next iteration of the NIPP to be issued in 

November 2005, with the sector-specific plans, including the TSSP, being 

incorporated into this plan in February 2006. HSPD-7 also requires DHS to 

coordinate with DOT on all transportation security matters. Table 1 

summarizes selected responsibilities for federal agencies with lead or 

supporting roles for critical infrastructure protection and risk 

management efforts. 

 21The transportation sector includes mass transit; aviation; maritime; ground/surface; and 

rail and pipeline systems. 
Page 18 GAO-05-851 Passenger Rail Security 

Table 1: Selected Roles and Responsibilities of Federal Agencies Related to Risk Management and Critical Infrastructure 

Protection 

Statute or directive 

Agency with lead 

or supporting role Selected responsibilities 

Related output of 

action Due date 

Homeland Security Act 

of 2002 

IAIPa Coordinates national critical 

infrastructure protection (CIP) 

efforts by: 

• conducting risk assessments of key 

resources and critical infrastructure 

to determine the risks posed by 

terrorist attacks within the United 

States; 

• integrating relevant information, 

analyses, and assessments 

(whether conducted by department 

or others) in order to identify 

priorities for protective and support 

measures; 

• recommending measures to protect 

the key resources and critical 

infrastructure of the United States in 

coordination with other federal 

agencies and in cooperation with 

state and local government 

agencies and authorities, the private 

sector, and other entities. 

Develop a 

comprehensive national 

plan for securing the key 

resources and critical 

infrastructure 

Not specified 

 ODPa As the principal federal agency in 

preparing the United States for acts 

of terrorism: 

• assists and supports DHS in 

conducting appropriate risk analysis 

and risk management activities of 

state, local, and tribal governments; 

• serves as primary office responsible 

for providing training, funds for the 

purchase of equipment, support for 

the planning and execution of 

exercises.

Risk analysis and risk 

management activities 

for states and local 

jurisdictions 

Not applicable 

Homeland Security 

Presidential 

Directive-7 

IAIPb Coordinate national CIP efforts by:

• identifying, prioritizing, and 

coordinating the protection of critical 

infrastructure, emphasizing 

protection against catastrophic 

health effects or mass casualties; 

• establishing uniform policies, 

approaches, guidelines, and 

methodologies for integrating 

federal infrastructure protection and 

risk management activities within 

and across sectors. 

National Infrastructure 

Protection Plan 

12/04 
Page 19 GAO-05-851 Passenger Rail Security 

Statute or directive 

Agency with lead 

or supporting role Selected responsibilities 

Related output of 

action Due date 

 TSAc As sector-specific agency for 

transportation: 

• identify, prioritize, and coordinate 

the protection of critical 

transportation systems 

infrastructure, including conducting 

and facilitating vulnerability 

assessments and encouraging risk 

management strategies; 

• coordinate and collaborate with 

relevant federal agencies, state and 

local governments, and the private 

sector. 

Transportation SectorSpecific Plan 12/04 

 DOTd Support CIP activities in 

transportation sector by: 

• collaborating with DHS on all 

matters relating to transportation 

security and transportation 

infrastructure protection. 

Not applicable Not applicable 

Intelligence Reform and 

Terrorism Prevention Act 

of 2004 

TSAe Develop, prepare, implement, and 

update as needed a National 

Strategy for Transportation 

Security, including: 

• development of transportation 

modal security plans; 

• identification and evaluation of 

transportation assets that must be 

protected from terrorist attack; 

• development of risk-based priorities 

across all transportation modes and 

realistic deadlines for addressing 

security needs associated with 

those assets. 

National Strategy for 

Transportation Security 

4/05 

 DOT Works jointly with DHS to develop, 

revise, and update the National 

Strategy for Transportation Security

Not applicable Not applicable 

Source: GAO analysis of federal roles and responsibilities related to risk management and critical infrastructure protection. 

a

Lead role designated by statute. 

b

Lead role for all sectors; responsibility delegated by DHS. 

c

Lead role for transportation sector; responsibility delegated by DHS. 

d

Supporting role for DHS. 

e

Lead role delegated by DHS. 
Page 20 GAO-05-851 Passenger Rail Security 

DHS component agencies have taken various steps to assess the risk 

posed by terrorism to U.S. passenger rail systems. ODP has developed and 

implemented a risk assessment methodology intended to help passenger 

rail operators and others enhance their capacity to respond to terrorist 

incidents and identify and prioritize security countermeasures. As of July 

2005, ODP had completed 7 risk assessments with rail operators and 12 

others were under way. Further, TSA completed a threat assessment for 

mass transit and rail and has begun to identify critical rail assets, but it has 

not yet completed an overall risk assessment for the passenger rail 

industry. DHS is developing guidance to help these and other sectorspecific agencies work with stakeholders to identify and analyze risk. 

In 2002, ODP began conducting risk assessments of passenger rail 

operators through its Mass Transit Technical Assistance program. These 

assessments are intended to help passenger rail operators and port 

authorities enhance their capacity and preparedness to respond to 

terrorist incidents involving weapons of mass destruction, and identify and 

prioritize security countermeasures and emergency response capabilities. 

ODP’s approach to risk assessment is generally consistent with the risk 

assessment component of our risk management approach. The agency has 

worked with passenger rail operators and others to complete several risk 

assessments. As of July 2005, ODP had completed 7 risk assessments in 

collaboration with passenger rail operators.22 Twelve additional risk 

assessments are under way, and an additional 11 transit agencies have 

requested assistance through this program. 

ODP’s methodology for conducting risk assessments is articulated in a tool 

kit designed to enable passenger rail operators and others to compare 

relative risks among assets, identify assets with a perceived high level of 

risk, and prioritize measures to mitigate those risks.23 Once ODP and a rail 

operator agree to collaborate on the risk assessment, ODP sends a 

 22ODP has completed risk assessments with the Port Authority of New York and New 

Jersey, New Jersey Transit, Massachusetts Bay Transportation Authority, Washington 

Metropolitan Area Transit Authority, Southeastern Pennsylvania Transportation Authority, 

Tri-County Metropolitan Transportation District of Oregon, and the Delaware River Port 

Authority. 

23According to ODP, risk assessment methodologies from a variety of sources were 

reviewed as part of the tool kit’s development, including various state transportation risk 

assessment methods, airport vulnerability methods, and DOT infrastructure assessment 

methods. 

DHS Has Taken Steps 

to Assess Risk to 

Passenger Rail 

Systems, but 

Additional Work Is 

Needed to Guide 

Security Investments 

ODP Has Worked with 

Passenger Rail Operators 

to Develop Risk 

Assessments to Help 

Prioritize Rail Security 

Needs and Investments 
Page 21 GAO-05-851 Passenger Rail Security 

technical assistance team consisting of experts in the risk management 

and emergency response field to visit the rail operator on-site to support 

the implementation of the risk assessment process. The team assists the 

operator in using the tool kit to generate information on criticality, threat, 

vulnerability, impact, and risk. Once completed, the documented results 

should serve as a guide for future applications of the risk assessment 

process to keep pace with new threat information and newly vulnerable 

assets. 

ODP’s risk assessment process involves, first, an analysis of four 

elements—criticality, threat, vulnerability, and impact. Using the tool kit, 

the operator begins by conducting the criticality assessment to identify 

and prioritize critical assets based upon factors such as the potential for 

serious injury or loss of life, or the economic implications on the 

livelihood, resources, or wealth of the area, region, or country if the asset 

was destroyed. Assets deemed to be “most critical” are then evaluated 

using the remaining risk assessment components. The operator then 

conducts the threat assessment to identify the range of weapon types that 

terrorists might use against the operator’s critical assets, establish the 

likelihood that critical assets might be targeted, and develop possible 

attack scenarios. These attack scenarios are then used to perform a 

vulnerability assessment that evaluates the susceptibility of critical assets 

to these scenarios and determines such things as the probability of an 

attack succeeding and whether it can be stopped. Once these first three 

assessment components are completed, the operator determines the 

impact that the partial or complete destruction of a critical asset would 

have on the asset’s ability to function based upon specific threat scenarios. 

Table 2 describes selected steps that operators take, in conjunction with 

ODP, to carry out these four assessment components using ODP’s risk 

assessment tool kit. 
Page 22 GAO-05-851 Passenger Rail Security 

Table 2: Selected Steps in ODP’s Risk Assessment Process 

Assessment component Assessment steps 

Criticality Step 1. Develop a worksheet of candidate critical assets (i.e., infrastructure, facilities, equipment, and 

personnel) that enable the operator to achieve its mission. 

Step 2. Establish critical asset factors—factors that describe the characteristics of assets that would 

result in significant negative impact to the operator given their loss in a terrorist event (i.e., economic 

impact, symbolic importance, functional importance). 

Step 3. Assign quantitative values to each factor that indicate the importance of the factor to the 

overall mission of the operator. 

Step 4. Apply the factors to the list of candidate assets to develop a criticality score. 

Step 5. Prioritize assets based upon their criticality scores. Rail operator officials review rankings to 

determine their reasonableness and to establish a threshold for the assets considered most critical. 

Threat Step 1. Develop a list of weapons types (i.e., large or small explosives, biological conventional 

explosive, nuclear device) that might be used by terrorists. 

Step 2. Evaluate the selected weapon types on the likelihood (using a five-point scale) that terrorists 

have each weapon and would use it against the operator’s assets. 

Step 3. Evaluate the attractiveness of targets based on the potential for casualties, potential for 

economic disruption, and symbolic importance. 

Step 4. Define attack scenarios (based on target asset, weapon, and mode of delivery); the 

information will be used in subsequent assessment components. 

Vulnerability Step 1. Develop a rating to determine the probability of a successful attack. Rating is based upon 

three factors: the ability to limit or deny ingress and egress to an asset by a terrorist (access control), 

the ability to expose or reveal an attack before it takes place (detection capabilities), the ability to 

interdict once an attack has been detected (interdiction capabilities). 

Step 2. Using these probability ratings, develop an overall vulnerability rating that represents the 

relative likelihood of an attack being attempted and successfully carried out. 

Impact Step 1. Use the critical asset factors identified above to rate the effect of a weapon on each asset’s 

mission. 

Step 2. Once each asset has been rated, use a mathematical formula to calculate a total overall 

impact level—how each asset’s mission is affected based upon the extent to which it would be 

destroyed. 

Source: GAO analysis of ODP information. 

The results developed in the threat, criticality, vulnerability, and impact 

assessments are then used to develop an overall risk assessment in order 

to evaluate the relative risk among various assets, weapons, and modes of 

attack. This is intended to give operators an indication of which asset 

types and threat scenarios carry the highest risk and that, accordingly, are 

likely candidates for early risk mitigation action. Using the results of the 

risk assessment process, a diagram of relative risk is developed by plotting 
Page 23 GAO-05-851 Passenger Rail Security 

the assets and scenarios in terms of vulnerability and consequence, as 

shown in figure 3. 24

Figure 3: Sample ODP Relative Risk Diagram 

By showing the relative risk of all assets and scenarios identified, this 

diagram identifies the assets and scenarios that have the greatest 

estimated level of relative risk and provides critical information useful to 

develop and prioritize security countermeasures. According to ODP, assets 

with scenarios that fall in quadrants I and III have the greatest potential 

negative impact (i.e., the greatest consequence) on an operator’s system if 

attacked. Assets with scenarios that fall in quadrants I and II have the 

greatest vulnerability to attack. Therefore, quadrant I contains the assets 

and scenarios that have the greatest vulnerability and negative 

consequence and are likely candidates for early mitigation action from a 

policy decision-making perspective. 

According to rail operators who have used ODP’s risk assessment 

methodology and commented about it to DHS or us, the method has been 

successful in helping to devise risk reduction strategies to guide security-

 24“Consequence” is defined as the portion of an asset’s criticality that would be reduced as 

a result of a successful attack. 
Page 24 GAO-05-851 Passenger Rail Security 

related investments. For example, between September 2002 and March 

2003, ODP’s technical assistance team worked with the Port Authority of 

New York and New Jersey (PANYNJ) to conduct a risk assessment of all 

of its assets—its Port Authority Trans-Hudson (PATH) passenger rail 

system, as well as airports, ports, interstate highway crossings, and 

commercial properties.25 According to PANYNJ officials, the authority was 

able to develop and implement a risk reduction strategy that enabled it to 

identify and set priorities for improvements in security and emergency 

response capability that are being used to guide security investments. 

As part of this risk assessment, PANYNJ identified and prioritized 

particular types of security countermeasures that, if implemented, would 

improve the authority’s overall risk profile by moving assets into the lower 

parts of the risk diagram (as shown in fig. 3). Examples of 

countermeasures considered include site-hardening of assets such as 

bridges and tunnels; increased patrols, guards, and canine units; eventactivated closed-circuit television (CCTV); and intrusion detection 

systems. According to PANYNJ officials, the associated costs and benefits 

of the countermeasures identified were considered, and management was 

involved in choosing and prioritizing the actions included in the plan. More 

specifically, according to authority officials, the risk assessment was 

instrumental in obtaining management approval for a 5-year, $500 million 

security capital investment program, as it provided a risk-based 

justification for these investments.26 Examples of passenger rail security 

capital investments PANYNJ is making as part of this program include the 

development of a state-of-the art system wide security operations center 

for the PATH system, access control and alarm monitoring system 

replacement at 45 locations, and digital video recording upgrades to its 

 25PANYNJ is a bistate public agency that manages and maintains bridges, tunnels, bus 

terminals, airports, the PATH passenger rail system, and seaports in the greater New 

York/New Jersey metropolitan area. PANYNJ was also the property owner and operator of 

the World Trade Center site and the PATH passenger rail station underneath the site that 

was destroyed by the September 11 terrorist attacks. At the request of PANYNJ, ODP’s 

technical assistance team worked with authority personnel to conduct the first risk 

assessment using ODP’s model. This collaborative effort provided the means for ODP to 

test and refine its methodology and develop the tool kit now in use. 

26On the basis of the ODP and prior risk assessments and identified risks, PANYNJ 

identified approximately $1 billion dollars in security investments or actions. The current 

$500 million capital investment program was based directly on the highest risks identified 

in the assessment. The initial $500 million program did not include countermeasures 

identified by the assessments that could not be implemented immediately. For example, 

the authority viewed countermeasures, such as weapons of mass destruction detection 

systems, as cost-prohibitive until technological advances are made in this arena. 
Page 25 GAO-05-851 Passenger Rail Security 

CCTV system. At the time of our review, the authority was 2 years into 

implementing the strategy and associated capital investment program and 

had just completed its first risk assessment update. PANYNJ officials told 

us they have formally incorporated the ODP risk assessment model into 

the authority’s annual planning and budgeting cycle and are able to track 

and assess how security projects improve the authority’s overall risk 

profile. PANYNJ staff are now working on a cost-benefit module to be 

included in the authority’s risk assessment program, with the objective of 

making more discrete trade-offs among high-cost security programs on the 

basis of which ones provided the highest payoff. 

The six other passenger rail operators that have completed ODP’s risk 

assessment process also stated that they valued the process. Specifically, 

operators said that the assessments enabled them to prioritize investments 

based on risk and are already allowing or are expected to allow them to 

effectively target and allocate resources toward security measures that 

will have the greatest impact on reducing risk across their system. For 

example, one rail operator stated that it is planning on spending its fiscal 

year 2005 Transit Security Grant Program funding to expand its CCTV 

coverage, with a focus on stations that serve major public gatherings but 

do not have such equipment, a measure identified by the risk assessment 

as the second most effective risk reduction measure to implement. 27 In 

addition, as a result of the assessment, the operator said that it has 

incorporated CCTVs into its standard design criteria for new system 

construction, such as stations and parking garages. 

On the basis of its own experience with conducting risk assessments in the 

field, and in keeping with its mission to develop and implement a national 

program to enhance the capacity of state and local agencies to respond to 

incidents of terrorism, ODP has offered to help other DHS components 

and federal agencies to develop risk assessment tools, according to ODP 

officials. For example, ODP is partnering with the FRA, TSA, the American 

Association of Railroads (AAR), and others to develop a risk assessment 

 27The assessment identified the most effective risk reduction measure as training 

employees and informing the public to serve as the “eyes and ears” and report suspicious 

objects and behaviors. While, according to the agency, it had undertaken comprehensive 

steps in these areas, the assessment pointed out the usefulness of making these efforts a 

permanent part of training, procedures, and public information. 

