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Report to the Ranking Democratic Member, Committee on Transportation 
and Infrastructure, House of Representatives: 

United States Government Accountability Office: 

GAO: 

September 2005: 

Transportation Security Administration: 

More Clarity on the Authority of Federal Security Directors Is Needed: 

GAO-05-935: 

GAO Highlights: 

Highlights of GAO-05-935, a report to the Ranking Democratic Member, 
Committee on Transportation and Infrastructure, House of 
Representatives: 

Why GAO Did This Study: 

The Transportation Security Administration (TSA) assigned Federal 
Security Directors (FSD) to oversee security, including the screening 
of passengers and their baggage, at the nation's more than 440 
commercial airports. FSDs must work closely with stakeholders to ensure 
that airports are adequately protected and prepared in the event of a 
terrorist attack. This report addresses (1) the roles and 
responsibilities of FSDs and the clarity of their authority relative to 
that of other airport stakeholders during security incidents, (2) the 
extent to which FSDs formed and facilitated partnerships with airport 
stakeholders, and (3) FSDs’ views of key changes TSA made to better 
support or empower the FSD position. 

What GAO Found: 

TSA has issued guidance that clearly defines FSDs’ roles and 
responsibilities. However, TSA’s guidance related to FSDs’ authority is 
outdated and lacks clarity regarding FSD authority relative to other 
airport stakeholders. TSA’s document that delegates authority to FSDs 
gives them authority to supervise and deploy a TSA law enforcement 
force that was never established. Also, it does not clearly address FSD 
authority during a security incident relative to other parties with 
airport security responsibilities. At airports GAO visited, 
stakeholders said that this information had never been communicated to 
them and they were not always clear on the FSDs’ authority in such 
situations. For example, confusion arose at one airport over whether 
the FSD had the authority to take certain actions during a security 
incident. In August 2005, TSA officials stated that they were updating 
guidance on FSDs’ authority but had not finalized their revisions prior 
to this report’s issuance. 

All of the FSDs and most stakeholders at the airports GAO visited 
reported developing partnerships that were generally working well. 
Communication and coordination were taking place among stakeholders at 
these airports, including meetings, briefings, and training exercises. 
According to TSA, partnerships with airport stakeholders are essential 
to FSDs’ success in addressing aviation security and customer service 
needs. For example, FSDs rely on law enforcement stakeholders during 
security incidents since they do not have their own law enforcement 
resources. FSDs also rely on air carriers for passenger volume 
information to schedule screeners, and air carriers rely on FSDs for 
efficient screening that minimizes passenger wait times. 

TSA made changes in 2004 to better support or empower the FSD position, 
and most of the 25 FSDs we interviewed generally viewed these changes 
favorably. For example, most of the FSDs we interviewed were satisfied 
with TSA’s new local hiring process that provided more options for FSDs 
to be involved in hiring screeners, and most said that the new process 
was better than the more centralized hiring process it replaced. Most 
FSDs we interviewed also saw value in the headquarters group TSA 
established to provide operational support to the field and a 
communication link among headquarters, field-based Area Directors, and 
FSDs. 

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

[See PDF for image] 

[End of figure] 

What GAO Recommends: 

GAO recommends that the Secretary of Homeland Security direct TSA to 
update its Delegation of Authority to FSDs and communicate this 
information to FSDs and airport stakeholders. The Department of 
Homeland Security generally concurred with GAO’s findings and 
recommendations and described corrective actions that it has initiated 
or plans to take to address the issues identified. 

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

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Cathleen Berrick at (202) 
512-8777 or Berrickc@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Federal Security Directors Have a Range of Responsibilities, but TSA's 
Guidance Regarding FSDs' Authority Is Unclear: 

TSA Provided Opportunities for Some FSDs to Participate in Developing 
TSA Aviation Security Policy: 

FSDs Formed Partnerships with Key Stakeholders and Participated in 
Communication and Coordination Efforts: 

TSA Made Changes to Better Support or Empower the FSD Position and Was 
Planning Additional Changes: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objective, Scope, and Methodology: 

Appendix II: Responses to Selected Questions from Interviews with 25 
Federal Security Directors: 

