Aviation Security: Progress Made but Actions Needed to Address Challenges in Meeting the Air Cargo Screening Mandate
Published: 2010-06-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This testimony discusses air cargo screening. In 2008, about 7.3 billion pounds of cargo was transported on U.S. passenger flights--approximately 58 percent of which was transported domestically (domestic cargo) and 42 percent of which was transported on flights arriving in the United States from a foreign location (inbound cargo). The 2009 Christmas Day plot to detonate an explosive device during an international flight bound for Detroit provided a vivid reminder that terrorists continue to view passenger aircraft as attractive targets. According to the Transportation Security Administration (TSA), the security threat posed by terrorists introducing explosive devices in air cargo shipments is significant, and the risk and likelihood of such an attack directed at passenger aircraft is high. To help enhance the security of air cargo, the Implementing Recommendations of the 9/11 Commission Act of 2007 (9/11 Commission Act) mandated the Department of Homeland Security (DHS) to establish a system to physically screen 50 percent of cargo on passenger aircraft--including the domestic and inbound flights of foreign and U.S. passenger operations--by February 2009, and 100 percent of such cargo by August 2010. The 9/11 Commission Act defines screening for purposes of the air cargo screening mandate as a physical examination or nonintrusive methods of assessing whether cargo poses a threat to transportation security. The act also requires that such a system provide a level of security commensurate with the level of security for the screening of checked baggage. According to TSA, the mission of its air cargo security program is to secure the air cargo transportation system while not unduly impeding the flow of commerce. Although the mandate is applicable to both domestic and inbound cargo, TSA stated that it must address the mandate for domestic and inbound cargo through separate systems because of differences in its authority to regulate domestic and international air cargo industry stakeholders. This testimony is based on a report we are publicly releasing today that assesses TSA's progress and related challenges in meeting the air cargo screening mandate. It addresses the following key issues in our report: progress TSA has made in meeting the 9/11 Commission Act screening mandate as it applies to (1) domestic air cargo and (2) inbound air cargo and related challenges it faces for each. For our report, we reviewed documents such as TSA's air cargo security policies and procedures. We also conducted site visits to four category X U.S. commercial airports and one category I U.S. commercial airport that process domestic and inbound air cargo. We selected these airports based on airport size, passenger and air cargo volumes, location, and participation in TSA's screening program. At these airports, we observed screening operations and technologies and interviewed local TSA officials, airport management officials, and representatives from 7 air carriers, 24 freight forwarders, 3 shippers, and 2 handling agents to obtain their views on TSA's system to implement the screening mandate. We selected these air carriers, freight forwarders, shippers, and handling agents based on input from TSA and industry stakeholders. More detailed information about our scope and methodology is included in our June 2010 report. We conducted this work in accordance with generally accepted government auditing standards.
section_title: What GAO Found
paragraphs: TSA has taken a number of actions to meet the screening mandate as it applies to domestic cargo, including creating a voluntary program to allow screening to take place at various points in the air cargo supply chain and mandating that, effective May 1, 2010, 75 percent of all cargo transported on passenger aircraft is screened. However, TSA faces several challenges in developing and implementing a system to screen 100 percent of domestic air cargo, and it is questionable, based on reported screening rates, whether 100 percent of such cargo will be screened by August 2010 without impeding the flow of commerce. Moreover, TSA has made some progress in meeting the screening mandate as it applies to inbound cargo, but challenges exist, in part related to TSA's limited ability to regulate foreign entities. TSA does not expect to achieve 100 percent screening of inbound air cargo by the mandated August 2010 deadline. We made five recommendations to TSA to address these challenges. TSA concurred with three of these recommendations, partially concurred with one, and did not concur with the remaining recommendation, which we discuss in more detail later in this statement. TSA has made progress in meeting the 9/11 Commission Act air cargo screening mandate as it applies to domestic cargo, and has taken several key steps in this effort, such as increasing the amount of domestic cargo subject to screening, creating a voluntary program to allow screening to take place at various points along the air cargo supply chain, and taking steps to test air cargo screening technologies, among other actions. However, TSA faces several challenges in fully developing and implementing a system to screen 100 percent of domestic air cargo, including those related to industry participation and technology.