ODP Has Sought to 

Promote Risk-Based 

Decision Making among 

Federal Agencies and Rail 

Operators 
Page 26 GAO-05-851 Passenger Rail Security 

tool for freight rail corridors. 28 In a separate federal outreach effort, ODP 

worked with TSA to establish a Federal Risk Assessment Working Group 

to promote interagency collaboration and information sharing. 

Representatives from participating federal agencies meet monthly to 

encourage information sharing regarding risk assessments and other 

related homeland security issues.29 The working group has, among other 

things, created a Web-based calendar so participating agencies can upload 

and share information regarding planned assessments. The calendar also 

contains detailed information on assessments, including locations, dates, 

types of assessment, and points of contact. 

In addition, in keeping with its mission to deliver technical assistance and 

training, ODP has partnered with the American Public Transportation 

Association (APTA) to inform passenger rail operators about its risk 

assessment technical assistance program. 30 Since June 2004, ODP has 

attended five APTA conferences or workshops where it has set up 

information booths, made the tool kit available, and conducted seminars 

to educate passenger rail operators about the risk assessment process and 

its benefits. According to an APTA official, ODP’s risk assessment 

technical assistance program has been well received by the transit 

community. The program is dependent on funding available in ODP’s 

technical assistance budget for support. In fiscal years 2004 and 2005, the 

program received $5.2 million and $5.7 million, respectively, through 

ODP’s technical assistance budget. 

ODP has leveraged its grant-making authority to promote risk-based 

funding decisions for passenger rail. For example, passenger rail operators 

must have completed a risk assessment to be eligible for financial 

 28The American Association of Railroads is an association representing the interests of the 

rail industry, focused mostly at the federal level. Its members are primarily freight rail 

operators in the United States, Canada, and Mexico. However, it also represents some 

passenger rail interests, including Amtrak. 

29Participating agencies include DHS’s Office of State and Local Government Coordination 

and Preparedness, DHS’s U.S. Coast Guard, DHS’s Information Analysis and Infrastructure 

Protection Directorate, the Department of Defense’s U.S. Transportation Command, DOT’s 

Federal Transit Administration, and DOT’s Federal Highway Administration. 

30The American Public Transportation Association is a nonprofit trade association 

representing over 1,500 public and private member organizations, including transit systems 

and commuter rail operators; planning, design, construction, and finance firms; product 

and service providers; academic institutions; transit associations; and state departments of 

transportation. 
Page 27 GAO-05-851 Passenger Rail Security 

assistance through the fiscal year 2005 Transit Security Grant program 

administered by ODP. To receive these funds, passenger rail operators are 

also required to have a security and emergency preparedness plan that 

identifies how the operator intends to respond to security gaps identified 

by risk assessments. This plan, along with a regional transit security 

strategy prepared by regional transit stakeholders, will serve as the basis 

for determining how the grant funds are to be allocated. 

Risk assessments are also a key driver of federal funds distributed through 

ODP’s fiscal year 2005 Intercity Passenger Rail Grant Program. This $7.1 

million program provides financial assistance to Amtrak for the protection 

of critical infrastructure and emergency preparedness activities along 

Amtrak’s Northeast Corridor and its hub in Chicago. Amtrak is required to 

conduct a risk assessment of these areas in collaboration with ODP, in 

order to receive the grant funds.31 A recent review of Amtrak’s security 

posture and programs conducted by the RAND Corporation and funded by 

FRA in 2004 found that no comprehensive terrorism risk assessment of 

Amtrak has been conducted that would provide an empirical baseline for 

investment prioritization and decision making for Amtrak’s security 

policies and investment plans. As another condition for receiving the grant 

funds, Amtrak is required to develop a security and emergency 

preparedness plan that, along with the risk assessment, is to serve as the 

basis for proposed allocations of grant funding. According to an Amtrak 

security official, it welcomes the risk assessment effort and plans to use 

the results of the assessment to guide its security plans and investments. 

According to ODP officials, as of July 2005, the Amtrak risk assessment 

was nearly 50 percent complete. 

As the agency responsible for ensuring the security of all modes of 

transportation, TSA has been charged by DHS with fulfilling key 

requirements of HSPD-7 and the Intelligence Reform and Terrorism 

Prevention Act of 2004. Specifically, TSA is required to conduct and 

 31Up to 30 percent of the available funds will be available to assist Amtrak in meeting its 

most pressing security needs in the Northeast Corridor and Chicago (as identified through 

previously conducted site-specific assessments) prior to completion of the risk assessment. 

However, the remainder of the grant funds will not be released until Amtrak has completed 

the risk assessment and also submitted a security and emergency preparedness plan. 

Amtrak is also required to demonstrate that its planning process and allocations of funds 

are fully coordinated with regional planning efforts in the National Capitol Region, 

Philadelphia, New York, Boston, and Chicago. Amtrak is using approximately $700,000 of 

the grant funds for the ODP risk assessment. 

TSA Has Begun to Assess 

Risks to Passenger Rail 
Page 28 GAO-05-851 Passenger Rail Security 

facilitate risk assessments in order to identify, prioritize, and coordinate 

the protection of critical transportation systems infrastructure, as well as 

develop risk-based priorities across all transportation modes. As part of 

this effort, TSA is required to develop plans that, among other things, 

identify and prioritize critical transportation assets for protection. At the 

time of our review, TSA had taken steps to meet these responsibilities but 

had not yet completed the risk assessments for the rail industry (among 

others) or the plans that they support as required. 

In October 2004, TSA completed an overall threat assessment for both 

mass transit and passenger and freight rail modes.32 TSA began conducting 

a second risk assessment element—criticality assessments of passenger 

rail stations—in the spring of 2004, but the effort had not been completed 

at the time of our review. According to TSA, a criticality assessment tool 

was developed that considers multiple factors, such as the potential for 

loss of life or effects on public health; the economic impact of the loss of 

function of the asset and the cost of reconstitution; and the local, regional, 

or national symbolic importance of the asset. These factors were to be 

used to arrive at a criticality score that, in turn, would enable the agency 

to rank assets and facilities based on relative importance, according to 

TSA officials. 

To date, TSA has assigned criticality scores to nearly 700 passenger rail 

stations. In May 2005, TSA began conducting assessments for other 

passenger rail assets such as bridges and tunnels. TSA officials told us that 

as of July 2005, they had completed 73 criticality assessments for bridge 

and tunnel assets and expect to conduct approximately 370 additional 

assessments in these categories. Once TSA has completed its criticality 

assessment, a senior group of transportation security experts will review 

these scores and subsequently rank and prioritize them. As of July 2005, 

TSA had not established a time frame for completing criticality 

assessments for passenger rail assets or for ranking assets, and had not 

identified whether it planned to do so. 

In 2003, TSA officials stated that they planned to work with transportation 

stakeholders to rank assets and facilities in terms of their criticality. 

HSPD-7 requires sector-specific agencies such as TSA to collaborate with 

all relevant stakeholders, including federal departments and agencies, 

 32The results of TSA’s passenger and freight rail threat assessments contain information 

that is security sensitive or classified and therefore cannot be disclosed in this report. 
Page 29 GAO-05-851 Passenger Rail Security 

state and local governments, and others. In addition, DHS’s interim NIPP 

states that sector-specific agencies, such as TSA, are expected to work 

with stakeholders—such as rail operators—to determine the most 

effective means of obtaining and analyzing information on assets. While 

TSA’s methodology for conducting criticality assessments calls for 

“facilitated sessions” involving TSA modal specialists, DOT modal 

specialists, and trade association representatives, these sessions with 

stakeholders have not been held. According to TSA officials, their final 

methodology for conducting criticality assessments did not include DOT 

modal specialists and trade associations. With respect to rail operators, 

TSA officials explained that their risk assessment process does not require 

operators’ involvement. TSA analysts said they have access to a great deal 

of information (such as open source records, satellite imagery, and 

insurance industry data) that can facilitate the assessment process. 

However, when asked to comment on TSA’s ability to identify critical 

assets in passenger rail systems, APTA officials and 10 rail operators we 

interviewed told us it would be difficult for TSA to complete this task 

without their direct input and rail system expertise. 

TSA plans to rely on asset criticality rankings to prioritize which assets it 

will focus on in conducting vulnerability assessments. That is, once an 

asset, such as a passenger rail station, is deemed to be most critical, then 

TSA would focus on determining the station’s vulnerability to attacks. TSA 

plans to conduct on-site vulnerability assessments for those assets deemed 

most critical. For assets that are deemed to be less critical, TSA has 

developed a software tool that it has made available to passenger rail and 

other transportation operators for them to use on a voluntary basis to 

assess the vulnerability of their assets. As of July 2005, the tool had not yet 

been used. According to APTA officials, passenger rail operators may be 

reluctant to provide vulnerability information to TSA without knowing 

how the agency intends to use such information. According to TSA, it is 

difficult, if not impossible, to project any timelines regarding completion 

of vulnerability assessments in the transportation sector because rail 

operators are not required to submit them. In this regard, while the rail 

operators are not required to submit this information, as the sectorspecific agency for transportation, TSA is required by HSPD-7 to complete 

vulnerability assessments for the transportation sector. Figure 4 illustrates 

the overall progress TSA had made in conducting risk assessments for 

passenger rail assets as of July 2005. 
Page 30 GAO-05-851 Passenger Rail Security 

Figure 4: Status of TSA’s Passenger Rail Risk Assessment Efforts, as of July 2005 

We recognize that TSA’s risk assessment effort is still evolving and TSA 

has had other pressing priorities, such as meeting the legislative 

requirements related to aviation security. However, until all three 

assessments of rail systems—threat, criticality, and vulnerability—have 

been completed in sequence, and until TSA determines how to use the 

results of these assessments to analyze and characterize risk (e.g., whether 

high, medium, or low), it may not be possible to prioritize passenger rail 

assets and guide investment decisions about protecting them. 

Finalizing a methodology for assessing risk to passenger rail and other 

transportation assets and conducting the assessments are key steps 

needed to produce the plans required by HSPD-7 and the Intelligence 

Reform and Terrorism Prevention Act of 2004. DHS and TSA have missed 

both deadlines for producing these plans. Specifically, DHS and TSA have 

yet to produce the TSSP required by HSPD-7 to be issued in December of 

2004, though a draft was prepared in November 2004. DHS and TSA 

officials told us that they expected the first version of the TSSP to be 

completed in February 2006. DHS and TSA also missed the April 1, 2005, 

deadline for completing the national strategy for transportation security 

required by the Intelligence Reform and Terrorism Prevention Act of 2004. 

In an April 2005 letter to Congress addressing the missed deadline, the 

DHS Deputy Secretary identified the need to more aggressively coordinate 

the development of the strategy with other relevant planning work such as 

the TSSP, to include further collaboration with DOT modal 
Page 31 GAO-05-851 Passenger Rail Security 

administrations and DHS components. The Deputy Secretary further 

stated that DHS expected to finish the strategy within 2 to 3 months. 

However, as of July 31, 2005, the strategy had not been completed. In April 

2005, senior DHS and TSA officials told us that in addition to DOT, 

industry groups such as APTA and AAR would also be more involved in 

developing the TSSP and other strategic plans. However, as of July 2005, 

TSA had not yet engaged these stakeholders in the development of these 

plans. 

As TSA, other sector-specific agencies, and ODP move forward with risk 

assessment activities, DHS is concurrently developing guidance intended 

to help these agencies work with their stakeholders to assess risk. HSPD-7 

requires DHS to establish uniform policies, approaches, guidelines, and 

methodologies for integrating federal infrastructure protection and risk 

management activities within and across sectors. To meet this 

requirement, DHS has, among other things, been working for nearly 2 

years on a risk assessment framework through IAIP.33 This framework is 

intended to help the private sector and state and local governments to 

develop a consistent approach to analyzing risk and vulnerability across 

infrastructure types and across entire economic sectors, develop 

consistent terminology, and foster consistent results. The framework is 

also intended to enable a federal-level assessment of risk in general, and 

comparisons among risks, for purposes of resource allocation and 

response planning. DHS has informed TSA that this framework will 

provide overarching guidance to sector-specific agencies on how various 

risk assessment methodologies may be used to analyze, normalize, and 

prioritize risk within and among sectors. The interim NIPP states that the 

ability to rationalize, or normalize, results of different risk assessments is 

an important goal for determining risk-related priorities and guiding 

investments. One core element of the DHS framework—defining concepts, 

terminology, and metrics for assessing risk—has yet to be completed. The 

completion date for this element—initially due in September 2004—has 

been extended twice, with the latest due date in June 2005. However, as of 

July 31, 2005, this element has not been completed. 

Because neither this element nor the framework as a whole has yet been 

finalized or provided to TSA or other sector-specific agencies, it is not 

 33DHS refers to this framework as a Risk Analysis and Management for Critical Asset 

Protection. 

DHS Faces Challenges in 

Comparing and 

Reconciling Risks and 

Prioritizing Investments 

within and across Sectors 
Page 32 GAO-05-851 Passenger Rail Security 

clear what impact, if any, DHS’s framework may have on ongoing risk 

assessments conducted by, and the methodologies used by, TSA, ODP, and 

others, and whether or how DHS will be able to use these results to 

compare risks and prioritize homeland security investments among 

sectors. Until DHS finalizes this framework, and until TSA completes its 

risk assessment methodology, it may not be possible to determine whether 

different methodologies used by TSA and ODP for conducting threat, 

criticality, and vulnerability assessments generate disparate qualitative and 

quantitative results or how they can best be compared and analyzed. In 

addition, TSA and others will have difficulty taking into account whether 

at some point TSA may be unnecessarily duplicating risk management 

activities already under way at other agencies and whether other agencies’ 

risk assessment methodologies, and the data generated by these 

methodologies, can be leveraged to complete the assessments required for 

the transportation sector. In the future, the implementation of DHS’s 

departmentwide proposed reorganization could affect decisions relating to 

critical infrastructure protection as new directorates are established, such 

as the directorates of policy and preparedness, and other preparedness 

assets are consolidated from across the department. 

FTA and FRA were the primary federal agencies involved in passenger rail 

security matters prior to the creation of TSA. Before and after September 

11, these two agencies launched a number of initiatives designed to 

strengthen passenger rail security. TSA also took steps to strengthen rail 

security, including issuing emergency security directives to rail operators 

and testing emerging rail security technologies for screening passengers 

and baggage. Rail industry stakeholders and federal agency officials raised 

questions about how effectively DHS had collaborated with them on rail 

security issues. DHS and DOT have signed a memorandum of 

understanding intended to identify ways that collaboration with federal 

and industry stakeholders might be improved. 

Prior to the creation of TSA in November 2001, DOT agencies (i.e., modal 

administrations)—notably FTA and FRA—were primarily responsible for 

the security of passenger rail systems. These agencies undertook a number 

of initiatives to enhance the security of passenger rail systems prior to and 

after September 11. For example, prior to September 11, FTA offered 

voluntary security assessments, sponsored training at the Transportation 

Safety Institute, issued written guidelines to improve emergency response 

planning, and partially funded a chemical detection demonstration project, 

called PROTECT, at the Washington Metropolitan Area Transit Authority. 

Multiple Federal 

Agencies Have Taken 

Actions to Enhance 

Passenger Rail 

Security 

DOT Agencies Led Initial 

Efforts to Enhance 

Passenger Rail Security 
Page 33 GAO-05-851 Passenger Rail Security 

In response to the terrorist attacks on September 11, FTA, using an $18.7 

million appropriation by the Department of Defense Emergency 

Supplemental Act of 2002, launched a multipart transit security initiative, 

much of which is still in place. The initiative included security 

assessments, planning, drills, and training, as described below: 

• Security readiness assessments: FTA deployed teams to assess security 

at 32 rail transit operators. FTA chose these 32 agencies on the basis of 

their ridership, vulnerability, and the potential consequences of a terrorist 

attack. Each assessment included a threat and vulnerability analysis, an 

evaluation of security and emergency plans, and a focused review of the 

agency’s unified command structure with external emergency responders. 

FTA completed the assessments in late summer 2002.34

• Security and emergency management technical assistance: As of July 

2005, FTA had provided technical assistance to 32 passenger rail agencies 

on security and emergency plans and emergency response drills. This is 

also a follow-on effort to the security assessments, as FTA is helping 

transit agencies fill identified security gaps customized to the individual 

agency’s needs and operating characteristics. 

• Emergency response drills: FTA offered transit agencies grants up to 

$50,000 for organizing and conducting emergency preparedness drills. 

According to FTA officials, FTA has awarded $3.4 million to over 80 transit 

agencies through these grants. 