Appendix III: Comments from the Department of Homeland Security: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Figures: 

Figure 1: Transportation Security Administration Organization Chart: 

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

Figure 3: Number of FSD Positions with Responsibility for a Designated 
Number of Airports, as of January 2005: 

Abbreviations: 

ATSA: Aviation and Transportation Security Act: 

BTS: Border and Transportation Security: 

CBP: Customs and Border Protection: 

DHS: Department of Homeland Security: 

DOT: Department of Transportation: 

FBI: Federal Bureau of Investigation: 

FSD: Federal Security Director: 

ICE: Immigration and Customs Enforcement: 

MANPADS: Man Portable Air Defense System: 

TSA: Transportation Security Administration: 

TSES: Transportation Senior Executive Service: 

[End of section] 

United States Government Accountability Office: 

Washington, DC 20548: 

September 23, 2005: 

The Honorable James L. Oberstar: 
Ranking Democratic Member: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

Federal Security Directors (FSD) are the ranking Transportation 
Security Administration (TSA) authorities responsible for leading and 
coordinating TSA security activities at the nation's more than 440 
commercial airports. During 2002, the first year FSDs were assigned to 
airports, FSDs worked to meet deadlines associated with screening, 
including deploying over 55,000 passenger and baggage screeners and 
screening checked baggage using explosive detection systems. As a part 
of their security responsibilities, FSDs must coordinate closely with 
airport and air carrier officials, local law enforcement, and emergency 
response officials to ensure that airports are adequately protected and 
prepared in the event of a terrorist attack. FSDs' success in 
sustaining and ensuring the effectiveness of aviation security efforts 
are dependent on their ability to develop and maintain effective 
partnerships with these stakeholders. 

In March 2004, after FSDs had been deployed at airports for over 2 
years, we surveyed all 155 FSDs at that time and learned that most 
thought they needed certain additional authorities and flexibilities to 
better address airport staffing and security needs. Since that survey, 
TSA has taken steps to enhance FSDs' authority and provide 
flexibilities in certain areas. To provide additional information on 
the ability of FSDs to address airport security needs, this report 
addresses the following questions: (1) What are the roles and the 
responsibilities of FSDs and how clear is their authority relative to 
that of other airport stakeholders during security incidents? (2) To 
what extent are FSDs involved in the development of TSA aviation 
security policy? (3) How have FSDs at selected airports formed and 
facilitated partnerships with airport stakeholders, and how are these 
partnerships working? (4) What key changes has TSA made or planned to 
make to better support or empower the FSD position, and how have 
selected FSDs viewed these efforts? 

To address these questions, we interviewed TSA's Chief Operating 
Officer and officials from TSA's Aviation Security Program Office, 
Office of Law Enforcement, Office of Compliance Programs, and Office of 
Human Resources, and we reviewed relevant laws and TSA documentation 
related to the FSD position. To obtain additional views on the role of 
the FSD and FSD-stakeholder partnerships, we met with headquarters 
officials from the Department of Homeland Security's (DHS) Border and 
Transportation Security Directorate (BTS),[Footnote 1] and the Federal 
Bureau of Investigation's (FBI) Counter-Terrorism and Criminal 
Investigations Divisions. We also met with officials from national 
organizations representing airports (the American Association of 
Airport Executives and the Airports Council International), airport law 
enforcement officials (the Airport Law Enforcement Agencies Network), 
and air carriers (the Air Transport Association). We conducted site 
visits to seven airports. We selected these airports because they 
incorporated all five airport security categories[Footnote 2]--three 
airports with an FSD dedicated solely to each airport, and two sets of 
airports where the FSD was responsible for at least two airports. At 
each airport, we met with the FSD (five in total) or the top-ranking 
TSA official, as well as the Assistant FSDs for Law Enforcement and 
Regulatory Inspection, where these positions existed. During our 
meetings with FSDs, we obtained their views on changes TSA made to 
further enhance the FSD position, as well as views on their roles and 
responsibilities and perspectives on their partnerships with local 
stakeholders. At airports, we also met with key stakeholders--airport 
managers, airport law enforcement, station managers representing 
selected air carriers, and FBI Airport Liaison Agents and officials 
from DHS's Customs and Border Protection (CBP) and Immigration and 
Customs Enforcement (ICE) (at the two international airports we 
visited) to obtain their views on the roles and responsibilities of the 
FSD and partnerships and communication mechanisms with FSDs. 