section_title: Letter
paragraphs: I appreciate the opportunity to participate in today’s hearing to discuss air  cargo screening. In 2008, about 7.3 billion pounds of cargo was  transported on U.S. passenger flights—approximately 58 percent of which  was transported domestically (domestic cargo) and 42 percent of which  was transported on flights arriving in the United States from a foreign  location (inbound cargo). The 2009 Christmas Day plot to detonate an  explosive device during an international flight bound for Detroit provided  a vivid reminder that terrorists continue to view passenger aircraft as  attractive targets. According to the Transportation Security Administration  (TSA), the security threat posed by terrorists introducing explosive  devices in air cargo shipments is significant, and the risk and likelihood of  such an attack directed at passenger aircraft is high. To help enhance the  security of air cargo, the Implementing Recommendations of the 9/11  Commission Act of 2007 (9/11 Commission Act) mandated the Department  of Homeland Security (DHS) to establish a system to physically screen 50  percent of cargo on passenger aircraft—including the domestic and  inbound flights of foreign and U.S. passenger operations—by February  2009, and 100 percent of such cargo by August 2010. The 9/11 Commission  Act defines screening for purposes of the air cargo screening mandate as a  physical examination or nonintrusive methods of assessing whether cargo  poses a threat to transportation security. The act also requires that such a  system provide a level of security commensurate with the level of security  for the screening of checked baggage.
According to TSA, the mission of its air cargo security program is to  secure the air cargo transportation system while not unduly impeding the  flow of commerce. Although the mandate is applicable to both domestic  and inbound cargo, TSA stated that it must address the mandate for  domestic and inbound cargo through separate systems because of  differences in its authority to regulate domestic and international air cargo  industry stakeholders. My statement is based on a report we are publicly  releasing today that assesses TSA’s progress and related challenges in  meeting the air cargo screening mandate. It addresses the following key  issues in our report: progress TSA has made in meeting the 9/11  Commission Act screening mandate as it applies to (1) domestic air cargo  and (2) inbound air cargo and related challenges it faces for each.
For our report, we reviewed documents such as TSA’s air cargo security  policies and procedures. We also conducted site visits to four category X  U.S. commercial airports and one category I U.S. commercial airport that  process domestic and inbound air cargo. We selected these airports based  on airport size, passenger and air cargo volumes, location, and  participation in TSA’s screening program. At these airports, we observed  screening operations and technologies and interviewed local TSA officials,  airport management officials, and representatives from 7 air carriers, 24  freight forwarders, 3 shippers, and 2 handling agents to obtain their views  on TSA’s system to implement the screening mandate. We selected these  air carriers, freight forwarders, shippers, and handling agents based on  input from TSA and industry stakeholders. More detailed information  about our scope and methodology is included in our June 2010 report. We  conducted this work in accordance with generally accepted government  auditing standards.
In summary, TSA has taken a number of actions to meet the screening  mandate as it applies to domestic cargo, including creating a voluntary  program to allow screening to take place at various points in the air cargo  supply chain and mandating that, effective May 1, 2010, 75 percent of all  cargo transported on passenger aircraft is screened. However, TSA faces  several challenges in developing and implementing a system to screen 100  percent of domestic air cargo, and it is questionable, based on reported  screening rates, whether 100 percent of such cargo will be screened by  August 2010 without impeding the flow of commerce. Moreover, TSA has  made some progress in meeting the screening mandate as it applies to  inbound cargo, but challenges exist, in part related to TSA’s limited ability  to regulate foreign entities. TSA does not expect to achieve 100 percent  screening of inbound air cargo by the mandated August 2010 deadline. We  made five recommendations to TSA to address these challenges. TSA  concurred with three of these recommendations, partially concurred with  one, and did not concur with the remaining recommendation, which we  discuss in more detail later in this statement.
subsections: section_title: TSA Has Made Progress toward Screening 100 Percent of Domestic Cargo, but Remaining Challenges Highlight the Need for a Contingency Plan
paragraphs: TSA has made progress in meeting the 9/11 Commission Act air cargo  screening mandate as it applies to domestic cargo, and has taken several  key steps in this effort, such as increasing the amount of domestic cargo  subject to screening, creating a voluntary program to allow screening to  take place at various points along the air cargo supply chain, and taking  steps to test air cargo screening technologies, among other actions.  However, TSA faces several challenges in fully developing and  implementing a system to screen 100 percent of domestic air cargo,  including those related to industry participation and technology.
subsections: section_title: Progress Made
paragraphs: TSA has taken several steps to address the air cargo screening mandate as  it applies to domestic cargo including the following.