• Transit Safety and Security Roundtables program: FTA developed 

the Transit Safety and Security Roundtables program, which brings 

together safety and security chiefs of the 30 largest transit systems to 

share information on technology and best practices and to develop 

relationships between federal and local officials working in the areas of 

transit safety and security. In October 2003, FTA and DHS, through TSA, 

sponsored the most recent roundtable, in Washington, D.C. In October 

2005, FTA and DHS plan to hold a roundtable with safety and security 

representatives of the 50 largest transit agencies. 

• Connecting Communities program: FTA developed and currently is 

offering free emergency preparedness and security training to transit 

agencies through its Connecting Communities Forums. These forums are 

 34FTA completed three additional assessments of rail transit agencies as part of its 

technical assistance program.
Page 34 GAO-05-851 Passenger Rail Security 

designed to bring together personnel from small and medium-sized transit 

agencies with their local emergency responders, including local 

firefighters and police officers. The purposes of the forums are to give the 

participants a better understanding of the roles played by transit agencies 

and emergency responders and to allow participants to begin developing 

the plans, tools, and relationships necessary to respond effectively in an 

emergency. FTA sponsored 17 forums under this program and has plans 

for the delivery of 12 more by the end of fiscal year 2006. TSA has 

provided financial support to this program. In fiscal year 2005, TSA 

transferred $100,000 to FTA to support the Connecting Communities 

program. 

• Transit Watch program: In 2003, FTA instituted the Transit Watch 

campaign, a nationwide safety and security awareness program designed 

to encourage the active participation of transit passengers and employees 

in maintaining a safe transit environment. The program provides 

information and instructions to transit passengers and employees so that 

they know what to do and whom to contact in the event of an emergency 

in a transit setting. Transit Watch invites riders and employees to be the 

“eyes and ears” of their local transit system. FTA plans to continue this 

initiative, in partnership with TSA and ODP, and offer additional security 

awareness materials that address unattended bags and emergency 

evacuation procedures for transit agencies. 

• Additional security training: In addition to the programs and training 

cited above, FTA worked with the National Transit Institute, Johns 

Hopkins University, and the Transportation Safety Institute to expand 

safety and security course offerings. For example, the National Transit 

Institute is now offering a security awareness course to frontline transit 

employees free of charge. The course covers skill sets for observing, 

determining, and reporting people and items that are suspicious or out of 

place. FTA also developed a training course for frontline transit employees 

to recognize and react to terrorist activity. This course incorporates the 

latest in international counterterrorism techniques. 

• Security guidance: FTA also developed security guidance for transit 

agencies based largely on the findings of the security readiness 

assessments. For example, in November 2003, FTA issued its Top 20 

Security Program Action Items for Transit Agencies, which recommends 

measures for transit agencies to implement into their security programs to 

improve both security and emergency preparedness. Recommended 

practices include performing background checks on employees, instituting 

access control procedures, and providing security awareness training to 

frontline employees. In 2003, FTA also issued recommended measures for 
Page 35 GAO-05-851 Passenger Rail Security 

transit agencies to implement in responding to various DHS threat level 

designations. 

FTA has also used research and development funds to develop guidance 

for security design strategies to reduce the vulnerability of transit systems 

to acts of terrorism. In November 2004, FTA provided rail operators with 

security considerations for transportation infrastructure. This guidance 

provided recommendations intended to help operators deter and minimize 

attacks against their facilities, riders, and employees by incorporating 

security features into the design of rail infrastructure. (Additional details 

on the use of this guidance are discussed later in this report.) 

FRA has also taken a number of actions to enhance passenger rail security 

since September 11. For example, it has assisted commuter railroads in 

developing security plans, reviewed Amtrak’s security plans, and helped 

fund FTA security readiness assessments for commuter railroads. More 

recently, in the wake of the Madrid terrorist bombings, nearly 200 FRA 

inspectors, in cooperation with DHS, conducted multi-day team 

inspections of each of the 18 commuter railroads and Amtrak to determine 

what additional security measures had been put into place to prevent a 

similar occurrence in the United States. FRA also conducted research and 

development projects related to passenger rail security. These projects 

included rail infrastructure security and trespasser monitoring systems 

and passenger screening and manifest projects, including explosives 

detection. 

Although DOT modal administrations now play a supporting role in 

transportation security matters since the creation of TSA, they remain 

important partners in the federal government’s efforts to improve rail 

security, given their role in funding and regulating the safety of passenger 

rail systems. Moreover, as TSA moves ahead with its passenger rail 

security initiatives, FTA and FRA are continuing their passenger rail 

security efforts. 
Page 36 GAO-05-851 Passenger Rail Security 

In response to the March 2004 commuter rail attacks in Madrid and federal 

intelligence on potential threats against U.S. passenger rail systems, TSA 

issued security directives to the passenger rail industry in May 2004. TSA 

issued these security directives to establish a consistent baseline standard 

of protective measures for all passenger rail operators, including Amtrak.35

The directives were not related to, and were issued independent of, TSA’s 

efforts to conduct risk assessments to prioritize rail security needs. TSA 

considered the measures required by the directives to constitute 

mandatory security standards that were required to be implemented 

within 72 hours of issuance by all passenger rail operators nationwide. In 

an effort to provide some flexibility to the industry, the directives allowed 

rail operators to propose alternative measures to TSA in order to meet the 

required measures. Table 3 contains examples of security measures 

required by these directives. 

Table 3: Examples of Measures Required by TSA Security Directives Issued to Passenger Rail Operators and Amtrak 

TSA directives require passenger rail operators to: 

• designate coordinators to enhance security-related communications with TSA 

• provide TSA with access to the latest security assessments and security plans 

• reinforce employee watch programs 

• ask passengers and employees to report unattended property or suspicious behavior 

• remove trash receptacles at stations determined by a vulnerability assessment to be at significant risk and only to the extent 

practical, except for clear plastic or bomb-resistant containers 

• install bomb-resistant trash cans to the extent resources allow 

• utilize canine explosive detection teams, if available, to screen passenger baggage, terminals, and trains 

• utilize surveillance systems to monitor for suspicious activity, to the extent resources allow 

• allow TSA-designated canine teams at any time or place to conduct canine operations 

• conduct frequent inspections of key facilities, stations, terminals, or other critical assets for persons and items that do not belong 

• inspect each passenger rail car for suspicious or unattended items, at regular periodic intervals 

• ensure that appropriate levels of policing and security are provided that correlate to DHS threat levels and threat advisories 

• lock all doors that allow access to train operators’ cab or compartment, if equipped with locking mechanisms 

• require Amtrak to request that adult passengers provide identification at the initial point where tickets are checked 

Source: TSA. 

Although TSA issued these directives, it is unclear how TSA developed the 

required measures contained in the directives, how TSA plans to monitor 

 35According to TSA, in issuing the passenger rail and mass transit security directives, TSA 

exercised its authorities under 49 U.S.C. 114. We are currently examining whether TSA met 

all relevant legal requirements in the promulgation of the directives. 

TSA Issued Mandatory 

Security Directives to Rail 

Operators but Faces 

Challenges Related to 

Compliance and 

Enforcement 
Page 37 GAO-05-851 Passenger Rail Security 

and ensure compliance with the measures, how rail operators are to 

implement the measures, and which entities are responsible for their 

implementation. According to the former DHS Undersecretary for Border 

and Transportation Security, the directives were developed based upon 

consultation with the industry and a review of best practices in passenger 

rail and mass transit systems across the country and were intended to 

provide a federal baseline standard for security. TSA officials stated to us 

that the directives were based upon FTA and APTA best practices for rail 

security. Specifically, TSA stated that it consulted a list of the top 20 

actions FTA identified that rail operators can take to strengthen security, 

FTA-recommended protective measures and activities for transit agencies 

that may be followed based on current threat levels, and an APTA member 

survey. While some of the directives correlate to information contained in 

the FTA guidance, such as advocating that rail personnel watch for 

abandoned parcels, vehicles, and the like, the source for many of the 

directives is unclear. For example, the source material TSA consulted does 

not support the requirement that train cabs or compartment doors should 

be kept locked. Furthermore, the sources do not necessarily reflect 

industry best practices, according to FTA and APTA officials. FTA’s list of 

recommended protective measures and the practices identified in the 

APTA survey are not necessarily viewed as industry best practices. For 

example, the APTA member survey that TSA used reports rail security 

practices that are in use by operators but which are not best practices 

endorsed by the group or other industry stakeholders. 

TSA officials have stated that they understood the importance of 

partnering with the rail industry on security matters, and that they would 

draw on the expertise and knowledge of the transportation industry and 

other DHS agencies, as well as all stakeholders, in developing security 

standards for all modes of transportation, including rail. TSA officials held 

an initial meeting with APTA, AAR, and Amtrak officials to discuss the 

draft directives prior to their issuance and told them that they would 

continue to be consulted prior to their final issuance. However, these 

stakeholders were not given an opportunity to comment on a final draft of 

the directives before their release because, according to TSA, DHS 

determined that it was important to release the directives as soon as 

possible to address a current threat to passenger rail. In addition, TSA 

stated that because the directives needed to be issued quickly, there was 

no public comment as part of the rule-making process. Shortly after the 

directives were issued, TSA’s Deputy Assistant Administrator for Maritime 

and Land Security told rail operators at an APTA conference we attended 

in June 2004 that if TSA determined that there is a need for the directives 

to become permanent, they would undergo a notice-and-comment period 
Page 38 GAO-05-851 Passenger Rail Security 

as part of the regulatory process. As of July 2005, TSA had not yet 

determined whether it intends to pursue the rule-making process with a 

notice-and-comment period. 

APTA and AAR officials stated that because they were not consulted 

throughout the development of the directives, the directives did not, in 

their view, reflect a complete understanding of the passenger rail 

environment or necessarily incorporate industry best practices. For 

example, APTA, AAR, and some rail operators raised concerns about the 

feasibility of installing bomb-resistant trash cans in rail stations because 

they could direct the force of a bomb blast upward, possibly causing 

structural damage in underground or enclosed stations. DHS’s Office for 

State and Local Government Coordination and Preparedness recently 

conducted tests to determine the safety and effectiveness of 13 models of 

commercially available bomb-resistant trash receptacles. At the time of 

our review, the results of these tests were not yet available. 

Amtrak and FRA officials raised concerns about some of the directives, as 

well, and told us they questioned whether the requirements reflected 

industry best practices. For example, before the directives were issued, 

Amtrak expressed concerns to TSA about the feasibility of the requirement 

to check the identification of all adult passengers boarding its trains 

because they did not have enough staff to perform these checks. However, 

the final directive included this requirement, and after they were released, 

Amtrak told TSA it could not comply with this requirement “without 

incurring substantial additional costs and significant detrimental impacts 

to its operations and revenues.” Amtrak officials told us that since 

passenger names would not be compared against any criminal or terrorist 

watch list or database, the benefits of requiring such identification checks 

were open to debate. To resolve its concern, and as allowed by the 

directive, Amtrak proposed, and TSA accepted, random identification 

checks of passengers as an alternative measure. FRA officials further 

stated that current FRA safety regulations requiring engineer compartment 

doors be kept unlocked to facilitate emergency escapes36 conflicts with the 

security directive requirement that doors equipped with locking 

mechanisms be kept locked. This requirement was not included in the 

draft directives provided to stakeholders. TSA did call one commuter rail 

operator prior to issuing the directives to discuss this potential proposed 

measure, and the operator raised a concern about the safety of the locked 

 3649 CFR 238.235. 
Page 39 GAO-05-851 Passenger Rail Security 

door requirement. TSA nevertheless included this requirement in the 

directives. 

With respect to how the directives were to be enforced, rail operators 

were required to allow TSA and DHS to perform inspections, evaluations, 

or tests based on execution of the directives at any time or location. Upon 

learning of any instance of noncompliance with TSA security measures, 

rail operators were to immediately initiate corrective action. Monitoring 

and ensuring compliance with the directives has posed challenges for TSA. 

In the year after the directives were issued, TSA did not have dedicated 

field staff to conduct on-site inspections. When the rail security directives 

were issued, the former DHS Undersecretary for Border and 

Transportation Security stated that TSA planned to form security 

partnership teams with DOT, including FRA rail inspectors, to help ensure 

that industry stakeholders complied with the directives. These teams were 

to be established in order to tap into existing capabilities and avoid 

duplication of effort across agencies. As of July 2005, these teams had not 

yet been utilized to perform inspections. TSA has, however, hired rail 

compliance inspectors to, among other things, monitor and enforce 

compliance with the security directives. As of July 2005, TSA had hired 57 

of up to 100 inspector positions authorized by Congress.37 However, TSA 

has not yet established processes or criteria for determining and enforcing 

compliance, including determining how rail inspectors or DOT partnership 

teams will be used in this regard. 

Establishing criteria for monitoring compliance with the directives may be 

challenging because the language describing the required measures allows 

for flexibility and does not define parameters. In an effort to acknowledge 

the variable conditions that existed in passenger rail environments, TSA 

designed the directives to allow flexibility in implementation through the 

use of such phrases as “to the extent resources allow,” “to the extent 

practicable,” and “if available.” The directives also include non-specific 

instructions that may be difficult to measure or monitor, telling operators 

to, for example, perform inspections of key facilities at “regular periodic 

intervals” or to conduct “frequent inspections” of passenger rail cars. 

When the directives were issued, TSA stated that it would provide rail 

operators with performance-based guidance and examples of 

 37These positions were funded through the DHS Appropriations Act of 2005 and its 

accompanying conference report, which provided TSA with $12 million in funding for rail 

security activities. 
Page 40 GAO-05-851 Passenger Rail Security 

announcements and signs that could be used to meet the requirements of 

the directives, including guidance on the appropriate frequency and 

method for inspecting rail cars and facilities. However, as of July 2005, this 

information had not been provided. 

Industry stakeholders we interviewed raised questions about how they 

were to comply with the measures contained in the directives and which 

entities were responsible for implementing the measures. According to an 

AAR official, in June 2004, AAR officials and rail operators held a 

conference call with TSA to obtain clarification on these issues. According 

to AAR officials, in response to an inquiry about what would constitute 

compliance for some of the measures, the then-TSA Assistant 

Administrator for Maritime and Land Security told participants that the 

directives were not intended to be overly prescriptive but were guidelines, 

and that operators would have the flexibility to implement the directives 

as they saw fit. The officials also asked for clarification on who was legally 

responsible for ensuring compliance for measures where assets, such as 

rail stations, were owned by freight railroads or private real estate 

companies. According to AAR officials, TSA told them it was the 

responsibility of the rail operators and asset owners to work together to 

determine these responsibilities. However, according to AAR and rail 

operators, given that TSA has hired rail inspectors and indicated its 

intention to enforce compliance with the directives, it is critical that TSA 

clarify what compliance entails for measures required by the directives 

and which entities are responsible for compliance with measures when 

rail assets are owned by one party but operated by another—such as when 

private companies that own terminals or stations provide services for 

commuter rail operations. 

The challenges TSA has faced in developing security directives as 

standards that reflect industry best practices—and which can be measured 

and enforced—stem from the original emergency nature of the directives, 

which were issued with limited input and review. TSA told rail industry 

stakeholders when the directives were issued 15 months ago that the 

agency would consider using the federal rule-making process as a means 

of making the standards permanent. Doing so would require TSA to hold a 

notice-and-comment period, resulting in a public record that reflects 

stakeholders’ input on the applicability and feasibility of implementing the 

directives, along with TSA’s rationale for accepting or rejecting this input. 

While there is no guarantee that this process would produce more 

effective security directives, it would be more transparent and could help 

TSA in developing standards that are most appropriate for the industry 

and can be measured, monitored, and enforced. 
Page 41 GAO-05-851 Passenger Rail Security 

In addition to issuing security directives, TSA also sought to enhance 

passenger rail security by conducting research on technologies related to 

screening passengers and checked baggage in the passenger rail 

environment. Beginning in May 2004, TSA conducted a Transit and Rail 

Inspection Pilot (TRIP) study, in partnership with DOT, Amtrak, the 

Connecticut Department of Transportation, the Maryland Transit 

Administration, and the Washington Metropolitan Area Transit Authority 

(WMATA). TRIP was a $1.5 million, three-phase effort to test the feasibility 

of using existing and emerging technologies to screen passengers, carry-on 

items, checked baggage, cargo, and parcels for explosives. Figure 5 

summarizes TRIP’s three-phased approach. 

Figure 5: Summary Information on TSA’s Transit and Rail Inspection Pilot Program Phases 

Source: TSA. 

