Maritime Security: Progress Made in Implementing Maritime Transportation Security Act, but Concerns Remain
Published: 2003-09-09T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: After the events of September 11, 2001, concerns were raised over the security of U.S. ports and waterways. In response to the concerns over port security, Congress passed the Maritime Transportation Security Act in November 2002. The act created a broad range of programs to improve the security conditions at the ports and along American waterways, such as identifying and tracking vessels, assessing security preparedness, and limiting access to sensitive areas. A number of executive agencies were delegated responsibilities to implement these programs and other provisions of the act. The Senate Committee on Commerce, Science, and Transportation asked GAO to conduct a review of the status of the agencies' efforts to implement the security requirements of the act. This testimony reflects GAO's preliminary findings; much of GAO's work in the area is still under way.
section_title: What GAO Found
paragraphs: Agencies responsible for implementing the security provisions of the Maritime Transportation Security Act have made progress in meeting their requirements. Thus far, GAO has obtained information about 43 of 46 specific action areas, and efforts are under way in 42 of them. For example, the Coast Guard, the Department of Homeland Security agency with lead responsibility for most of the assignments, has published six interim rules covering responsibilities ranging from security of port facilities to vessel identification systems. Two other agencies within the new department--the Transportation Security Administration and the Bureau of Customs and Border Protection--have actions under way in such areas as establishing an identification system for millions of port workers and setting information requirements for cargo. The Maritime Administration, a Department of Transportation agency, has already completed or is well into implementing such responsibilities as developing training for security personnel. While much has been accomplished, GAO's review found five areas of concern. Three relate primarily to security issues: (1) only a limited number of ports covered by vessel identification system; (2) questions about the scope and quality of port security assessments; and (3) concerns related to approving security plans for foreign vessels. Two relate primarily to organizational and operational matters: (1) potential duplication of maritime intelligence efforts; and (2) inconsistency with Port Security Grant Program requirements.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the implementation of the  Maritime Transportation Security Act (MTSA) of 2002. This sweeping  piece of legislation was enacted just 10 months ago, but it has already  produced major changes in the nation’s approach to maritime security. At  your request, we have begun reviewing the implementation of security  provisions of Title I of MTSA. I am here today to tell you about our  preliminary findings and what agencies within the Department of  Homeland Security (DHS) and other federal departments are doing to  fulfill their many responsibilities under the act. I also want to advise you  about specific matters that agency officials or others have brought to our  attention thus far and other issues that may require further oversight. We  will be continuing our efforts to more fully evaluate a number of the issues  I will address today, and we plan to issue a report when this work is  complete.
Our information is based on interviews with agency officials charged with  implementing MTSA’s provisions, as well as with officials and  stakeholders from several ports.
Our preliminary findings are as follows:    Progress has been made in implementing MTSA. MTSA called for actions  in 46 key areas we identified, such as creating a maritime intelligence  security system, assessing security conditions in port areas, creating and  implementing a vessel tracking system, and creating identification systems  for port workers and seafarers. So far, we have obtained information for  43 of these areas, and agency officials indicate that actions are complete  or under way in 42 of them. For example, the Coast Guard, which had lead  responsibility for most of the assignments, has six interim rules in place  covering major areas of responsibility, such as security in and around the  ports, aboard individual vessels, and at individual facilities. All six Coast  Guard Maritime Safety and Security Teams included in the fiscal year 2003  budget are expected to be operational by the end of September 2003; these  teams are designed to provide increased protection against terrorism in  and around the nation’s harbors. Also, the Transportation Security  Administration (TSA) is testing new identification cards for controlling  access to secure transportation facilities, including vessels and port  facilities. The agency plans to start issuing the cards to millions of port  workers in 2004. The Bureau of Customs and Border Protection (BCBP)  and the Maritime Administration (MARAD), the two other agencies with  the largest set of responsibilities under MTSA, also are making progress on  major projects. Agency officials told us that cooperation and coordination  on MTSA implementation has been strong. Further work will be needed to  determine the extent to which early progress will be sustained over the  course of implementation efforts and whether the spirit of cooperation  translates into efforts at the port level.
These findings not withstanding and bearing in mind our caveats as to the  preliminary nature of these results, five areas have surfaced as potentially  requiring further attention. (See table 1.)