TSA increased the amount of domestic cargo subject to screening.  Effective October 1, 2008, TSA established a requirement for 100 percent  screening of nonexempt cargo transported on narrow-body passenger  aircraft. In 2008, narrow-body flights transported about 24 percent of all  cargo on domestic passenger flights. Effective February 1, 2009, pursuant  to the 9/11 Commission Act, TSA also required air carriers to ensure the  screening of 50 percent of all nonexempt air cargo transported on all  passenger aircraft. Furthermore, effective May 1, 2010, air carriers were  required by TSA to ensure that 75 percent of such cargo was screened.  TSA also eliminated or revised most of its screening exemptions for  domestic cargo.
TSA created a voluntary program to facilitate screening  throughout the air cargo supply chain. Since TSA concluded that  relying solely on air carriers to conduct screening would result in  significant cargo backlogs and flight delays, TSA created the voluntary  Certified Cargo Screening Program (CCSP) to allow screening to take  place earlier in the shipping process, prior to delivering the cargo to the air  carrier. Under the CCSP, facilities at various points in the air cargo supply  chain, such as shippers, manufacturers, warehousing entities, distributors,  third-party logistics companies, and freight forwarders that are located in  the United States, may voluntarily apply to TSA to become certified cargo  screening facilities (CCSF). TSA initiated the CCSP at 18 U.S. airports that  process high volumes of air cargo, and then expanded the program to all  U.S. airports in early 2009.
TSA is conducting outreach efforts to air cargo industry  stakeholders. Starting in September 2007, TSA began outreach to freight  forwarders and subsequently expanded its outreach efforts to shippers  and other entities to encourage participation in the CCSP. TSA is focusing  its outreach on particular industries, such as producers of perishable  foods, pharmaceutical and chemical companies, and funeral homes, which  may experience damage to their cargo if it is screened by a freight  forwarder or an air carrier.
TSA is taking steps to test technologies for screening air cargo. To  test select screening technologies among CCSFs, TSA created the Air  Cargo Screening Technology Pilot in January 2008, and selected some of  the nation’s largest freight forwarders to use these technologies and report  on their experiences. In a separate effort, in July 2009, DHS’s Directorate  for Science and Technology completed the Air Cargo Explosives Detection  Pilot Program that tested the performance of select baggage screening  technologies for use in screening air cargo at three U.S. airports. In  November 2008, in addition to the canine and physical search screening  methods permitted by TSA to screen air cargo, TSA issued to air carriers  and CCSFs a list of X-ray, explosives trace detection (ETD), and  explosives detection systems (EDS) models that the agency approved for  screening air cargo until August 3, 2010. In March 2009, TSA initiated a  qualification process to test these and other technologies that it plans to  allow air carriers and CCSP participants to use in meeting the screening  mandate against TSA technical requirements.
TSA expanded its explosives detection canine program. TSA has  taken steps to expand the use of TSA-certified explosives detection canine  teams. According to TSA, in fiscal year 2009, TSA canine teams screened  over 145 million pounds of cargo, which represents a small portion of  domestic air cargo. As of February 2010, TSA had 113 dedicated air cargo  screening canine teams—operating in 20 major airports—and is in the  process of adding 7 additional canine teams. TSA also deployed canine  teams to assist the Pacific Northwest cherry industry during its peak  harvest season from May through July 2009, to help air carriers and CCSFs  handling this perishable commodity to meet the 50 percent screening  requirement without disrupting the flow of commerce.
TSA established a system to verify that screening is being  conducted at the mandated levels. The agency established a system to  collect and analyze data from screening entities to verify that requisite  levels for domestic cargo are being met. Effective February 2009, TSA  adjusted air carrier reporting requirements and added CCSF reporting  requirements to include monthly screening reports on the number and  weight of shipments screened.
section_title: Challenges Facing TSA
paragraphs: TSA faces industry participation, technology, planning, oversight, and  other challenges in meeting the air cargo screening mandate as it applies  to domestic cargo.