According to TSA, all three phases of the TRIP program were completed 

by July 2004. However, TSA has not yet issued a planned report analyzing 

whether the technologies could be used effectively to screen rail 

passengers and their baggage. According to TSA officials, a report on 

results and lessons learned from TRIP is under review by DHS. TSA 

officials told us that based upon preliminary analyses, the screening 

technologies and processes tested would be very difficult to implement on 

more heavily used passenger rail systems, such as mass transit systems in 

large urban areas, because these systems carry high volumes of 

passengers and have multiple points of entry. However, TSA officials 

stated to us that the screening processes used in TRIP may be useful on 

certain long-distance intercity train routes, which make fewer stops. 

Further, officials stated that screening could be used either randomly or 

for all passengers during certain high-risk events or in areas where a 

particular terrorist threat is known to exist. For example, screening 

TSA Has Begun Testing 

Rail Security Technologies 

Phase I: Screen commuter rail passengers and carry-on baggage before trains are boarded using an 

explosive detection device similar in appearance to an airport metal detector and other explosive screening 

technologies.

Phase II: Screen passenger baggage including checked baggage, unclaimed baggage, and cargo on longhaul Amtrak trains prior to departure. 

Phase III: Screen passengers and their carry-on baggage on board a moving commuter rail train. All 

passengers are required to enter the train in the specially designed screening car, which was a commuter 

rail passenger car that been reconfigured to hold screening equipment and security personnel. 
Page 42 GAO-05-851 Passenger Rail Security 

technology similar to that used in TRIP was used by TSA to screen certain 

passengers and belongings in Boston and New York during the Democratic 

and Republican national conventions, respectively, in 2004. 

APTA officials and the 28 passenger rail operators we interviewed—all 

who are not directly involved in the pilot—agreed with TSA’s preliminary 

assessment. They told us they believed that the TRIP screening procedures 

could not work in most passenger rail systems, given the number of 

passengers using these systems and the open nature (e.g., multiple entry 

points) of the systems. For example, as one operator noted, over 1,600 

people pass through dozens of access points in New York’s Penn Station 

per minute during a typical rush hour, making screening of all passengers 

very challenging, if not impossible. Passenger rail operators were also 

concerned that screening delays could result in passengers opting to use 

other modes of transportation. APTA officials and some rail operators we 

interviewed said that had they been consulted by TSA, they would have 

recommended alternative technologies to explore and indicated that they 

hoped to be consulted on security technology pilot programs in the future. 

FRA officials further stated that TSA could have benefited from earlier and 

more frequent collaboration with them during the TRIP pilot than 

occurred, and could have tapped their expertise to analyze TRIP results 

and develop the final report. TSA research and development officials told 

us that the agency has begun to consider and test security technologies 

other than those used in TRIP, which may be more applicable to the 

passenger rail environment. For example, TSA’s and DHS’s Science and 

Technology Directorate are currently evaluating infrared cameras and 

electronic metal detectors, among other things. 

In our prior transportation security work, we have called for improved 

coordination among all levels of government and the private sector, as a 

means of enhancing security across all transportation modes.38 In 

September 2004, DHS and DOT signed a memorandum of understanding to 

develop procedures by which the two departments could improve their 

cooperation and coordination for promoting the safe, secure, and efficient 

movement of people and goods throughout the transportation system. The 

MOU defines broad areas of responsibility for each department. For 

example, it states that DHS, in consultation with DOT and affected 

stakeholders, will identify, prioritize, and coordinate the protection of 

 38GAO-03-263 and GAO-03-843. 

DHS and DOT Are Taking 

Steps to Improve 

Coordination and 

Collaboration with Federal 

Agencies and Industry 

Stakeholders 
Page 43 GAO-05-851 Passenger Rail Security 

critical infrastructure. The MOU was developed in response to a 

recommendation we made in June 2003 in which we noted that the roles 

and responsibilities of DOT and TSA for transportation security matters 

had not been clearly defined. We emphasized the need for greater 

coordination between DOT and TSA on transportation security efforts—

noting that the lack of coordination can lead to duplication or conflicting 

efforts and gaps in preparedness. To improve coordination between DOT 

and DHS on transportation security matters, we recommended that DOT 

and DHS develop a mechanism, such as a memorandum, to clearly define 

roles and responsibilities for transportation security matters, in such areas 

as the development and implementation of security standards and 

regulations, determining funding priorities, and interfacing with the 

transportation industry. 

The MOU between DHS and DOT represents an overall framework for 

cooperation that is to be supplemented by additional signed agreements, 

or annexes, between the departments. These annexes are to delineate the 

specific security-related roles, responsibilities, resources, and 

commitments for mass transit, rail, research and development, and other 

matters. As of July 2005, separate annexes for mass transit security, rail 

security, and research and development were at various stages of 

development, according to DHS and DOT officials. DHS and DOT officials 

told us that an annex for mass transit security had been prepared and was 

undergoing final review by both departments. According to DHS and DOT 

officials, the annex is intended to ensure that the programs and protocols 

for incorporating stakeholder feedback and making enhancements to 

security measures are coordinated. 

According to officials, the mass transit annex will address how DHS’s 

Office of State and Local Government Coordination and Preparedness, 

TSA, FTA, and DOT’s Office of Intelligence, Security, and Emergency 

Management are to coordinate their programs and services, including 

grants, training, exercises, risk assessments, and technical assistance, in 

order to better assist transit agencies in prioritizing and addressing their 

security needs. For example, officials stated to us that the annex would 

likely address coordination on such programs as FTA’s Transit Watch and 

Transit Safety and Security Roundtables programs, which are designed to 

raise transit employees’ on-the-job awareness about security and provide a 

forum for stakeholders to share information on technology and best 

practices. In addition, according to officials, the annex will require DHS 

and DOT to consult on such matters as regulations and security directives 

that affect security and will identify points of contact for coordinating this 

consultation. 
Page 44 GAO-05-851 Passenger Rail Security 

In addition to the annexes currently under development, DHS and DOT 

must also complete an annex to define and clarify the respective roles and 

responsibilities of DHS and DOT relating to public transportation security 

within 45 days of the enactment of The Safe, Accountable, Flexible, and 

Efficient Transportation Equity Act of 2005, which President Bush signed 

on August 10, 2005. According to the law, this annex shall establish a 

process to develop security standards for public transportation agencies; 

create a method of direct coordination with public transportation agencies 

on security matters; address any other issues determined to be appropriate 

by the Secretary of Transportation and the Secretary of Homeland 

Security; and include a formal and permanent mechanism to ensure 

coordination and involvement by DOT, as appropriate, in public 

transportation security.39

In addition to their work on the MOU and related annexes, DHS and TSA 

have taken other steps in an attempt to improve collaboration with DOT 

and industry stakeholders. In April 2005, DHS officials stated that better 

collaboration with DOT and industry stakeholders was needed to develop 

strategic security plans associated with various homeland security 

presidential directives and statutory mandates, such as the Intelligence 

Reform and Terrorism Prevention Act of 2004, which required DHS to 

develop a national strategy for transportation security in conjunction with 

DOT. Responding to the need for better collaboration, DHS established a 

senior-level steering committee in conjunction with DOT to coordinate 

development of this national strategy. In addition, senior DHS and TSA 

officials stated that industry groups will also be involved in developing the 

national strategy for transportation security and other strategic plans. 

Moreover, according to TSA’s assistant administrator for intermodal 

programs, TSA intends to work with APTA and other industry 

stakeholders in developing security standards for the passenger rail 

industry.40

 39Section 3028 of Pub. L. No. 109-59. 

40APTA is a standards development organization recognized by DOT that has set standards 

for commuter rail, mass transit, and bus safety and operations. 
Page 45 GAO-05-851 Passenger Rail Security 

U.S. passenger rail operators have taken numerous actions to secure their 

rail systems since the terrorist attacks of September 11, in the United 

States, and the March 11, 2004, attacks in Madrid. These actions included 

both improvements to system operations and capital enhancements to a 

system’s facilities, such as track, buildings, and train cars. All of the U.S. 

passenger rail operators we contacted have implemented some types of 

security measures—such as increased numbers and visibility of security 

personnel and customer awareness programs—that were generally 

consistent with those we observed in select countries in Europe and Asia. 

We also identified three rail security practices—covert testing, random 

screening of passengers and their baggage, and centralized research and 

testing—utilized by foreign operators or their governments that are not 

currently utilized by domestic rail operators or the U.S. government.41

All 32 of the U.S. rail operators we interviewed or visited reported taking 

specific actions to improve the security and safety of their rail systems by, 

among other things, investing in new security equipment, utilizing more 

law enforcement personnel, and establishing public awareness campaigns. 

Passenger rail operators we spoke with cited the 1995 sarin gas attacks on 

the Tokyo subway system and the September 11 terrorist attacks as 

catalysts for their security actions. After the attacks, many passenger rail 

operators used FTA’s security readiness assessments of heavy and 

passenger rail systems as a guide to determine how to prioritize their 

security efforts, as well as their own understanding of their system’s 

vulnerabilities, to determine what actions to take to enhance security. 

Similarly, as previously mentioned, the rail systems that underwent ODP 

risk assessments are currently using or plan to use these assessments to 

guide their security actions. In addition, 20 of the 32 U.S. operators we 

contacted or visited had conducted some type of security assessment 

internally or through a contractor, separate from the federally funded 

assessments. For example, some assessments evaluated vulnerabilities of 

physical assets, such as tunnels and bridges, throughout the passenger rail 

system. Passenger rail operators stated that security-related spending by 

rail operators was also based, in part, on budgetary considerations, as well 

as other practices used by other rail operators that were identified through 

 41At the time we completed our work, in June 2005, these three practices were not utilized. 

However, as discussed later in this report, some rail operators began using random 

screening in the aftermath of the July bomb attacks on the London subway system. 

U.S. and Foreign Rail 

Operators Have Taken 

Similar Actions to 

Secure Rail Systems, 

and Opportunities for 

Additional Domestic 

Security Actions May 

Exist 

Actions Taken by U.S. and 

Foreign Passenger Rail 

Operators to Strengthen 

Security Reflect Security 

Assessments, Budgetary 

Constraints, and Other 

Factors 
Page 46 GAO-05-851 Passenger Rail Security 

direct contact or during industry association meetings. 42 Passenger rail 

operators frequently made capital investments to improve security, and 

these investments often are not part of federal funding packages for new 

construction unless they are part of new facilities being constructed. 

According to APTA, 54 percent of transit agencies are facing increasing 

deficits, and no operator covers expenses with fare revenue; thus, 

balancing operational and capital improvements with security-related 

investments has been an ongoing challenge for these operators. Several 

foreign rail operators we interviewed also stated that funding for security 

enhancements was limited in light of other funding priorities within the 

rail system, such as personnel costs and infrastructure and equipment 

maintenance. 

Foreign rail operators we visited also told us that risk assessments played 

an important role in guiding security-related spending for rail. For 

example, one foreign rail operator with a daily ridership of 2.3 million 

passengers used a risk management methodology to assess risks, threats, 

and vulnerabilities to rail in order to guide security spending. The 

methodology is part of the rail operator’s corporate focus on overall safety 

and security and is intended to help protect the operator’s various rail 

systems against, among other things, terrorist attacks, as well as other 

forms of corporate loss, such as service disruption and loss of business 

viability. According to the operator, the methodology employs a “riskinformed” approach to support management’s business decision process 

regarding security. Other than the results of risk assessments, issues such 

as laws and regulations, and business requirements, are also taken into 

consideration. The approach relies on a combination of risk, threat, and 

vulnerability assessment and management, and focuses on proactive 

prevention. Implementing the methodology involves all corporate 

departments and staff at three activity levels: 

• At the corporate level, the focus on security is articulated in a threepart corporate security policy that states, among other things, that 

managers are responsible for performing risk management activities in 

their functional areas and maintaining cost-effective security measures. 

 42As we have previously reported, since the mid-1990s, federal funding for transit and 

commuter rail operators has generally been limited to assistance with capital projects 

involving building new transit service, extensions of existing lines, or rehabilitation of 

existing transit infrastructure, such as tracks, rolling stock, or stations. See GAO-03-263. 
Page 47 GAO-05-851 Passenger Rail Security 

• At the department level, department heads are responsible for 

promoting security awareness, setting rules and guidelines, and 

allocating security responsibilities (in the form of assigning “risk 

ownership”). 

• At the line level, managers are responsible for implementing the risk 

assessment component of the methodology, consistent with the 

security policy described earlier. This component, which involves an 

iterative process, consists of identifying threats and quantifying risks 

(risk is expressed as a function of likelihood and consequence); 

designing and implementing security protective measures; and 

measuring compliance with and the effectiveness of these measures, 

similar to our risk management approach. 

According to officials of the foreign rail operator, to measure 

performance, the operator conducts periodic surveys to measure the 

perceptions of riders and employees; rates the success of drills; and 

measures the incidence of crime (such as pick pocketing). The operator’s 

security department also conducts audits to measure compliance and help 

ensure that security procedures are being followed. Separately, the rail 

operator’s insurers review the security management of the rail system, 

including the methodology, every 4 years. 

Both U. S. and foreign passenger rail operators we contacted have 

implemented similar operational and capital improvements43 to enhance 

the security of their systems.44 A summary of these efforts follows. 

Customer awareness: Customer awareness programs we observed used 

signage and announcements to encourage riders to alert train staff if they 

observed suspicious packages, persons, or behavior. Of the 32 domestic 

rail operators we interviewed, 30 had implemented a customer awareness 

program or made enhancements to an existing program. FTA has assisted 

 43Operational enhancements are actions that involve changes to the way a rail agency’s 

staff operate their rail system on a day-to-day basis—such as enhancing customer 

awareness, increasing the number and visibility of security personnel, training employees, 

and implementing selective passenger and baggage screening. Capital improvements 

include construction of new facilities or rehabilitation of old facilities such as stations, 

train yards, tracks, and so on, or purchase of new equipment to enhance existing 

capabilities. 

44Actions taken by Amtrak to enhance security are discussed later in this report. 

U.S. and Foreign Rail 

Operators Employ Similar 

Security Practices 

Operational improvements 
Page 48 GAO-05-851 Passenger Rail Security 

rail operators in this area by creating the Transit Watch program, in 

cooperation with industry groups such as APTA. Transit Watch is a 

nationwide safety and security awareness program designed to encourage 

the active participation of transit passengers and employees in maintaining 

a safe transit environment. FTA distributed education and training 

materials to rail operators so these materials could be provided to 

customers and employees. Rail operators stated that they attempt to 

entitle their customer awareness programs so that customers can easily 

remember the goals of the program. New York City Transit’s “If You See 

Something, Say Something” campaign and the WMATA program, “Is That 

Your Bag?” are examples of this. (See fig. 6 for an example of public 

awareness signage). Foreign rail operators we visited also attempt to 

enhance customer awareness. For example, 11 of the 13 operators we 

interviewed had implemented a customer awareness program. Similar to 

programs of U.S. operators, these programs used signage, announcements, 

and brochures to inform passengers and employees about the need to 

remain vigilant and report any suspicious activities. Only one of the 

European passenger rail operators that we interviewed has not 

implemented a customer security awareness program, citing the fear or 

panic that it might cause among the public. 
Page 49 GAO-05-851 Passenger Rail Security 

Figure 6: Example of Passenger Rail Customer Awareness Poster 

Increased number and visibility of security personnel: Of the 32 U.S. rail 

operators we interviewed, 23 had increased the number of security 

personnel they utilized since September 11, to provide security throughout 

their system or had taken steps to increase the visibility of their security 

personnel. In addition to adding security personnel, many operators stated 

that increasing the visibility of security was as important as increasing the 

number of personnel. For example, several U.S. and foreign rail operators 

we spoke with had instituted policies such as requiring their security staff, 

in brightly colored vests, to patrol trains or stations more frequently, so 

they are more visible to customers and potential terrorists or criminals. 

These policies make it easier for customers to contact security personnel 

in the event of an emergency, or if they have spotted a suspicious item or 

person. At foreign sites we visited, 10 of the 13 operators had increased 

the number of their security officers throughout their systems in recent 

years because of the perceived increase in risk of a terrorist attack. One 

rail operator, the Tokyo Metro system, in addition to increasing the 

number of security personnel, has also made them more visible. Tokyo 

Metro stations now include an elevated security platform for security 

Source: WMATA.
Page 50 GAO-05-851 Passenger Rail Security 

personnel to stand on, which allows them to better see throughout the 

station and allows passengers to see the security staff more easily. 