Three of these areas, as shown in table 1, primarily have security  implications. For example, MTSA called for development of an automatic  identification system. The Coast Guard developed a system that would  allow port officials and personnel on other vessels to determine the  identity and position of vessels entering or operating within the port.  While the Coast Guard is implementing this system, more than half of the  25 busiest U.S. ports will not have it for the foreseeable future, because it  requires extensive shore-based equipment and infrastructure that many  ports do not have. The two remaining areas relate primarily to operational  or efficiency matters, such as duplication of effort in collecting  intelligence information. We are continuing to examine all five areas.
subsections: section_title: Background
paragraphs: MTSA was landmark legislation that mandated a quantum leap in security  preparedness for America’s maritime ports. Prior to the terrorist attacks of  September 11, 2001, federal attention at ports tended to focus on  navigation and safety issues, such as dredging channels and environmental  protection. While the terrorist attacks initially focused the nation’s  attention on the vulnerability of its aviation system, it did not take long for  attention to fall on the nation’s ports as well. Besides being gateways  through which dangerous materials could enter the country, ports  represent attractive targets for other reasons: they are often large and  sprawling, accessible by water and land, close to crowded metropolitan  centers, and interwoven with highways, roads, factories, and businesses.  Security is made more difficult by the many stakeholders, public and  private, involved in port operations. These stakeholders include local,  state, and federal agencies; multiple law enforcement jurisdictions;  transportation and trade companies; and factories and other businesses.
Passed in November 2002, MTSA imposed an ambitious schedule of  requirements on a number of federal agencies. MTSA called for a  comprehensive security framework—one that included planning,  personnel security, and careful monitoring of vessels and cargo. (See table  2 for examples of key MTSA activities.) MTSA tasked the Secretary of  DHS, and the Secretary in turn has tasked the Coast Guard, with lead  responsibility for the majority of its requirements. Timetables were often  daunting. For example, one of the Coast Guard’s responsibilities was to  develop six interim final rules implementing MTSA’s operational  provisions in sufficient time to receive public comment and to issue a final  rule by November 25, 2003.
Adding to the difficulty has been the need to implement MTSA against the  backdrop of the most extensive federal reorganization in over a half- century. Most of the agencies with MTSA responsibilities were reorganized  into the Department of Homeland Security in March 2003, less than 5  months after MTSA enactment. Among the 22 agencies in the new  department were some relatively new organizations, such as TSA. Other  more longstanding agencies, including the Coast Guard, U.S. Customs  Service, and Immigration and Naturalization Service, were transferred  from a variety of executive departments. This vast recombination of  organizational cultures introduced new chains of command and reporting  responsibilities. MTSA implementation also involved coordination with  other executive agencies, including the Departments of State,  Transportation, and Justice.
section_title: Progress Has Been Made in Implementing MTSA
paragraphs: Since the passage of MTSA in 2002 the responsible agencies—primarily the  Coast Guard, TSA, and BCBP in DHS, along with MARAD in the  Department of Transportation—have made strides in implementing the  act’s security provisions. MTSA called for actions in 46 key areas we  identified. Thus far, we have received information from the responsible  agencies on 43 of these areas. Of the 43 areas, work is done in 2 (issuing  interim rules and developing training for maritime security personnel), and  under way in 40 others. These agencies also reported that cooperation  and coordination has been extensive throughout the course of their  activities.
A major achievement has been the Coast Guard’s publication on July 1,  2003, of six interim rules on the provisions where it had lead  responsibility. The rules set requirements for many of the provisions  delegated to the Coast Guard under MTSA. The rules, which included  sections on national maritime security initiatives, area maritime security,  vessel security, facility security, outer continental shelf facility security,  and automatic identification systems, were published approximately 8  months after MTSA was enacted. Doing so kept the Coast Guard on  schedule for meeting MTSA’s requirement to receive public comment and  issue the final rules by the end of November 2003. The rules provided a  comprehensive description of industry-related maritime security  requirements and the cost-benefit assessments of the entire set of rules.  The Coast Guard plans to publish the final rules before November 25,  2003, after receiving and acting on comments to the interim rules.