Industry Participation. Although TSA is relying on the voluntary  participation of industry stakeholders to meet the screening mandate, far  fewer shippers and independent CCSFs have joined the program than TSA  had targeted. As shown in figure 1, TSA officials have estimated that an  ideal mix of screening to achieve the 100 percent mandate as it applies to  domestic cargo without impeding the flow of commerce would be about  one-third of cargo weight screened by air carriers, one-third by freight  forwarders, and one-third by shippers and independent CCSFs.
To achieve TSA’s ideal mix of screening by August 2010, shipper and  independent CCSF screening efforts would need to increase by over  sixteenfold. As shown in figure 1, the total percentage of reported  screened cargo rose on average by less than a percentage point per month  (from 59 to 68 percent) from February 2009 through March 2010. At these  rates, it is questionable whether TSA’s screening system will achieve 100  percent screening of domestic cargo by August 2010 without impeding the  flow of commerce. Effective May 1, 2010, TSA requires that 75 percent of  air cargo transported on passenger aircraft be screened. However, even if  this requirement is met, an additional 25 percent of domestic air cargo  would still need to be screened in the 3 months prior to the August 2010  deadline, including some of the most challenging types of cargo to screen,  such as unit load device (ULD) pallets and containers.
TSA and industry officials reported that several factors, such as lack of  economic and regulatory incentives, are contributing to low shipper  participation levels. TSA and the domestic passenger air carrier and freight  forwarder industry association officials we interviewed stated that many  shippers and freight forwarders are not incurring significant screening  costs from air carriers. This decreases the financial pressure on the  entities to join the CCSP and invest resources into screening cargo, factors  that are making TSA’s outreach efforts more challenging.
Screening Technology. There is currently no technology approved or  qualified by TSA to screen cargo once it is loaded onto a ULD pallet or  container—both of which are common means of transporting air cargo on  wide-body passenger aircraft. Cargo transported on wide-body passenger  aircraft makes up 76 percent of domestic air cargo shipments transported  on passenger aircraft. Prior to May 1, 2010, canine screening was the only  screening method, other than physical search, approved by TSA to screen  such cargo. However, TSA officials still have some concerns about the  effectiveness of the canine teams, and effective May 1, 2010, the agency no  longer allows canine teams to be used for primary screening of ULD  pallets and containers. Canine teams still may be used for secondary  screening of ULD pallets and containers; however, secondary screening  does not count toward meeting the air cargo screening mandate.
In addition, TSA is working to complete qualification testing of air cargo  screening technologies; thus, until all stages of qualification testing are  concluded, the agency may not have reasonable assurance that the  technologies that air carriers and program participants are currently  allowed to use to screen air cargo are effective. Qualification tests are  designed to verify that a technology system meets the technical  requirements specified by TSA. Because of the mandated deadlines, TSA is  conducting qualification testing to determine which screening  technologies are effective at the same time that air carriers are using these  technologies to meet the mandated requirement to screen air cargo  transported on passenger aircraft. While we recognize that certain  circumstances, such as mandated deadlines, require expedited deployment  of technologies, our prior work has shown that programs with immature  technologies have experienced significant cost and schedule growth. We  reported that these technology challenges suggest the need for TSA to  consider a contingency plan to meet the screening mandate without  unduly affecting the flow of commerce.
Contingency Planning. Although TSA faces industry participation and  technology challenges that could impede the CCSP’s success and the  agency’s efforts to meet the 100 percent screening mandate by August  2010, the agency has not developed a contingency plan that considers  alternatives to address these challenges. Without adequate CCSP  participation, industry may not be able to screen enough cargo prior to its  arrival at the airport to maintain the flow of commerce while meeting the  mandate. Likewise, without technology solutions for screening cargo in a  ULD pallet or container, industry may not have the capability to effectively  screen 100 percent of air cargo without affecting the flow of commerce.  We have previously reported that a comprehensive planning process,  including contingency planning, is essential to help an agency meet  current and future capacity challenges. Alternatives could include, but  are not limited to, mandating CCSP participation for certain members of  the air cargo supply chain—instead of relying on their voluntary  participation—and requiring the screening of some or all cargo before it is  loaded onto ULD pallets and containers. In the report being released  today, we recommended that TSA develop a contingency plan for meeting  the mandate as it applies to domestic cargo that considers alternatives to  address potential CCSP participation shortfalls and screening technology  limitations. TSA did not concur with this recommendation and stated that  a contingency plan is unnecessary since effective August 1, 2010, 100  percent of domestic cargo transported on passenger aircraft will be  required to be screened. The agency also stated that there is no feasible  contingency plan that can be implemented by TSA that does not  compromise security or create disparities in the availability of screening  resources. However, we continue to believe that there are feasible  alternatives that TSA should consider to address potential CCSP  participation shortfalls and screening technology limitations. Thus, it is  prudent that TSA consider developing a contingency plan that would allow  for the security and legitimate flow of air cargo.