Increased use of canine teams: Of the 32 U.S. passenger rail operators we 

contacted, 21 had begun to use canine units, which include both dogs and 

human handlers, to patrol their facilities or trains or had increased their 

existing utilization of such teams. Often, these units are used to detect the 

presence of explosives, or in some cases, drugs, and may be called in 

when a suspicious package is detected. One operator we spoke with uses 

its canines to patrol its system simply as a crime deterrent rather than to 

detect explosives or drugs. Some operators that did not maintain their 

own canine units stated that it was prohibitively expensive to do so and 

that they could call in local police canine units if necessary. In foreign 

countries we visited, passenger rail operators’ use of canines varied. In 

some Asian countries, canines were not culturally accepted by the public 

and thus were not used for rail security purposes. In contrast, most 

European passenger rail operators, as in the United States, used canines 

for explosive detection or as deterrents. 

Employee training: All of the domestic and foreign rail operators we 

interviewed had provided some type of security training to their staff, 

either through in-house personnel or an external provider. In many cases, 

this training consisted of ways to identify suspicious items and persons 

and how to respond to events once they occur. For example, the London 

Underground and the British Transport Police developed the “HOT” 

method for its employees to identify suspicious items in the rail system. In 

the HOT method, employees are trained to look for packages or items that 

are Hidden, Obviously suspicious, and not Typical of the environment. 

Items that do not meet these criteria would likely receive a lower security 

response than an item meeting all of the criteria. However, if items meet 

all of these criteria, employees are to notify station managers, who would 

call in the authorities and potentially shut down the station or take other 

action. According to London Underground officials, the HOT method has 

significantly reduced the number of system disruptions caused when a 

suspicious item was identified. In addition, officials noted that the HOT 

method is easy for rail employees to remember and is successful, in part, 

because it provides rail employees with the discretion to make securityrelated decisions on their own. According to British Transport Police and 

London Underground officials, there have been no cases where 

unattended packages that employees determined did not meet the HOT 

criteria contained explosive devices. Several passenger rail operators in 

the United States and abroad have trained their employees in the HOT 

method. Several domestic operators had also trained their employees in 
Page 51 GAO-05-851 Passenger Rail Security 

how to respond to terrorist attacks and provided them with wallet-size 

cards highlighting actions they should take in response to various forms of 

attack. (See fig. 7 for examples of cards that are distributed by the San 

Francisco Bay Area Rapid Transit [BART] to their employees to help them 

prevent or respond to terrorist attacks.) It is important to note that 

training such as the HOT method is not designed to prevent acts of 

terrorism like the July 2005 London attacks, where suicide bombers killed 

themselves rather than leaving bombs behind. 
Page 52 GAO-05-851 Passenger Rail Security 

Figure 7: Wallet-size Cards Distributed to BART Employees Containing Anti-terrorism Information 

Source: San Francisco Bay Area Rapid Transit District.

Example of instructions on reverse 

side of card for BART employees

Not actual size

Reverse side
Page 53 GAO-05-851 Passenger Rail Security 

Officials from the London Underground also provided insights into the 

importance of how training is provided to staff, in addition to the type of 

training provided. In training rail station staff, London Underground 

officials stressed the importance of direct supervisors or managers 

providing security briefings to each employee or small groups of 

employees. In doing so, officials stated that they believed it helps make 

staff more aware of their responsibilities in certain situations, enables 

supervisors to hold employees accountable for what they learned in 

training, and allows employees to ask questions related to their specific 

job duties. 

Passenger and baggage screening practices: Some domestic and foreign 

rail operators have trained employees to recognize suspicious behavior as 

a means of screening passengers. Eight U.S. passenger rail operators we 

contacted were utilizing some form of behavioral screening. For example, 

the Massachusetts Bay Transportation Authority (MBTA), which operates 

Boston’s T system, has utilized a behavioral screening system to identify 

passengers exhibiting suspicious behavior. The Massachusetts State Police 

train all MBTA personnel to be on the lookout for behavior that may 

indicate someone has criminal intent, and to approach and search such 

persons and their baggage when appropriate. Massachusetts State Police 

officers have been training rail operators on this behavior profiling system, 

and WMATA and New Jersey Transit were among the first additional 

operators to implement the system. According to MBTA personnel, several 

other operators have expressed interest in this system. Abroad, we found 

that 4 of 13 operators we interviewed had implemented forms of 

behavioral screening similar to MBTA’s system. (Rail operators’ use of 

random screening of passengers is discussed later in the report.) 

All of the domestic and foreign rail operators we contacted have ruled out 

an airport-style screening system for daily use in heavy traffic, where each 

passenger and the passenger’s baggage are screened by a magnetometer or 

X-ray machine, based on cost, staffing, and customer convenience factors, 

among others. For example, although the Spanish National Railway 

screens passenger baggage using an X-ray machine on certain longdistance trains that it believes could be at risk, all of the operators we 

contacted stated that the cost, staffing requirements, delay of service, and 

inconvenience to passengers would make such a system unworkable in 

highly trafficked, inherently open systems like U.S. and foreign passenger 

rail operations. In addition, one Asian rail official stated that his 

organization was developing a contingency plan for implementing an 

airport-style screening system, but that such a system would be used only 

in the event of intelligence information indicating suicide bomb attacks 
Page 54 GAO-05-851 Passenger Rail Security 

were imminent, or if several attacks had already occurred during a short 

period of time. According to this official, the plan was in the initial stages 

of development, and the organization did not know how quickly such a 

system could be implemented. 

Upgrading technology: Many rail operators we interviewed had embarked 

on programs designed to upgrade their existing security technology. For 

example, we found that 29 of the 32 U.S. operators had implemented a 

form of CCTV to monitor their stations, yards, or trains. While these 

cameras cannot be monitored closely at all times, because of the large 

number of staff they said this would require, many rail operators felt the 

cameras acted as a deterrent, assisted security personnel in determining 

how to respond to incidents that have already occurred, and could be 

monitored if an operator has received information that an incident may 

occur at a certain time or place in their system. One rail operator, New 

Jersey Transit, had installed “smart” cameras, which were programmed to 

alert security personnel when suspicious activity occurred, such as if a 

passenger left a bag in a certain location or if a boat were to dock under a 

bridge. According to the New Jersey Transit officials, this technology was 

relatively inexpensive and not difficult to implement. Several other 

operators stated they were interested in exploring this technology. 

Abroad, all 13 of the foreign rail operators we visited had CCTV systems in 

place. For example, the London Underground uses an extensive system of 

CCTV cameras to monitor all of its passenger rail system stations and 

respond to both criminal and emergency incidents. In addition, one Asian 

system we visited had over 1,000 cameras recording activity in some of its 

busier stations. However, as in the United States, foreign rail operators use 

these cameras primarily as a crime deterrent and to respond to incidents 

after they occur, because they do not have enough staff to continuously 

monitor all of these cameras. The Madrid Metro is currently testing the use 

of personal digital assistants (PDA), which would have the ability to 

operate all security functions in passenger rail stations. These PDAs would 

enable security staff to monitor any station CCTV camera that they chose 

from the PDA and respond to a potential emergency, such as a terrorist 

attack, by shutting down rail or station operations (escalators or 

ventilation systems, amongst others) from the PDA itself. Madrid Metro 

officials said that they plan to make the use of the PDAs operational in the 

future, but did not know when they would do so. 

In addition, 18 of the 32 U.S. rail operators we interviewed had installed 

new emergency phones or enhanced the visibility of the intercom systems 

they already had. Passengers can use these systems to contact train 

Capital improvements 
Page 55 GAO-05-851 Passenger Rail Security 

operators or security personnel to report suspicious activity, crimes in 

progress, or other problems. Furthermore, while most rail operators we 

spoke with had not installed chemical or biological agent detection 

equipment because of the costs involved, a few operators had this 

equipment or were exploring purchasing it. For example, WMATA, in 

Washington, D.C., has installed these sensors in some of its stations, 

thanks to a program jointly sponsored by DOT and the Department of 

Energy that provided this equipment to WMATA because of the high 

perceived likelihood of an attack in Washington, D.C. Also, at least three 

other domestic rail operators we spoke with are exploring the possibility 

of partnering with federal agencies to install such equipment in their 

facilities on an experimental basis. 

Also, as in the United States, a few foreign operators had implemented 

chemical or biological detection devices at these rail stations, but their use 

was not widespread. Two of the 13 foreign operators we interviewed had 

implemented these sensors, and both were doing so on an experimental 

basis. In addition, police officers from the British Transport Police—

responsible for policing the rail system in the United Kingdom—were 

equipped with pagers to detect chemical, biological, or radiological 

elements in the air, allowing them to respond quickly in case of a terrorist 

attack using one of these methods. The British Transit Police also has 

three vehicles carrying devices to determine if unattended baggage 

contains explosives—these vehicles patrol the system 24 hours per day. 

Access control: Tightening access procedures at key facilities or rights-ofway is another way many rail operators have attempted to enhance 

security. A majority of domestic and selected foreign passenger rail 

operators had invested in enhanced systems to control unauthorized 

access at employee facilities and stations. Specifically, 23 of the 32 U.S. 

operators had installed a form of access control at key facilities and 

stations. This often involved installing a system where employees had to 

swipe an access card to gain access to control rooms, repair facilities, and 

other key locations. For example, the Greater Cleveland Regional Transit 

Authority had a particularly comprehensive system where all doors 

throughout its rail system are linked to a central alarm and intrusion 

detection system. If an unauthorized employee or customer attempts to 

gain access to any facility system wide, alarms are to activate in the 

control center. Also, BART in California has a modern system utilizing 

lasers to detect intruders at tunnel portals and other key facilities. Finally, 

all 13 foreign operators had implemented some form of access control to 

their critical facilities or rights-of-way. However, these measures varied 

from simple alarms on doors at electrical substations on one subway 
Page 56 GAO-05-851 Passenger Rail Security 

system we visited to infrared sensors monitoring every inch of right-of-way 

along the track on three of the high-speed interurban rail systems. The 

high-speed systems had these extensive systems because of the potential 

for catastrophe if a train traveling at over 200 miles per hour were to hit a 

vehicle placed along the tracks or travel over rail that had been sabotaged. 

Rail system design and configuration: In an effort to reduce 

vulnerabilities to terrorist attack and increase overall security, passenger 

rail operators in the United States and abroad have been, or are now 

beginning to, incorporate security features into the design of new and 

existing rail infrastructure, primarily rail stations. For example, of the 32 

domestic rail operators we contacted, 22 of them had removed their 

conventional trash bins entirely, or replaced them with transparent or 

bomb-resistant trash bins, as TSA instructed in its May 2004 security 

directives. In past terrorist attacks on rail systems, particularly in Great 

Britain, trash bins have been used as a means for hiding explosive devices. 

Removing trash bins entirely, as PATH in New Jersey has done, eliminates 

the trash bin as a place to hide an explosive device. Installing transparent 

trash bins, as a few operators have done, might allow security personnel to 

see inside trash bins to determine if suspicious items are inside. Three 

operators have installed bomb-resistant trash bins to contain the impact of 

a blast and minimize the amount of dangerous shrapnel that could be 

expelled. Conversely, one rail operator told us that his agency was not 

removing any of its conventional trash bins because it feared litter would 

become an unmanageable problem without them and that bomb-resistant 

and transparent trash bins were ineffective—specifically, that they simply 

directed the force of a bomb blast upward toward the ceiling, which could 

cause severe structural damage in an underground station. Similarly, while 

only a limited number of domestic rail operators we contacted ever had 

bicycle or storage lockers in their systems, many of those operators that 

did, at one time, have those lockers told us that they had removed them to 

avoid the possibility of someone using them as a hiding place for an 

explosive, or had moved them to locations farther away from stations and 

crowded places to minimize the impact of a potential attack. Also, foreign 

rail operators had taken steps to remove traditional trash bins from their 

systems. Of the 13 operators we visited, 8 had either removed their trash 

bins entirely or replaced them with blast-resistant cans or transparent 

receptacles. In fact, the London Underground rail system was the first 

system worldwide to begin using clear plastic trash bags to eliminate 

places to hide an explosive. Officials from the Underground stated that 

this technique helped to deter terrorists from the Irish Republican Army 

from placing bombs in conventional trash cans during the height of that 

organization’s terrorist campaign against the rail system. 
Page 57 GAO-05-851 Passenger Rail Security 

Many foreign rail operators are also incorporating aspects of security into 

the design of their rail infrastructure. Of the 13 operators we visited, 11 

have attempted to design new facilities with security in mind and have 

attempted to retrofit older facilities to incorporate security-related 

modifications. For example, one foreign operator we visited is retrofitting 

its train cars with windows that passengers could open in the event of a 

chemical attack. In addition, the London Underground, one of the oldest 

rail systems in the world, incorporates security into the design of all its 

new stations as well as when existing stations are modified. We observed 

several security features in the design of Underground stations, such as 

using vending machines that have no holes that someone could use to hide 

a bomb, and sloped tops to reduce the likelihood that a bomb can be 

placed on top of the machine. In addition, stations are designed to provide 

staff with clear lines of sight to all areas of the station, such as underneath 

benches or ticket machines, and station designers try to eliminate or 

restrict access to any recessed areas where a bomb could be hidden. 

Figure 8 shows selected security design elements incorporated into 

London Underground stations. 
Page 58 GAO-05-851 Passenger Rail Security 

Figure 8: Selected Security Design Elements Incorporated into London’s Underground 

In one London station, we observed the use of netting throughout the 

station to help prevent objects, such as bombs, from being placed in a 

recessed area, such as beneath a stairwell or escalator. In this station and 

other stations we visited, Underground officials have installed “help posts” 

at which customers can call for help if an incident occurs. When these 

posts are activated, CCTV cameras display a video image of the help post 

and surrounding area to staff at a central command center. This allows the 

staff to directly observe the situation and respond appropriately. See 

figure 9 for a photograph of a help post. 

Source: London Underground.

Vending machines, as well as ticket vendors, can be designed to minimize opportunities for hiding 

objects above or behind them; clear plastic trash bags and clean lines of sight minimize opportunities 

to hide objects on the platform.
Page 59 GAO-05-851 Passenger Rail Security 

Figure 9: Security Design Elements Incorporated into London’s Underground 

Underground officials stated that the incorporation of security features in 

station design is an effective measure in deterring some terrorists from 

attacking the system. For example, officials told us that CCTV video 

recorded the efforts by Irish Republican Army terrorists attempting to 

place an explosive device inside a station—and when they could not find a 

suitable location to hide the device, they placed it outside in a trash can 

instead, thereby mitigating the impact of the explosion. 

In the United States, several passenger rail operators stated that they were 

taking security into account when designing new facilities or remodeling 

older ones. Twenty-two of 32 rail operators we interviewed told us that 

they were incorporating security into the design of new or existing rail 

infrastructure. For example, New York City Transit and PATH officials 

told us they are incorporating security into the design of its new stations, 

including the redesigned Fulton Street station and the World Trade Center 

Hub that were damaged or destroyed during the September 11 attacks. 

Source: London Underground. 

The "help post" in this London Underground rail station allows passengers to contact station security 

staff in an emergency. Once activated, the CCTV camera would be turned on so security staff could 

monitor the situation and identify what actions to take.

Emergency help post

CCTV camera
Page 60 GAO-05-851 Passenger Rail Security 

Under FTA’s New Starts program—a discretionary grant-making program 

available to transit agencies seeking federal funds for new or expanded 

fixed-guideway system construction—a security management plan must 

be developed and security must be taken into consideration when 

designing or constructing federally funded projects. Although securityspecific design considerations are required for these security plans, the 

plans need not incorporate a particular set of security design principles or 

guidelines. In June 2005, FTA issued guidelines for use by the transit 

industry encouraging the incorporation of particular security features into 

the design of transit infrastructure. These guidelines include, for example, 

increasing visibility for onboard staff, reducing the areas where someone 

could hide an explosive device on a transit vehicle, and enhancing 

emergency exits in transit stations. The program guidance for New Starts 

does not require that agencies consider these particular guidelines to 

further enhance station security and mitigate exposures to terrorist attack 

when enhancing new systems or expansions. In response to our inquiry 

about the feasibility and appropriateness of such a requirement, FTA 

officials stated that they planned to incorporate such a requirement into 

the program’s regulations after legislation reauthorizing the New Starts 

program is approved.45

Figure 10 shows a diagram of several security measures that we observed 

in passenger rail stations both in the United States and abroad. It should 

be noted that this represents an amalgam of stations we visited, not any 

particular station. 

 45The New Starts program was reauthorized through the enactment of Pub. L. No. 109-59 on 

August 10, 2005. 
Page 61 GAO-05-851 Passenger Rail Security 

Figure 10: Composite of Selected Security Practices in the Passenger Rail Environment 

TICKETS

FARECARDS

K-9 patrol unit(s)

Station entrance

Enter

Exit

Enter

Exit

Tracks

Elevators

Bench Bench

Law enforcement

Station official(s)

Alert signs

CCTV(s): Pantilt zoom,

digital, and monitored

Security resources currently used

Source: GAO and NOVA Development Corporation.