Another Coast Guard accomplishment was the establishment of Maritime  Safety and Security Teams called for under MTSA. These teams, which can  be rapidly deployed where needed, are designed to provide antiterrorism  protection for strategic shipping, high-interest vessels, and critical  infrastructure. The Coast Guard has already deployed four teams—in  Seattle and Galveston and near Norfolk and Los Angeles. The Coast Guard  will deploy teams in New York City and near Jacksonville this year, and  six more teams have been requested in the president’s budget in 2004.  These are to be located in San Diego, Honolulu, Boston, San Francisco,  New Orleans, and Miami.
Other agencies in DHS have also made progress in their implementation of  MTSA provisions. Responding to MTSA’s requirement for the development  of biometric transportation security identification cards that would allow  only authorized persons access to secure areas of vessels or facilities, TSA  is currently testing several different technology credentialing systems on  sample cards. The agency will begin testing prototypes of the entire  security card process, including conducting background checks, collecting  biometric information on workers, verifying cardholders’ identities, and  issuing cards in early 2004. TSA plans to start issuing about 5 to 6 million  new cards per year in the middle of 2004. Developing all of the policies and  programs to make this system work is still under way and will continue to  pose challenges to continued progress. Another DHS agency, BCBP, was  delegated the responsibility for issuing regulations for electronic  transmission of cargo information to BCBP by October 1, 2003; BCBP  published its proposed rule on July 23, 2003. BCBP was waiting for  comments on the proposed rule, and BCBP officials told us that they  expect to publish the rule on time.
MARAD has also made progress in its requirements. Among the provisions  for which MARAD is responsible are developing standards and curricula  for the training of maritime security personnel. MARAD submitted a  Report to Congress, dated May 2003, containing the standards and  curriculum called for by MTSA in the form of model course frameworks  for seven categories of maritime security professionals. As an extension of  the MTSA project, MARAD also produced three model maritime security  courses for the International Maritime Organization (IMO). An IMO  validation team has reviewed drafts of these courses, which found little  need for change.
Agency officials told us that cooperation and coordination on MTSA  implementation has been strong. Coast Guard officials said that they had  developed channels of communication with other relevant agencies, and  they said these other agencies were supportive in implementing provisions  for which they did not have primary responsibility. In the work we have  conducted at ports since the September 11th attacks, we have noted an  increasing level of cooperation and coordination at the port level.  However, ensuring smooth coordination as the many aspects of MTSA  implementation continue is a considerable challenge. Additional work will  be needed to determine the extent to which this spirit of cooperation  continues to be translated into effective actions at the level where  programs must be implemented.
section_title: Issues Raised Include Both Security and Operational Concerns
paragraphs: While progress is being made, our preliminary work has identified five  areas that merit attention and further oversight. Three relate primarily to  security issues: (1) the limited number of ports that will be covered by the  vessel identification system, (2) questions about the scope and quality of  port security assessments, and (3) the Coast Guard’s plans not to  individually approve security plans for foreign vessels. The remaining two  relate primarily to operational and efficiency matters: (1) potential  duplication of maritime intelligence efforts and (2) inconsistency with Port  Security Grant Program requirements.
subsections: section_title: Vessel Identification System Will Cover a Limited Number of Ports
paragraphs: The main security-related issue involves the implementation of a vessel  identification system. MTSA called for the development of an automatic  identification system. Coast Guard implementation calls for a system that  would allow port officials and other vessels to determine the identity and  position of vessels entering or operating within the harbor area. Such a  system would provide an “early warning” of an unidentified vessel or a  vessel that was in a location where it should not be. To implement the  system effectively, however, requires considerable land-based equipment  and other infrastructure that is not currently available in many ports. As a  result, for the foreseeable future, the system will be available in less than  half of the 25 busiest U.S. ports.
The identification system, called the Automatic Identification System  (AIS), uses a device aboard a vessel to transmit a unique identifying signal  to a receiver located at the port and to other ships in the area. This  information gives port officials and other vessels nearly instantaneous  information about a vessel’s identity, position, speed, and course. MTSA  requires that vessels in certain categories install tracking equipment  between January 1, 2003, and December 31, 2004, with the specific date  dependent on the type of vessel and when it was built.