Inspection Resources. While TSA has amended its Regulatory Activities  Plan to include inspections of CCSP participants, the agency has not  completed its staffing study to determine how many inspectors will be  necessary to provide oversight of the additional program participants  when the 100 percent screening mandate goes into effect. According to  TSA, the agency’s staffing study is continuing through fiscal year 2010 and  is therefore not yet available to provide guidance in helping to plan for  inspection resources needed to provide oversight. According to our  analysis of TSA data, in the next year, inspectors will need to at least  double their comprehensive inspections of CCSFs to reach the agency’s  inspection goals. We recommended that TSA create milestones to help  ensure completion of the staffing study. TSA concurred and stated that as  part of the staffing study, the agency is working to develop a model to  identify the number of required transportation security inspectors and that  this effort would be completed in the fall of 2010. If this model includes an  analysis of the resources needed to provide CCSP oversight under various  scenarios, it will address the intent of our recommendation.
Reported Screening Data. While TSA reported to Congress that industry  achieved the February 2009 50 percent screening deadline domestically,  questions exist about the reliability of the screening data, which are self- reported by industry representatives, because TSA does not have a  mechanism to verify the accuracy of the data reported by the industry. We  recommended that TSA develop a mechanism to verify the accuracy of all  screening data through random checks or other practical means. TSA  stated that verifying the accuracy of domestic screening data will continue  to be a challenge because there is no means to cross-reference local  screening logs—which include screening information on specific  shipments—with screening reports submitted by air carriers to TSA that  do not contain such information. However, TSA could consider a quality  review mechanism similar to the compliance measurement program used  by CBP, which includes regular quality reviews to ensure accuracy in  findings and management oversight to validate results.
In-Transit Cargo. Cargo that has already been transported on one leg of  a passenger flight—known as in-transit cargo—may be subsequently  transferred to another passenger flight without undergoing screening.  According to TSA officials, though the agency does not have a precise  figure, industry estimates suggest that about 30 percent of domestic cargo  is transferred from an inbound flight. TSA officials stated that transporting  in-transit cargo without screening could pose a vulnerability, but as of  February 2010, the agency was not planning to require in-transit cargo  transferred from an inbound flight to be physically screened because of  the logistical difficulties associated with screening cargo that is  transferred from one flight to another. We recommended that TSA develop  a plan with milestones for how and when it intends to require the  screening of in-transit cargo. TSA concurred with our recommendation  and stated that the agency has implemented changes, effective August 1,  2010, that will require 100 percent of in-transit cargo to be screened unless  it can otherwise be verified as screened. Because this is a significant  change and potentially operationally challenging, it will be important to  closely monitor the industry’s understanding and implementation of this  requirement to help ensure that 100 percent screening of in-transit cargo is  being conducted.
section_title: TSA Has Made Progress but Faces Several Challenges and Lacks a Plan for Achieving 100 Percent Screening of Inbound Cargo
paragraphs: TSA has taken steps to increase the percentage of inbound cargo  transported on passenger aircraft that is screened, but the agency has not  developed a plan, including milestones, for meeting the mandate as it  applies to inbound cargo. Consequently, TSA officials have stated that the  agency will not be able to meet the mandate as it applies to inbound cargo  by the August 2010 deadline.
subsections: section_title: Steps Taken
paragraphs: Steps TSA has taken to increase the percentage of inbound air cargo that  is screened include the following:    Revising its requirements for foreign and U.S. air carrier security  programs, effective May 1, 2010, to generally require air carriers to  screen a certain percentage of shrink-wrapped and banded inbound  cargo and 100 percent of inbound cargo that is not shrink-wrapped or  banded. According to TSA, implementation of this requirement will  result in the screening of 100 percent of inbound cargo transported on  narrow-body aircraft since none of this cargo is shrink-wrapped or  banded.