Operator

Report unattended 

items or suspicious 

activities immediately!

Public awareness

 announcements 

Track monitoring

Station design: ticket

machines, benches, etc.

designed to prevent

items being hidden

Sloped top Sloped top

Camera

Bomb-resistant

trash cans

Subway train
Page 62 GAO-05-851 Passenger Rail Security 

In securing its extensive system, Amtrak faces its own set of securityrelated challenges, some of which are different from those facing a 

commuter rail or transit operator. First, Amtrak operates over thousands 

of miles, often far from large population centers. This makes its route 

system much more difficult to patrol and monitor than one contained in a 

particular metropolitan region, and it causes delays in responding to 

incidents when they occur in remote areas. Also, outside the Northeast 

Corridor, Amtrak operates almost exclusively on tracks owned by freight 

rail companies. Amtrak also utilizes stations owned by freight rail 

companies, transit and commuter rail authorities, private corporations, 

and municipal governments. This means that Amtrak often cannot 

unilaterally make security improvements to others’ rights-of-way or station 

facilities and that it is reliant on the staff of other organizations to patrol 

their facilities and respond to incidents that may occur. Furthermore, with 

over 500 stations, only half of which are staffed, screening even a small 

portion of the passengers and baggage boarding Amtrak trains is difficult. 

Last, Amtrak’s financial condition has never been strong—Amtrak has 

been on the edge of bankruptcy several times—and the future of Amtrak 

operations is in question pending the outcome of the fiscal year 2006 

budget.46

Amid the ongoing challenges of securing its coast-to-coast railway, Amtrak 

has taken some actions to enhance security throughout its intercity 

passenger rail system. For example, Amtrak has initiated a passenger 

awareness campaign, similar to those described elsewhere in this report. 

Also, Amtrak has begun enforcing existing restrictions on carry-on luggage 

that limit passengers to two carry-on bags, not exceeding 50 pounds. All 

bags also must have identification tags on them. Furthermore, Amtrak has 

begun requiring passengers to show positive identification after boarding 

trains when asked by staff to ensure that tickets have not been transferred 

or stolen, although Amtrak officials acknowledge their onboard staffs only 

sporadically enforce this requirement because of the numerous tasks these 

staff members must perform before a train departs. However, in November 

2004, Amtrak implemented the Tactical Intensive Patrols (TIPS) program, 

under which its security staff flood selected platforms to ensure Amtrak 

baggage and identification requirements are met by passengers boarding 

 46The President’s fiscal year 2006 budget proposed eliminating the federal government’s 

subsidy to Amtrak. According to Amtrak officials, while the outcome of the budget is 

unknown at this time, severe cutbacks in Amtrak funding could reduce the amount of 

personnel Amtrak has available to perform security functions, while a total elimination of 

federal funding for Amtrak could cause a system shutdown. 

Amtrak Faces Challenges 

Specific to Intercity 

Passenger Rail in Securing 

Its System 
Page 63 GAO-05-851 Passenger Rail Security 

trains. In addition, Amtrak increased the number of canine units patrolling 

its system, most of which are located in the Northeast Corridor, looking 

for explosives or narcotics and assigned some of its police to ride trains in 

the Northeast Corridor. Also, Amtrak has instituted a policy of randomly 

inspecting checked luggage on its trains. Finally, Amtrak is making 

improvements to the emergency exits in certain tunnels to make 

evacuating trains in the tunnels easier in the event of a crash or terrorist 

attack. 

To ensure that security measures are applied consistently throughout 

Amtrak’s system, Amtrak has established a series of Security Coordinating 

Committees, which include representatives of all Amtrak departments. 

These committees are to review and establish security policies, in 

coordination with Amtrak’s police department, and have worked to 

develop countermeasures to specific threats. According to Amtrak, in the 

aftermath of the July 2005 London bombings, these committees met with 

Amtrak police and security staff to ensure additional security measures 

were implemented. Also in the wake of the London attacks, Amtrak began 

working with the police forces of several large east coast cities, allowing 

them to patrol Amtrak stations to provide extra security. In addition, all 

Amtrak employees now receive a “Daily Security Awareness Tip” and are 

receiving computer-based security training. Amtrak police officers are also 

now receiving specialized counterterrorism training. 

While Amtrak has taken the actions outlined above, it is difficult to 

determine if these actions appropriately or sufficiently addressed pressing 

security needs. As discussed earlier, Amtrak has not performed a 

comprehensive terrorism risk assessment that would provide an empirical 

baseline for investment prioritization and decision making for Amtrak’s 

security policies and investment plans. However, as part of the 2005 

Intercity Passenger Rail Grant Program, Amtrak is required to produce a 

security and emergency preparedness plan, which is to include a risk 

assessment that Amtrak expects to finish by September 30, 2005. Upon 

completing this plan, Amtrak management should have a more informed 

basis regarding which security enhancements should receive the highest 

priority for implementation. 

While many of the security practices we observed in foreign rail systems 

are similar to those U.S. passenger rail operators are implementing, we 

encountered three practices in other countries that were not currently in 

use among the domestic passenger rail operators we contacted at the time 

Three Foreign Rail 

Security Practices Are Not 

Currently Used in the 

United States 
Page 64 GAO-05-851 Passenger Rail Security 

we completed our field work in June 2005, nor were they performed by the 

U.S. government. These practices are discussed below. 

Covert testing: Two of the 13 foreign rail systems we visited utilize 

covert testing to keep employees alert about their security responsibilities. 

Covert testing involves security staff staging unannounced events to test 

the response of railroad staff to incidents such as suspicious packages or 

setting off alarms. In one European system, this covert testing involves 

security staff placing suspicious items throughout their system to see how 

long it takes operating staff to respond to the item. Similarly, one Asian 

rail operator’s security staff will break security seals on fire extinguishers 

and open alarmed emergency doors randomly to see how long it takes 

staff to respond. Officials of these operators stated that these tests are 

carried out on a daily basis and are beneficial because their staff know 

they could be tested at any moment, and they, therefore, are more likely to 

be vigilant with respect to security. 

Random screening: Of the 13 foreign operators we interviewed, 2 have 

some form of random screening of passengers and their baggage in place. 

In the systems where this is in place, security personnel can approach 

passengers either in stations or on the trains and ask them to submit their 

persons or their baggage to a search. Passengers declining to cooperate 

must leave the system. For example, in Singapore, rail agency officials 

rotate the stations where they conduct random searches so that the 

searches are carried out at a different station each day. Prior to the July 

2005 London bombings, no passenger rail operators in the United States 

were practicing a form of random passenger or baggage screening on a 

continuing daily basis. However, during the Democratic National 

Convention in 2004, MBTA instituted a system of random screening of 

passengers, where every 11th passenger at certain stations and times of 

the day was asked to provide his or her bags to be screened. Those who 

refused were not allowed to ride the system. MBTA officials recognized 

that it is impossible to implement such a system comprehensively 

throughout the rail network without massive amounts of additional staff, 

and that even doing random screening on a regular basis would be a drain 

on resources. However, officials stated that such a system is workable 

during special events and times of heightened security but would have to 

be designed very carefully to ensure that passengers’ civil liberties were 

not violated. After the July 2005 London bombings, four passenger rail 

operators—PATH, New York Metropolitan Transportation Authority, 
Page 65 GAO-05-851 Passenger Rail Security 

New Jersey Transit, and Utah Transit Authority in Salt Lake City—

implemented limited forms of random bag screening in their system.47 In 

addition, APTA, FTA, and the National Academy of Science’s 

Transportation Research Board are currently conducting a study on the 

benefits and challenges that passenger rail operators would face in 

implementing a randomized passenger screening system.48 The study is 

examining such issues as the legal basis for conducting passenger 

screening or search, the precedence for such measures in the 

transportation environment, the human resources required, and the 

financial implications and cost considerations involved. As of July 2005, an 

initial draft of the study was under review. 

National government maintains clearinghouse on technologies and 

best practices: According to passenger rail operators in five countries we 

visited, their national governments have centralized the process for 

performing research and developing passenger rail security technologies 

and maintaining a clearinghouse on these technologies and security best 

practices. According to these officials, this allows rail operators to have 

one central source for information on the merits of a particular passenger 

rail security technology, such as chemical sensors, CCTVs, and intrusion 

detection devices. Some U.S. rail operators we interviewed expressed 

interest in there being a more active centralized federal research and 

development authority in the United States to evaluate and certify 

passenger rail security technologies and make that information available 

to rail operators. Although TSA is the primary federal agency responsible 

for conducting transportation security research and development, and has 

conducted the TRIP as previously mentioned, most of the agency’s 

research and development efforts to date have focused on aviation 

security technologies. As a result, domestic rail operators told us that they 

rely on consultations with industry trade associations, such as APTA, to 

learn about best practices for passenger rail security technologies and 

related investments. Several rail operators stated that they were often 

unsure of where to turn when seeking information on security-related 

products, such as CCTV cameras or intrusion detection systems. 

 47According to APTA, MBTA has maintained the right to conduct random searches of 

passengers. In addition, after the London bombings, the Metropolitan Area Rapid Transit 

Authority in Atlanta posted notices on buses and trains stating that it maintains the right to 

conduct random searches. 

48This research is being conducted through the Transit Cooperative Research Program, a 

partnership among these three entities that undertakes research and other technical 

activities in response to the needs of transit service providers. 
Page 66 GAO-05-851 Passenger Rail Security 

Currently, many operators said they informally ask other rail operators 

about their experiences with a certain technology, perform their own 

research via the Internet or trade publications, or perform their own 

testing. 

No federal agency has yet compiled or disseminated best practices to rail 

operators to aid in this process. We have previously reported that 

stakeholders have stated that the federal government should play a greater 

role in testing transportation security technology and making this 

information available to industry stakeholders.49 TSA and DOT agree that 

making the results of research testing available to industry stakeholders 

could be a valuable use of federal resources by reducing the need for 

multiple rail operators to perform the same research and development 

efforts, but they have not taken action to address this.50

Implementing these three practices—covert testing, random screening, 

and a government-sponsored clearinghouse for technologies and best 

practices—in the United States could pose political, legal, fiscal, and 

cultural challenges because of the differences between the United States 

and these foreign nations. For instance, many foreign nations have dealt 

with terrorist attacks on their public transportation systems for decades, 

compared with the United States, where rail transportation has not been 

specifically targeted during terrorist attacks. According to foreign rail 

operators, these experiences have resulted in greater acceptance of 

certain security practices, such as random searches, which the U.S. public 

may view as a violation of their civil liberties or which may discourage 

them from using public transportation. The impact of security measures 

on passengers is an important consideration for domestic rail transit 

operators, since most passengers could choose another means of 

transportation, such as a personal automobile. As such, security measures 

that limit accessibility, cause delays, increase fares, or otherwise cause 

inconvenience could push people away from transit and into their cars. In 

contrast, the citizens of the European and Asian countries we visited are 

more dependent on public transportation than most U.S. residents and 

therefore, according to the rail operators we spoke with, may be more 

willing to accept more intrusive security measures, simply because they 

have no other choice for getting from place to place. Nevertheless, in 

order to identify innovative security measures that could help further 

 49GAO-03-843. 

50See GAO-03-843. 
Page 67 GAO-05-851 Passenger Rail Security 

mitigate terrorism-related risk to rail assets—especially as part of a 

broader risk management approach discussed earlier—it is important to at 

least consider assessing the feasibility and costs and benefits of 

implementing the three rail security practices we identified in foreign 

countries in the United States. Officials from DHS, DOT, passenger rail 

industry associations, and rail systems we interviewed told us that 

operators would benefit from such an evaluation. Furthermore, the 

passenger rail association officials told us that such an evaluation should 

include practices used by foreign rail operators that integrate security into 

infrastructure design. 

Differences in the business models and financial status of some foreign 

rail operators could also affect the feasibility of adopting certain security 

practices in the United States. Several foreign countries we visited have 

privatized their passenger rail operations. Although most of the foreign rail 

operators we visited—even the privatized systems—rely on their 

governments for some type of financial assistance, two foreign rail 

operators generated significant revenue and profits in other business 

endeavors, which they said allowed them to invest heavily in security 

measures for their rail systems. In particular, the Paris Metro system is 

operated by the RATP Corporation (Regie Autonome des Transports 

Parisiens), which also contracts with other cities in France and throughout 

the world to provide consulting and project management services. RATP’s 

ability to make a profit, according to its officials, through its consulting 

services allows the agency to supplement government funding in order to 

support expensive security measures for the Paris mass transit system. 

For example, RATP recently installed a computer-assisted security control 

system that uses CCTV, radio, and global positioning technology that it 

says has significantly reduced the amount of time it takes for security or 

emergency personnel to respond to an incident or emergency, such as a 

terrorist attack. Because of RATP’s available funding for security, the 

corporation also purchased an identical system for the Metropolitan Paris 

Police, so the RATP and the police system would be compatible. In 

addition, according to Hong Kong mass transit system officials, their 

company was highly profitable because of its real estate and development 

operations, allowing the company to invest in security measures. In 

contrast, domestic rail operators do not generate a profit and therefore are 

dependent on financial assistance from the federal, state, and local levels 

of government to maintain and enhance services, including funding 

security improvements. 

Another important difference between domestic and foreign rail operators 

is the structure of their police forces. In particular, England, France, 
Page 68 GAO-05-851 Passenger Rail Security 

Belgium, and Spain all have national police forces patrolling rail systems 

in these countries. The use of a national police force is a reflection that 

these foreign countries often have one nationalized rail system, rather than 

over 30 rail transit systems owned and operated by numerous state and 

local governments, as is the case in the United States. For example, in 

France, the French National Railway operates all intercity passenger rail 

services in the country and utilizes the French Railway police to provide 

security. According to foreign rail operators, the use of one national rail 

police force allows for consistent policing and security measures 

throughout the country. In the United States, in contrast, there is not a 

national police force for the rail transit systems.51 Rather, some transit 

agencies maintain individual polices forces, while others rely on their city 

or county police forces for security. 

The recent London rail bombings made clear that even when a variety of 

security precautions are put in place, passenger rail systems that move 

high volumes of passengers on a daily basis remain vulnerable to attack. It 

is important nonetheless to take the necessary steps to identify and 

mitigate risks to passenger rail systems. In the United States, securing the 

passenger rail system is a daunting task. As we have reported previously, 

the sheer number of stakeholders involved in securing these systems can 

lead to communication challenges, duplication of effort, and confusion 

about roles and responsibilities. Accordingly, enhanced federal leadership 

is needed to help ensure that actions and investments designed to enhance 

security are properly focused and prioritized. We are encouraged by the 

steps DHS components have taken to use elements of a risk management 

approach to guide critical infrastructure protection decisions for the 

passenger rail industry. This is a necessary step in a broader effort by DHS 

to determine how to allocate finite resources not only to help protect all 

modes of transportation, but also to secure other national critical 

infrastructure sectors. 

However, both DHS and TSA could take additional steps to help ensure 

that the risk management efforts under way clearly and effectively identify 

priority areas for security-related investments in rail and other sectors. We 

recognize that TSA has had many aviation security-related responsibilities 

and has implemented many security initiatives to meet legislative 

 51Unlike domestic rail transit agencies, Amtrak maintains a 342-member police force for its 

national network. 

Conclusions 
Page 69 GAO-05-851 Passenger Rail Security 

requirements. Notwithstanding, TSA has not yet completed its 

methodology for determining how the results of threat, criticality, and 

vulnerability assessments will be used to identify and prioritize risks to 

passenger rail and other transportation sectors. In order to complete and 

apply its methodology as part of the forthcoming transportation sectorspecific plan, TSA needs to more consistently involve industry 

stakeholders in the overall risk assessment process and collaborate with 

them on collecting and analyzing information on critical infrastructure and 

key resources in the passenger rail industry. Without consistent and 

substantive stakeholder input, TSA may not be able to fully capture critical 

information on rail assets—information that is needed to properly assess 

risk. In addition, as part of the process to complete its risk assessment 

methodology, TSA needs to consider whether other proven approaches, 

such as ODP’s risk assessment methodology, could be leveraged for rail 

and other transportation modes, such as aviation. Until the overall risk to 

the entire transportation sector is identified, TSA will not be able to fully 

benefit from the outcome of risk management analysis—including 

determining where and how to target the nation’s limited resources to 

achieve the greatest security gains. 