The only ports with the necessary infrastructure to use AIS are those that  have waterways controlled by Vessel Traffic Service (VTS) systems.  Similar to air traffic control systems, VTS uses radar, closed circuit  television, radiophones, and other technology to allow monitoring and  management of vessel traffic from a central shore-based location. The  Coast Guard currently plans to install AIS receiving equipment at the 10  locations with VTS systems. More than half of the 25 busiest ports, such  as Philadelphia, Baltimore, Miami, Charleston, Tampa, and Honolulu, do  not have VTS systems; hence, AIS will be inoperable at these locations for  the foreseeable future. When AIS will be operable at these other ports  depends heavily on how soon the Coast Guard can put an extensive  amount of shore-based infrastructure in place. For the present, the Coast  Guard is requiring AIS equipment only for (1) vessels on international  voyages and (2) vessels navigating waterways under VTS control. Some of  these international ships will be calling on ports that will not have AIS  equipment. In such cases, the transmitters aboard the vessels will be of no  use for the ports, because they will not have equipment to receive the  signals.
Cost is a major factor in the full implementation of AIS. Expanding  coverage will require substantial additional investment, both public and  private. The Coast Guard’s budget request for fiscal year 2004 includes $40  million for shore-based AIS equipment and related infrastructure—an  amount that covers only current VTS areas. According to a Coast Guard  official, wider-reaching national implementation of AIS would involve  installation and training costs ranging from $62 million to $120 million.  Also, the cost of installing AIS equipment aboard individual ships averages  about $10,000 per vessel, which is to be borne by the vessel owner or  operator. Some owners and operators, particularly of domestic vessels,  have complained about the cost of equipping their vessels.
section_title: Concerns about Port Security Assessments
paragraphs: Another security-related issue involves the Coast Guard’s efforts to  address MTSA’s security planning requirements through a series of  security assessments of individual ports. Security assessments are  intended to be in-depth examinations of security threats, vulnerabilities,  consequences, and conditions throughout a port, including not just  transportation facilities, but also factories and other installations that pose  potential security risks. The Coast Guard had begun these assessments  before MTSA was passed and decided to continue the process, changing it  as needed to meet MTSA planning requirements, which include developing  area security plans based on the evaluation of specific facilities  throughout the port. At the request of the Subcommittee on Coast Guard  and Maritime Transportation, House Committee on Transportation and  Infrastructure, we have been examining these assessments, which are  being conducted by an outside contractor. Our preliminary work has  surfaced several potential concerns, which we are still in the process of  reviewing.
One concern involves an apparent truncation of the review process for  ensuring that the assessment methodology will deliver what MTSA  requires. When MTSA took effect, the outside contractor already  completed the first 10 of 55 planned assessments. The Coast Guard  directed the contractor to modify the assessment methodology to take  MTSA’s planning requirements into account, and it decided that the next  two assessments would be a pilot test of the revised methodology. The  Coast Guard plans to use the pilot test to evaluate lessons learned, so that  additional modifications can be made before any further contracts are  signed.
Instead of waiting to see what changes might be needed as a result of the  pilot projects, however, the contractor has apparently started the scoping  phase for the next six port assessments. Scoping is a significant part of the  new methodology, and as such, it is a major determinant in the nature and  breadth of the issues to be addressed, as well as the assessment’s cost.  The contractor has also reportedly sought to negotiate and sign contracts  to review the next six ports. Since the pilot projects will not be completed  until at least October 2003, it seems premature to reach decisions about  the scope of the assessments and sign contracts for them. The revised  methodology needs to be reviewed so that any needed changes are  reflected in the next contract.
A second concern that has surfaced involves the scope and quality of the  assessments themselves. As part of our work, we have interviewed port  stakeholders to obtain their views on the process. At one port, where the  assessment has been completed and the report issued, stakeholders said  they had not been given an opportunity to comment on the report, which  contained factual errors and did not include an assessment of railroads  and the local power generating plant. At the other port, where the  assessment was still in process, local Coast Guard personnel and port  stakeholders noted that a survey instrument referred to the wrong port,  asked questions they regarded as not pertaining to security, and was  conducted in ways that raised concerns about credibility. Many of these  stakeholders saw little usefulness in the assessments, believing that they  added little to what the stakeholders had already learned from conducting  their own more extensive security reviews of individual facilities or  installations. They said the assessments focused on the same systems that  had already been reviewed and would have greater value if they were  focused on matters that had not already been thoroughly studied, such as  the potential for waterborne assault. Coast Guard officials at the two ports  said, however, that in their view the assessments would provide such  benefits as a more comprehensive perspective on port operations and  vulnerabilities and validate their need for additional assets and people to  provide adequate security. Ensuring that the assessments are of high  quality is important not only for their effectiveness as security  instruments, but also because of their cost. For the most part, assessments  have been conducted only at medium-sized ports, and even there they are  costing $1 million or more per assessment.