Obtaining information from foreign countries on their respective air  cargo screening levels and practices to help assess the rigor and  quality of foreign screening practices.
Working to harmonize security standards with those of foreign  nations.
section_title: Challenges TSA Faces
paragraphs: According to TSA, screening inbound air cargo poses unique challenges,  related, in part, to TSA’s limited ability to regulate foreign entities. As  such, TSA officials stated that the agency is focusing its air cargo  screening efforts on domestic cargo and on screening elevated-risk  inbound cargo as it works to address the challenges it faces in screening  100 percent of inbound cargo. In April 2007, we reported that TSA’s  screening exemptions for inbound cargo could pose a risk to the air cargo  supply chain and recommended that TSA assess whether these  exemptions pose an unacceptable vulnerability and, if necessary, address  these vulnerabilities. TSA agreed with our recommendation, but beyond  its requirement to screen 100 percent of inbound cargo transported on  narrow-body aircraft and a certain percentage of shrink-wrapped or  banded inbound cargo, has not reviewed, revised, or eliminated inbound  screening exemptions, and did not provide a time frame for doing so. We  continue to believe that TSA should assess whether these exemptions pose  an unacceptable security risk.
In addition, identifying the precise level of screening being conducted on  inbound air cargo is difficult because TSA lacks a mechanism to obtain  actual data on all screening that is being conducted on inbound air cargo.  TSA officials estimate that 55 percent of inbound cargo by weight is  currently being screened and that 65 percent of inbound cargo by weight  will be screened by August 2010. However, these estimates are based on  the current screening requirements of certain countries and are not based  on actual data collected from air carriers or other entities, such as foreign  governments, on what percentage of cargo is actually being screened. We  recommended that TSA develop a mechanism to verify the accuracy of all  screening data through random checks or other practical means and  obtain actual data on all inbound screening. TSA concurred in part with  our recommendation, stating that as of May 1, 2010, the agency issued  changes to air carriers’ standard security programs that require air carriers  to report inbound cargo screening data to TSA. However, as noted in our  report, these requirements apply to air carriers and the screening that they  conduct and not to the screening conducted by other entities, such as  foreign governments. Thus, TSA will continue to rely in part on estimates  to report inbound cargo screening levels. TSA officials stated that it may  be challenging to obtain screening data from some foreign governments  and other entities that conduct cargo screening, but TSA has not  developed a plan for how it could obtain these data. We recognize that it  may be challenging for TSA to obtain cargo screening data from foreign  governments; however, similar to domestic reporting requirements, the  agency could require air carriers to report on cargo screening for all  inbound cargo they transport, including the screening conducted by other  entities.
Moreover, the 9/11 Commission Act requires the establishment of a system  to screen 100 percent of cargo transported on passenger aircraft, including  inbound cargo. As we have reported in our prior work, a successful  project plan—such as a plan that would be used to establish such a  system—should consider all phases of the project and clearly state  schedules and deadlines. TSA officials reported that the agency is unable  to identify a timeline for meeting the mandate for inbound cargo, stating  that its efforts are long term, given the extensive work it must conduct  with foreign governments and associations. However, interim milestones  could help the agency provide reasonable assurance to Congress that it is  taking steps to meet the mandate as it applies to inbound cargo. In our  June 2010 report, we recommended that TSA develop a plan with  milestones for how and when the agency intends to meet the mandate as it  applies to inbound cargo. TSA concurred with our recommendation and  stated that the agency is drafting milestones as part of a plan that will  generally require air carriers to conduct 100 percent screening by a  specific date. If implemented effectively, this plan will address the intent  of our recommendation.
Madam Chairwoman, this concludes my statement. I look forward to  answering any questions that you or other members of the subcommittee  may have.
section_title: Contacts and Acknowledgments
paragraphs: For questions about this statement, please contact Stephen M. Lord at  (202) 512-4379 or lords@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this statement. Individuals making key contributions to this testimony  are Steve D. Morris, Assistant Director; Tina Cheng; Barbara A. Guffy;  David K. Hooper; Richard B. Hung; Stanley J. Kostyla; Linda S. Miller;  Yanina Golburt Samuels; and Rebecca Kuhlmann Taylor.
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