Once risk assessments for the passenger rail industry have been 

completed, it will be critical to be able to compare assessment results 

across all transportation modes as well as other critical sectors and make 

informed, risk-based investment trade-offs. The framework that DHS is 

developing to help ensure that risks to all sectors can be analyzed and 

compared in a consistent way needs to be completed and shared with TSA 

and other sector-specific agencies. The delay in completing the element of 

the framework that defines concepts, terminology, and metrics for 

assessing risk limits DHS’s ability to compare risk across sectors as sectorspecific agencies are concurrently conducting risk assessment activities 

without this guidance. Until this framework is complete, it will not be 

possible for information from different sectors to be reconciled to allow 

for a meaningful comparison of risk—a goal outlined in DHS’s interim 

NIPP. 

Apart from its efforts to formally identify risks, TSA has taken steps to 

enhance the security of the overall passenger rail system. The issuance of 

security directives in the wake of the Madrid bombings was a wellintentioned effort to take swift action in response to a current threat. 

However, because these directives were issued under emergency 

circumstances, with limited input and review by rail industry and federal 

stakeholders—and no public comment period—they may not provide the 

industry with baseline security standards based on industry best practices. 
Page 70 GAO-05-851 Passenger Rail Security 

Nor is it clear how these directives are to be measured and enforced. 

Consequently, neither the federal government nor rail operators can be 

sure they are requiring and implementing security practices proven to help 

prevent or mitigate disasters. Collaborating with rail industry stakeholders 

to develop security standards is an important starting point for 

strengthening the security of passenger rail systems. DHS and DOT have 

taken steps in this direction through the interdepartmental MOU in place 

and related agreements now being developed to define roles and 

responsibilities and resources for mass transit, rail, and other matters. 

These agreements, once completed and communicated to the rail industry, 

will help ensure that federal activities to secure rail systems, including the 

development of standards, are coordinated, and that stakeholders are 

involved in their development and implementation to the extent possible. 

Otherwise, security efforts could be duplicative, thus dispersing finite 

resources, rather than focusing them based on risk, or fail to achieve the 

intended ends. Given the importance of clearly defining DHS’s and DOT’s 

roles and responsibilities for rail security matters, time frames could be 

established to hold DHS and DOT accountable for completing the MOU 

agreements. 

While foreign passenger rail operators face similar challenges to securing 

their systems and have generally implemented similar security practices as 

U.S. rail operators, there are some practices that are utilized abroad that 

U.S. rail operators or the federal government have not studied in terms of 

the feasibility, costs, and benefits. For example, an information 

clearinghouse for new passenger rail technologies that are available and 

have been tested might allow rail operators to efficiently implement 

technologies that had already received approval. In addition, while FTA 

plans to require rail operators to consider its security infrastructure design 

guidelines when renovating or constructing rail systems or facilities, 

opportunities may still exist to further research and evaluate ways of 

integrating security into design, as some foreign rail operators have done. 

Another rail security practice—covert testing of rail security procedures—

is being used in two foreign rail systems we visited and is considered by 

them as an effective means of keeping rail employees alert to their 

surroundings and potential security threats. And finally, random searches 

of passengers and baggage are being used by two foreign rail operators 

and this practice has recently been adopted by four domestic rail 

operators in the wake of the London attacks. 

Introducing these security practices into the United States may involve 

cultural, financial, and political challenges, owing to differences between 

the United States and foreign nations. Nonetheless, as part of the overall 
Page 71 GAO-05-851 Passenger Rail Security 

risk management approach, there may be compelling reasons for 

exploring the feasibility, costs, and benefits of implementing any of these 

practices in the United States. Doing so could enable the United States to 

leverage the experiences and knowledge of foreign passenger rail 

operators and help identify additional innovative measures to secure rail 

systems against terrorist attack in this country. 

In order for the Department of Homeland Security to have the information 

needed to fully evaluate, compare, and prioritize risk mitigation activities 

across sectors, we recommend that the Secretary of the Department of 

Homeland Security take the following action: 

• Establish a timeline for completing the department’s framework for 

analyzing sector risks and ensure that the risk assessment 

methodologies used by sector-specific agencies are consistent with this 

framework. 

In order for the Transportation Security Administration to have the 

information needed to more fully evaluate, select, and implement risk 

mitigation activities, and complete its transportation sector-specific plan 

and other strategic risk based plans, we recommend that the Secretary of 

the Department of Homeland Security direct the Assistant Secretary of the 

Transportation Security Administration to take the following two actions: 

• Establish a plan for completing its methodology for conducting risk 

assessments that includes timelines and addresses how it will work 

with passenger rail stakeholders and leverage existing federal expertise 

in Department of Homeland Security components, including the Office 

for Domestic Preparedness, as well as the Department of 

Transportation modal administrations, including the Federal Railroad 

Administration and the Federal Transit Administration. 

• Evaluate whether the risk assessment methodology used by the Office 

for Domestic Preparedness should be leveraged to facilitate the 

completion of risk assessments for rail and other transportation modes. 

To ensure that future rail security directives are enforceable, transparent, 

and feasible, we recommend that the Secretary of the Department of 

Homeland Security direct the Assistant Secretary of the Transportation 

Security Administration, in collaboration with the Department of 

Transportation and the passenger rail industry, to take the following two 

actions: 

Recommendations for 

Executive Action 
Page 72 GAO-05-851 Passenger Rail Security 

• Develop security standards that reflect industry best practices and can 

be measured, monitored, and enforced by Transportation Security 

Administration rail inspectors and, if appropriate, by rail asset owners. 

This could be accomplished by using the rule-making process, with 

notice in the Federal Register and an opportunity for interested 

stakeholders to comment, to promulgate long-term regulations that 

incorporate these standards. 

• Set timelines for completing the memorandum of understanding modal 

agreements for rail, mass transit, and research and development, which 

both the Department of Homeland Security and the Department of 

Transportation have agreed to pursue. 

To help strengthen the security of passenger rail systems in the United 

States and potentially leverage the knowledge and practices employed by 

foreign rail operators, we recommend that the Secretary of the 

Department of Homeland Security, in collaboration with the Department 

of Transportation and the passenger rail industry, take the following two 

actions: 

• Evaluate the feasibility of establishing and maintaining an information 

clearinghouse on existing and emergency security technologies and 

security best practices used in the passenger rail industry both in the 

United States and abroad. 

• Evaluate the potential benefits and applicability—as risk analyses 

warrant and as opportunities permit—of implementing covert testing 

processes to evaluate the effectiveness of rail system security 

personnel; implementing practices used by foreign rail operators that 

integrate security into infrastructure design; and implementing random 

searches or screening of passengers and their baggage, pending the 

results of an ongoing joint federal and industry review of the impact of 

random screening on passenger rail operators. 

We provided DHS, DOT, and Amtrak a draft of this report for review and 

comment. DOT and Amtrak generally agreed with our findings and 

recommendations and provided technical comments, which we 

incorporated where appropriate. 

DHS generally concurred with the report’s recommendations and provided 

detailed comments on various sections of the report. Its comments are 

contained in appendix IV. We summarize their comments and provide our 

response below. 

Agency Comments 

and Our Evaluation 
Page 73 GAO-05-851 Passenger Rail Security 

In commenting on the report, DHS stated that it is working through the 

Office of State and Local Government Coordination Preparedness 

(referred to in this report as the Office for Domestic Preparedness, ODP), 

TSA, and FTA to maximize and leverage collective resources to better 

serve the mass transit and commuter rail industry. In addition, DHS 

indicated that it will share ODP’s risk management architecture with 

public and private sector entities and use risk management principles to 

better prioritize its funding decisions. DHS reported taking or is planning 

to take other actions to enhance the security of the U.S. passenger rail 

system, such as initiating a canine explosives detection program, gathering 

and centralizing information on mass transit security to aid in decision 

making, and partnering with FRA inspectors to review rail security 

measures in operation since the July 2005 London rail bombings. We are 

encouraged by DHS’s efforts to work towards a common risk-based 

architecture for securing the passenger rail system and its related security 

initiatives. 

In more specific comments, DHS stated that our assertion that TSA missed 

the December 2004 deadline for completing the TSSP was misleading 

because the agency completed a draft by November 2004. DHS also stated 

that it plans to include industry associations, such as APTA and AAR, in its 

development of the TSSP and noted that it partnered with these 

associations and their members after the London bombings in July 2005. 

We modified the report to reflect the fact that a draft TSSP was completed 

by this date. However, the plan was not produced by December 2004, as 

required by HSPD-7, and therefore was not available for use by the rail 

operators and stakeholders. 

DHS also noted that while TSA’s methodology for conducting criticality 

assessments relies on open source information and therefore does not 

require direct contact with industry stakeholders, the agency nevertheless 

involved federal stakeholders and rail operators in conducting the 

assessments. We recognize that TSA’s process for conducting criticality 

assessments relies on open source information, and TSA reported to us 

that it had some contact with stakeholders. However, DHS’s interim NIPP 

states that the department and sector-specific agencies would work with 

the industry to determine the most effective means of collecting and 

analyzing information on critical assets. TSA was not able to provide us 

with evidence showing that it had solicited and evaluated input from 

industry stakeholders on its criticality assessment methodology. In 

addition, the criticality assessment case files we reviewed contained no 

evidence of coordination with stakeholders during the assessment 

process. Furthermore, industry associations we interviewed told us that 
Page 74 GAO-05-851 Passenger Rail Security 

TSA did not solicit their input on the agency’s criticality assessment 

methodology or ask them to identify specific critical assets. Moreover, of 

the 32 rail operators we contacted about TSA’s criticality assessment 

process, 22 operators responded; of those who responded, all stated that 

TSA did not involve them in conducting critical assessments of their 

systems. 

DHS also stated that while stakeholders were not given an opportunity to 

comment on the final draft of the measures contained in the security 

directives, various stakeholders, including Amtrak, did comment on each 

of the measures required by the directive. Our report acknowledges that 

associations and Amtrak were given an opportunity to comment on the 

draft directives. However, the draft directives initially provided to industry 

stakeholders did not include all of the measures required by the final 

directives. For example, the draft directives provided to APTA and AAR 

did not include the requirement that engineer cab or compartments be 

kept locked. Moreover, although TSA stated that it would continue to 

collaborate with industry stakeholders on the development of the 

directives, DHS and TSA determined that the prevailing threat 

environment necessitated issuing the directives without additional 

consultation. According to TSA, the emergency circumstances under 

which the directives were issued allowed for only limited input and review 

by federal and rail industry stakeholders. However, we believe that using 

the federal rule-making process as a means of establishing permanent 

standards would make the process more transparent and could help TSA 

in developing standards that are most appropriate for the industry and 

which can be measured, monitored, and enforced. Since stakeholders will 

play a critical role in administering, implementing, and/or enforcing TSA 

standards, their involvement in the development of standards is important 

to the success of these initiatives. 

DHS stated that our report criticized TSA’s efforts to develop the 

directives based upon consultation with industry and a review of best 

security practices. Specifically, DHS said that TSA went beyond FTA’s and 

APTA’s written documents (i.e., FTA’s list of the top 20 actions FTA rail 

operators can take to strengthen security, FTA-recommended protective 

measures and activities for transit agencies that may be followed based on 

current threat levels, and an APTA member survey) and considered other 

effective security measures, such as locking engineer cab and 

compartment doors (a measure suggested by WMATA, according to DHS), 

which the agency said were being implemented by various operators. 

While we agree that collaborating with other federal agencies and industry 

stakeholders to develop security standards based upon best practices is a 
Page 75 GAO-05-851 Passenger Rail Security 

critical step in enhancing the security of U.S. passenger rail systems and 

are making a recommendation to this effect, we continue to question the 

extent to which TSA followed this approach in developing the directives 

and the criteria TSA used to determine what constituted industry best 

practices. For example, regarding the requirement to lock train operator 

cabs or compartments, it is unclear whether this requirement is an 

industry best practice. The source material TSA provided to us, which the 

agency said it consulted in developing the directives, does not indicate 

that locking engineer or train operator cab or compartment doors is a best 

practice, or an effective one, in use by WMATA or other operators. 

Furthermore, TSA did not seek input from other stakeholders to determine 

whether they viewed this as a best practice. For example, the draft 

directives provided to AAR and APTA for comment did not include this 

measure. In addition, documentation shows that TSA called one commuter 

rail operator prior to issuing the directives to discuss this proposed 

measure, and the operator raised a concern about the safety of the locked 

door requirement. All of the rail operators and association representatives 

we interviewed raised concerns either about the extent of TSA’s 

coordination with the industry in developing the directives or the 

feasibility of specific directives. 

Regarding our assertion that the locked door measure may conflict with an 

FRA safety requirement, DHS responded that, according to FRA, the 

measure applied only to two types of passenger rail cars. However, FRA’s 

director of the office of safety assurance and compliance and its director 

of security disagreed with this assertion and said that this safety concern 

would apply to all commuter or intercity rail equipment that is equipped 

with locking mechanisms. While the locked door requirement may be well 

intentioned, it may have the unintended consequence of increasing safety 

risks to railroad employees and passengers. According to FRA, a locked 

door pursuant to the directive would not allow the locomotive engineer to 

quickly exit the cab when faced with an impending highway rail grade 

crossing collision or other accident. In some cases, the door providing 

access to the locomotive’s cab also serves as one of only two primary 

paths for emergency exit by passengers and is marked as an emergency 

exit. According to FRA, if these doors are locked pursuant to the 

directives, they may not be usable in an emergency, and passenger 

evacuation time could be substantially increased. 

In the report, we stated that APTA, AAR, and other stakeholders did not 

believe they had been sufficiently consulted throughout the development 

of the security directives, including the measure advocating installation of 

bomb-resistant trash cans. As a result, stakeholders did not believe the 
Page 76 GAO-05-851 Passenger Rail Security 

directives reflected a complete understanding of the passenger rail 

environment or incorporate industry best practices. On this issue, DHS 

noted in its comments that the directives did not require the installation of 

bomb-resistant trash cans, but rather encouraged the removal of 

traditional trash cans. While we agree that the directive emphasizes the 

desirability, under certain circumstances and to the extent that resources 

allow, of removing traditional trash cans, we believe the directive also 

directly advocates the use of bomb-resistant trash cans since it directs 

operators to “install bomb resistant receptacles to the extent resources 

allow.” While industry stakeholders had an opportunity to comment on the 

trash can removal issue, they were not given an opportunity to consider 

the feasibility or efficacy of installing bomb-resistant trash cans because 

this measure was not included in the draft directives provided to industry 

stakeholders for comment. 

With regard to the directive requiring Amtrak and the Alaska Railroad 

Corporation to perform ID checks on all passengers, DHS stated that our 

report raised an issue regarding the efficacy of performing ID checks 

without vetting passenger names against a watch list or other database. 

DHS stated that ID checks were a baseline measure that could be 

enhanced in response to heightened or specific threats by vetting names 

against a watch list. DHS also explained that Amtrak was already 

performing some ID checks, and that the measure was designed to 

incorporate the ID check into current business practice of operators such 

as Amtrak, which could request passengers to have their IDs available 

when tickets are checked. We do not disagree with DHS’s assertion that 

additional measures could be added in heightened threat environments. 

Our discussion of this measure focuses on Amtrak’s concern about the 

feasibility of the requirement in light of the potential impacts on Amtrak’s 

operations and revenue. DHS’s explanation of the intent of this measure 

suggests that it was to encourage the use of ID checks and that operators 

“could request passengers to have their ID available.” However, as written, 

the directive requires rather than encourages IDs to be checked at the 

initial point where tickets are checked. 

In commenting on our report’s assertion that it is unclear which entities 

are responsible for implementing the security directives, DHS 

acknowledged that individual stations and terminals may be owned and/or 

operated by multiple federal, state, and private entities but emphasized 

that the prevailing threat environment at the time the security directives 

were issued necessitated looking to the passenger rail operator to 

coordinate the implementation of the required measures. We agree that 

rail operators must play an important role in the implementation of 
Page 77 GAO-05-851 Passenger Rail Security 

measures in stations that they may not own. However, the directives, as 

written, do not make it clear which entities (rail operators and station and 

terminal owners) are responsible for implementing the requirements and, 

in the 15 months since the directives were issued, TSA has not yet clarified 

these responsibilities. The industry associations and rail operators still 

believe that implementation responsibilities remain unclear. Given that 

TSA considers these directives to be mandatory and has hired inspectors 

to ensure compliance with directives, we believe that it is important to 

clearly articulate which entities are to be held accountable for 

implementing the measures required by the directives. 