section_title: Coast Guard Not Intending to Individually Approve Security Plans for Foreign Vessels
paragraphs: Concerns have been raised about the proposed approach for meeting  MTSA’s requirement that the Secretary of DHS approve vessel security  plans for all vessels operating in U.S. waters. Vessel security plans include  taking such steps as responding to assessed vulnerabilities, designating  security officers, conducting training and drills, and ensuring that  appropriate preventive measures will be taken against security incidents.  To implement this MTSA requirement the Coast Guard has stated, in  general, that it is not the Coast Guard’s intent to individually approve  vessel security plans for foreign vessels. Separate from MTSA, an  international agreement requires vessels to carry on board a vessel  security plan that is approved by the vessel’s country of registry—its “flag”  state—to ensure that an acceptable security plan is in place. The Coast  Guard provides that it will deem a flag state approval of a vessel security  plan to constitute the MTSA-required Secretary approval of MTSA vessel  security plans. However, MTSA does not mention any role for foreign  nations in the Secretary’s required approval of vessel security plans, and  some concerns have been raised about the advisability of allowing flag  states—some with a history of lax regulation—to ensure the security of  vessels traveling to the United States.
The international requirement for a security plan is contained in the  International Ship and Port Facility Security (ISPS) Code. Under this  requirement, which was adopted about the same time that MTSA was  enacted and will go into effect on July 1, 2004, the vessel’s flag state is  responsible for reviewing and certifying the vessel’s security plan. Prior to  this time, the vessels’ flag state had already been responsible for ensuring  that its vessels met safety requirements. Critics of using this approach for  MTSA-required security plans have pointed out that in the past, some flag  states had a spotty record of enforcing safety requirements.
Rather than individually approving security plans for vessels overseen by  foreign flag states, the Coast Guard plans an extensive monitoring effort as  part of its oversight of vessels bound for U.S. waters. However, the Coast  Guard’s interim rule stated that, as part of an aggressive port state control  program, the Coast Guard would verify that foreign vessels have an  approved, fully implemented security plan, as well as tracking the  performance of owners, operators, flag administrations, charters, and port  facilities. Coast Guard officials have said that they are working from  existing procedures, in that their security effort is modeled after their  safety program. They also said, however, that they have no contingency  plans in case stronger measures than those called for in their current plans  are required.
The concerns are limited mainly to foreign flag vessels. Vessels registered  in the United States will have their security plans reviewed and approved  by the Coast Guard. It has been reported that the Coast Guard estimates  that review and approval of security plans for domestic vessels and  facilities will require 150 full-time personnel and cost $70 million as part of  its 2004 budget.
section_title: Potential Duplication of Maritime Intelligence Efforts
paragraphs: Turning to issues that are related more to program efficiency and  management than to security concerns, one issue that has arisen involves  potential duplication in the area of maritime intelligence. MTSA required  the Secretary of Homeland Security to implement a system to collect,  integrate, and analyze information on vessels operating on or bound for  U.S. waters. The Secretary of DHS in turn delegated responsibilities to TSA  and the Coast Guard. There appears to be potential for duplication by TSA  and the Coast Guard in these efforts.
The duplication concerns center on the new Integrated Maritime  Information System (IMIS) required under the Secretary’s delegations. The  Secretary of DHS delegated primary responsibility for this system to TSA,  and TSA was appropriated $25 million to develop it. Coast Guard officials  have voiced concerns that TSA’s efforts in developing the overall system  are duplicating existing Coast Guard efforts that are more extensive and  better funded. According to these officials, IMIS is very similar to the  Coast Guard’s Intelligence Coordination Center (ICC) Coastwatch  program, an effort that has 10 times the amount of funding appropriated  for IMIS, involves 100 more staff members, and has staff already in place  with considerable intelligence analysis capability. Coast Guard officials  questioned whether TSA’s smaller effort could yield information of similar  quality.