Finally, DHS commented that it has approved and distributed standard 

operating procedures to its rail inspectors since we completed our field 

work, and that DOT had been actively engaged in reviewing and 

commenting on these procedures. We are encouraged that TSA is moving 

forward with efforts to develop processes for ensuring compliance with 

security standards. However, as stated above, we are concerned that TSA 

may not be effectively able to ensure or enforce compliance until the 

standards have been more fully developed in consultation with 

stakeholders. TSA was not able to provide us with evidence to show it had 

collaborated with DOT in developing and approving these procedures. In 

addition, DOT officials raised questions regarding the approved status of 

these procedures. For example, FTA’s director of safety and security told 

us he had not seen either a draft or a final version of these procedures. 

Furthermore, FRA’s director of the office of safety assurance and 

compliance did not believe the procedures had been approved. According 

this official, TSA provided a draft of the standard operating procedures on 

August 10, 2005, and comments are due back on September 14, 2005. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the date of this letter. We will then send copies of this report to the 

Secretary of Homeland Security, the Secretary of Transportation, the 

Assistant Secretary of the Transportation Security Administration, the 

Administrator of the Federal Railroad Administration, the Administrator of 

the Federal Transit Administration, the President and Chief Executive 

Officer of Amtrak, the Director of the Office of State and Local 

Government Coordination and Preparedness, and interested congressional 

committees. We will make copies available to others upon request. In 

addition, this report will be available at no charge on our Web site at 

http://www.gao.gov. 
Page 78 GAO-05-851 Passenger Rail Security 

If you or your staff have any questions about this report, please contact 

Ms. Cathleen Berrick on (202) 512-8777 or Ms. JayEtta Hecker on 

(202) 512-2834. Contact points for our offices of 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 V. 

Cathleen A. Berrick, Director 

Homeland Security and Justice Issues 

JayEtta Hecker, Director 

Physical Infrastructure Issues 
Appendix I: Objectives, Scope, and 

Methodology 

Page 79 GAO-05-851 Passenger Rail Security 

To address our first objective, to identify the actions taken by the 

Department of Homeland Security (DHS) agencies to assess risks posed by 

terrorism in the context of prevailing risk management principles, we 

interviewed officials from DHS, the Department of Transportation (DOT), 

and Amtrak. Specifically, within DHS, we interviewed officials from the 

Transportation Security Administration’s (TSA) Office of Intermodal 

Security Programs (formerly the Office of Maritime and Land Security), 

Office of Transportation Security Policy, Transportation Security 

Intelligence Service, and the Chief Operating Officer. We also interviewed 

officials from the Office of State and Local Government Coordination and 

Preparedness (SLGCP), the Information Analysis and Infrastructure 

Protection Directorate, the Border and Transportation Security 

Directorate, and the Office of Inspector General. Within DOT, we 

interviewed officials from the Office of Intelligence, Inspector General, 

Deputy Secretary of Transportation, the Federal Transit Administrations 

(FTA) Office of Safety and Security, and the Federal Railroad 

Administration (FRA) Office of Security and Office of Safety Assurance 

and Compliance. We also interviewed Amtrak’s Chief of Police and 

Security, Vice President of Corporate Security, Inspector General, and 

Amtrak security officials in locations throughout the United States. In 

addition, we reviewed federal agency plans such as the DHS Interim 

National Infrastructure Protection Plan, and obtained and reviewed 

various risk-related assessments conducted by federal agencies, including 

the vulnerability assessments of rail transit systems conducted by FTA, 

TSA threat assessments of mass transit and rail and criticality assessments 

of passenger rail assets, and a passenger rail risk assessment tool kit 

developed by SLGCP. Further, we conducted a site visit to and interview 

with officials from the Port Authority of New York and New Jersey to 

discuss the results of an SLGCP risk assessment conducted at that 

location. 

To address our second objective to determine the actions that federal 

agencies have taken to enhance the security of the U.S. passenger rail 

system, we interviewed officials from FTA’s Office of Safety and Security, 

DOT’s Office of the Secretary, FRA’s Office of Security, Office of Research 

and Development, and Office of Safety Assurance and Compliance, and 

TSA’s Office of Intermodal Security Programs, Office of Research and 

Development, and the Chief Operating Officer. We did not evaluate the 

effectiveness of any of these federal passenger rail security efforts. We 

also reviewed federal guidance, such as Homeland Security Presidential 

Directive-7, FTA’s Top 20 Security Program Action Items for Transit 

Agencies, and TSA’s security directives for passenger rail operators; 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 80 GAO-05-851 Passenger Rail Security 

inspected all phases of TSA’s TRIP program; and reviewed the 

memorandum of understanding between DHS and DOT. 

To determine the security practices that domestic and selected foreign 

passenger rail operators have implemented to mitigate risks and enhance 

security, and any differences in these practices, we interviewed officials 

from TSA’s Office of Intermodal Security Programs, FRA’s Office of 

International Policy, and FTA’s Office of Safety and Security to discuss 

domestic and foreign passenger rail security measures. We also conducted 

site visits to or teleconferences with 32 heavy and commuter rail operators 

in the United States—representing over 95 percent of the nation’s 

passenger rail ridership in 2003—and Amtrak. Table 4 lists the domestic 

passenger rail operators that we visited or interviewed during our review. 

Table 4: Domestic Passenger Rail Agencies We Visited or Interviewed for the 

Purposes of this Review 

Passenger rail agency Urban area served 

Altamont Commuter Express (ACE) Stockton and San Jose, California 

Alaska Railroad Corporation Anchorage and Fairbanks, Alaska 

Bay Area Rapid Transit (BART) San Francisco–Oakland, California 

CALTRAIN San Francisco and San Jose, 

California 

San Diego Transit Corp. (Coaster) San Diego, California 

Dallas Area Rapid Transit / Trinity Railway 

Express (DART) 

Dallas, Texas 

Greater Cleveland Regional Transportation 

Authority (GCRTA) 

Cleveland, Ohio 

Los Angeles County Metropolitan Transportation 

Authority (LACMTA) 

Los Angeles, California 

Metropolitan Atlanta Rapid Transit Authority 

(MARTA) 

Atlanta, Georgia 

Maryland Transit Administration (MTA) Greater Washington, D.C., and 

Maryland 

Massachusetts Bay Transportation Authority 

(MBTA) 

Boston, Massachusetts 

METRA Commuter Rail Chicago, Illinois 

Southern California Regional Rail Authority 

(Metrolink) 

Greater Los Angeles, California 

Long Island Railroad (LIRR) New York, New York 

Metro North Railroad (MNR) New York, New York 

New York City Transit (NYCT) New York, New York 
Appendix I: Objectives, Scope, and 

Methodology 

Page 81 GAO-05-851 Passenger Rail Security 

Passenger rail agency Urban area served 

Staten Island Railway (SIR) New York, New York 

San Francisco Municipal Railway (MUNI) San Francisco, California 

Northern Indiana Commuter District Chicago, Illinois–-Northern Indiana 

Delaware River Port Authority (PATCO) New Jersey and Philadelphia, 

Pennsylvania 

Port Authority Trans Hudson (PATH) New York, New York–-New Jersey 

San Diego Trolley San Diego, California 

Southeastern Pennsylvania Transportation 

Authority (SEPTA) 

Philadelphia, Pennsylvania 

South Florida Regional Transportation Authority 

(SFRTA) 

Miami, Florida 

Connecticut Department of Transportation (Shore 

Line East) 

New Haven, Connecticut 

Sound Transit (Sounder) Seattle, Washington 

TRIMET Portland, Oregon 

Virginia Railway Express (VRE) Northern Virginia, Greater 

Washington, D.C. 

Washington Metropolitan Area Transit Authority 

(WMATA) 

Washington, D.C. 

New Jersey Transit (NJT) Newark, New Jersey– New York, 

New York 

Miami Dade Transit Miami, Florida 

Chicago Transit Authority (CTA) Chicago, Illinois 

Source: National Transit Database. 

We also conducted site visits to 13 passenger rail operators in seven 

European and Asian countries, including France, the United Kingdom, 

Belgium, Spain, Japan, Singapore, and Hong Kong. In all of these 

countries, we met with passenger rail security officials and toured 

facilities to identify security practices being used on their systems as well 

as differences from U.S. passenger rail systems. We also met with 

government officials in select countries. See table 5 for a list of foreign 

passenger rail operators and government agencies we met with abroad. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 82 GAO-05-851 Passenger Rail Security 

Table 5: Foreign Passenger Rail and Government Agencies We Visited or 

Interviewed for the Purposes of This Review 

Passenger rail agency or government agency Area served 

Paris Metro Paris, France 

French National Railway France 

National Department for Transport—Security Directorate United Kingdom 

London Underground London, United Kingdom 

Network Rail United Kingdom 

British Transport Police United Kingdom 

Channel Tunnel Rail Link United Kingdom/France 

Transport for London London, United Kingdom 

Belgian National Railway Belgium 

Madrid Metro Madrid, Spain 

RENFE (Spanish National Railway) Spain 

European Commission—Directorate for Energy and 

Transport 

European Union 

JR Central Japan 

Tokyo Metro Tokyo, Japan 

Ministry of Land, Infrastructure, and Transport Japan 

SBS Transit Corporation Singapore 

Singapore Mass Rapid Transit Singapore 

Land Transport Authority Singapore 

Hong Kong Mass Transit Railway Hong Kong 

Special Administrative Regional Government Hong Kong 

Source: GAO. 

We also attended an international rail security conference sponsored by 

the International Union of Railways in partnership with the International 

Union on Public Transport. While attending this conference, we 

interviewed officials from the German National Railway. Because we 

selected a nonprobability sample of both foreign and domestic passenger 

rail operators, the information we obtained from these interviews and 

visits cannot be generalized to all foreign or domestic rail operators. 

Finally, we discussed those foreign security practices identified with 

several domestic passenger rail operators and a collection of surface 

transportation security experts from the Mineta Transportation Institute 

and RAND Corporation to determine the potential to use some of these 

practices in the United States. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 83 GAO-05-851 Passenger Rail Security 

We performed our work from May 2004 through July 2005 in accordance 

with generally accepted government auditing standards. 
Appendix II: Elements of a Typical Homeland 

Security Risk Assessment 

Page 84 GAO-05-851 Passenger Rail Security 

A threat assessment: Threat is defined as a potential intent to cause harm or damage to an asset (e.g., natural environment, people, 

man-made infrastructures, and activities and operations). Threat assessments consist of the identification of adverse events that can 

potentially affect an entity. Threats might be present at the global, national, or local level, and their sources include terrorists and 

criminal enterprises. Specific threat information may indicate vulnerabilities that are subject to attack, or following the completion of a 

risk management process may, for instance, indicate that resources should be temporarily deployed to protect cargo in a particular 

region of the country or a specific airport. Even if updated often, a threat assessment might not adequately capture some emerging 

threats. 

A vulnerability assessment: Vulnerability is defined as the inherent state (either physical, technical, or operational) of an asset that 

can be exploited by an adversary to cause harm or damage. Vulnerability assessments identify these inherent states and the extent of 

their susceptibility to exploitation, relative to the existence of any countermeasures. A vulnerability assessment is generally conducted 

by a team of experts skilled in such areas as engineering, intelligence, security, information systems, finance, and other disciplines. 

A criticality assessment: Criticality is defined as an asset’s relative importance, given that an event occurs. Criticality or similar 

consequence assessments identify and evaluate an entity’s assets based on a variety of factors, including the importance of its

mission or function, the extent to which people are at risk, or the significance of a structure or system in terms of, for example, national 

security, economic activity, or public safety. Criticality or consequence assessments are important because they provide, in 

combination with threat and vulnerability assessments, information for later stages of the risk management process. 

Risk assessment: A complete risk assessment is a qualitative and/or quantitative determination of the likelihood (probability) of 

occurrence of an adverse event and the severity, or impact, of its consequences. Risk assessment can involve designating risk as, for 

example, low, medium, or high (other scales, such as numeric, can also be used), and often integrates threat, criticality, and 

vulnerability assessments. Such analyses can help inform which actions are best suited to mitigate assessed risk, in conjunction with 

the risk-based evaluation of alternatives while considering cost and other factors. 

Source: GAO. 

Appendix II: Elements of a Typical Homeland 

Security Risk Assessment 
Appendix III: FTA and ODP Passenger Rail 

Risk Assessments Conducted or In Progress 

Page 85 GAO-05-851 Passenger Rail Security 

1. Bi-State Development Agency 

2. Chicago Metra Commuter Rail 

3. Chicago Transit Authority 

4. Dallas Areas Rapid Transit--Trinity Railway Express 

5. Denver Regional Transportation District 

6. Detroit Department of Transportation 

7. Greater Cleveland Regional Transit Authority 

8. King County Department of Transportation Metro District 

9. Los Angeles County Metropolitan Transportation Authority 

10. Maryland Transit Administration 

11. Massachusetts Bay Transportation Authority 

12. Metropolitan Transit Authority of Harris County 

13. Metropolitan Atlanta Rapid Transit Authority 

14. Metropolitan Transportation Authority--Long Island Railroad 

15. Metropolitan Transportation Authority--Metro North Railroad 

16. Metropolitan Transportation Authority--New York City Transit 

17. Miami Dade Transit 

18. Minneapolis Metro Transit 

19. New Jersey Transit 

20. New Orleans Regional Transit Authority 

21. Niagara Frontier Transportation Authority 

22. North County Transit District--Coaster 

23. Port Authority Trans-Hudson--PATH 

Appendix III: FTA and ODP Passenger Rail 

Risk Assessments Conducted or In Progress 

FTA Risk 

Assessments 

Conducted 
Appendix III: FTA and ODP Passenger Rail 

Risk Assessments Conducted or In Progress 

Page 86 GAO-05-851 Passenger Rail Security 

24. Port Authority of Allegheny County Pennsylvania 

25. Puerto Rico Highway and Transportation Authority 

26. Sacramento Regional Transit District 

27. San Diego Trolley 

28. Santa Clara Valley Transit Authority 

29. San Francisco Municipal Railway–MUNI 

30. San Francisco Bay Area Rapid Transit 

31. Southeastern Pennsylvania Transportation Authority 

32. Tri-County Commuter Rail Authority 

33. Tri-County Metropolitan Transportation District of Oregon--TriMet 

34. Utah Transit Authority 

35. Virginia Railway Express 

36. Washington Metropolitan Area Transit Authority 

Completed 

1. Port Authority of New York and New Jersey 

2. New Jersey Transit 

3. Massachusetts Bay Transportation Authority 

4. Washington Metropolitan Area Transit Authority 

5. Southeastern Pennsylvania Transportation Authority 

6. Tri-County Metropolitan Transportation District of Oregon--TriMet 

7. Delaware River Port Authority-–PATCO 

ODP Risk 

Assessments 
Appendix III: FTA and ODP Passenger Rail 

Risk Assessments Conducted or In Progress 

Page 87 GAO-05-851 Passenger Rail Security 

In Progress 

1. Bay Area Rapid Transit 

2. San Mateo County Transit District 

3. San Francisco Municipal Railway 

4. Metropolitan Transit Authority of Harris County, Texas 

5. Chicago Transit Authority 

6. Miami-Dade Transit 

7. Metropolitan Atlanta Rapid Transit Authority 

8. AMTRAK Northeast Corridor 

9. Dallas Area Rapid Transit / Trinity Railway Express 

10. South Florida Regional Transportation Authority 

11. Maryland Transit Administration 

12. Detroit Transportation Corporation 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 88 GAO-05-851 Passenger Rail Security 

Appendix IV: Comments from the 

Department of Homeland Security 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 89 GAO-05-851 Passenger Rail Security 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 90 GAO-05-851 Passenger Rail Security 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 91 GAO-05-851 Passenger Rail Security 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 92 GAO-05-851 Passenger Rail Security 
Appendix IV: Comments from the Department of Homeland 

Security 

Page 93 GAO-05-851 Passenger Rail Security 
Appendix V: GAO Contacts and Staff 

Acknowledgments 

Page 94 GAO-05-851 Passenger Rail Security 

Cathleen A. Berrick, (202) 512-8777 

JayEtta Z. Hecker, (202) 512-2834 

In addition to those named above, Seto Bagdoyan, Amy Bernstein, Leo 

Barbour, Christopher Currie, Nikki Clowers, Scott Farrow, David Hooper, 

Andrew Huddleston, Kirk Kiester, Octavia Parks, Jack Schulze, and Ray 

Sendejas made key contributions to this report. 

Appendix V: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Acknowledgments 

(440319) 
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