Coast Guard officials also expressed concerns about potential duplication  of effort at the port level. TSA’s tests of the system would place TSA  personnel at the port level. Coast Guard personnel noted that these efforts  seemed similar to the Coast Guard’s Field Intelligence Support Teams, as  well as teams from the legacy agencies, the Customs Service and the  Immigration and Naturalization Service, that also operate at the port level.  Coast Guard officials said that they saw little sharing of the intelligence at  that level.
While we have not yet had the opportunity to observe the intelligence  arms of TSA and the Coast Guard in action to more fully evaluate the  potential for duplication of effort, it does appear that some potential  duplication exists. From conversations with TSA and Coast Guard  officials, we could discern little difference in a number of their  information and integration efforts. Aside from potential inefficient use of  resources, this possible duplication may also limit either agency from  obtaining a complete intelligence picture and detecting potential threats.
section_title: Differences between Current TSA Grant Program and MTSA Grant Requirements
paragraphs: The final issue involves TSA’s implementation of MTSA’s grant program.  MTSA required the Secretary of Transportation to establish a program of  grants to ports and other entities to implement area and facility-specific  security plans. Prior to the enactment of MTSA, TSA, in partnership with  MARAD and the Coast Guard, already had begun a port security grant  program in February 2002. This program was originally intended to fund  security assessments and enhanced operational security at ports and  facilities, and two rounds of grants were funded before MTSA was enacted  in November 2002. TSA officials told us that, rather than creating a new  grant program to specifically respond to MTSA, they are adapting the  existing program to meet MTSA requirements. Under this approach, some  time will elapse before all of the grant requirements specified under MTSA  are in place.
The existing grant program differs from MTSA requirements in several  respects. Most significantly, the existing grant program does not require  cost-sharing, while MTSA does. MTSA grant provisions state that for  projects costing more than $25,000, federal funds for any eligible project  shall not exceed 75 percent of the total cost. A TSA official said that, in  starting to fold MTSA grants into the existing program for the third round  of grants, TSA was still disbursing moneys from a prior appropriation, and  the language of that legislation limited its ability to make changes that  would meet MTSA requirements. As a result, TSA encouraged cost-sharing  but did not require it. While TSA limited its changes for the first three  rounds of grants, in the future continued deviation from MTSA cost- sharing requirements would keep federal dollars from reaching as many  projects as possible. By not requiring a grantee to share in the financial  burden, TSA does not take into account the applicant’s ability to  participate in the funding. If applicants have such ability, the result is that  available federal dollars are not effectively leveraging as many projects as  possible.
There are two additional areas where TSA’s current grant program differs  from MTSA provisions. First, the current grant program does not  specifically correspond to the stated purpose of MTSA’s grant funding,  which is to implement area and facility-specific security plans. TSA  officials told us that in round three, they would give preference to  regulated facilities and vessels that were already required to have security  assessments and plans in place. As a result, the grants would likely be for  mitigating identified vulnerabilities rather than developing plans. Second,  in the application instructions for the current program, TSA said that  recurring costs for personnel and operations and maintenance costs were  not eligible for funding. MTSA specifically includes these costs.
TSA officials said that for later rounds of grants during fiscal year 2004,  they would discuss potential changes in the Port Security Grant Program  with the Coast Guard and MARAD. These potential changes would include  requiring that all grant proposals be designed to meet MTSA port security  grant requirements. The officials said, however, that before making any  changes, they would look for specific directions accompanying currently  pending appropriations for fiscal year 2004.
Mr. Chairman, this concludes my prepared statement. I would be pleased  to answer any questions that you or other members of the committee may  have.
section_title: Contacts and Acknowledgments
paragraphs: For information about this testimony, please contact Margaret Wrightson,  Director, Homeland Security and Justice Issues, at (415) 904-2000.  Individuals making key contributions to this testimony include Jonathan  Bachman, Jason Berman, Steven Calvo, Matthew Coco, Rebecca Gambler,  Geoffrey Hamilton, Christopher Hatscher, Lori Kmetz, Stan Stenersen, and  Randall Williamson.
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