To corroborate and expand on what we learned from the FSDs we 
interviewed during our site visits, we randomly selected 25 additional 
FSDs and telephoned them to obtain their views on a range of topics 
including recent TSA initiatives and the development of federal 
aviation security policy. We also included selected questions-- 
regarding the adequacy of the FSDs' authority and flexibility--that we 
had posed earlier, in a March 2004 Web-based survey of all 155 FSDs in 
place at that time conducted in support of other aviation security 
reviews. Of the 25 FSDs we interviewed by telephone as part of this 
review, 21 were FSDs at the time of that Web-based survey and, as such, 
responded to both. The information we obtained during our seven airport 
visits and telephone interviews with 25 FSDs cannot be generalized to 
all airports and FSDs across the nation. 

We conducted our work from August 2004 through September 2005 in 
accordance with generally accepted government auditing standards. 
Appendix I contains more details about our scope and methodology. 

Results in Brief: 

TSA developed guidance that describes the roles and responsibilities of 
the FSD position, such as ensuring overall aviation security, providing 
regulatory oversight, implementing policy, and managing stakeholder 
relationships. However, the document that specifically describes the 
FSDs' authority--TSA's Delegation of Authority to FSDs--is outdated, 
does not clearly address the extent of FSD authority relative to other 
airport stakeholders, and has not been adequately communicated to these 
stakeholders. The document has not been updated since FSDs were first 
assigned to airports and gives FSDs authority to supervise and deploy a 
TSA law enforcement force that was envisioned but never established. 
Also, the document describes some of the authorities of FSDs but does 
not clearly address the extent of their authority relative to other 
airport stakeholders, including law enforcement agencies, during 
security incidents. Stakeholders at the airports we visited said they 
were not always clear on the authority FSDs had relative to that of 
other agencies, particularly FSDs' authority in various security 
incidents, and that such information had not been communicated to them. 
For example, at two airports, confusion or conflicting opinions arose 
over whether the FSD had the authority to take certain actions during 
particular security incidents. Stakeholders at the national level also 
questioned the clarity of the FSDs' authority relative to other 
agencies, particularly during security incidents. For example, FBI 
headquarters officials stated that past airport training exercises 
revealed that some FSDs thought they were in charge of certain 
situations for which the FBI had authority. According to these 
officials, in an actual security incident, confusion over roles could 
result in conflict, confusion, and increased response time. In 
addition, 18 of the 25 FSDs we interviewed by telephone said they 
believed that TSA needs to do more to clarify their roles and 
responsibilities for the benefit of FSDs and stakeholders, and many 
stated that the authority of the FSD, in particular, needed 
clarification. In August 2005, TSA officials stated that they had 
drafted a new Delegation of Authority that clarified FSDs' authority. 
However, TSA had not completed the revision prior to the issuance of 
this report. 

TSA does not charge FSDs with responsibility for developing federal 
aviation security policy, but it does provide several opportunities for 
some FSDs to be involved in developing some such policies. TSA's FSD 
Advisory Council provides one mechanism for selected FSDs to be 
involved in TSA's development of aviation security policy. The FSD 
Advisory Council consists of 22 FSDs who the Administrator selects 
based on various factors, such as airport security category. FSD 
members provide the Administrator their opinions and guidance on 
establishing and modifying TSA policies and procedures when requested 
and have opportunities for input in other areas. On occasion, some FSDs 
also have had the opportunity to provide input on draft federal 
aviation security policy through ad hoc consultation groups organized 
by TSA's Aviation Security Program Office. Testing new technology and 
procedures at their airports has been another way for some FSDs to be 
involved in developing federal aviation security policy. 

FSDs responsible for the seven airports we visited reported that they 
had entered into partnerships with airport stakeholders, and FSDs and 
stakeholders we contacted at these airports said that their 
partnerships were generally working well. TSA recognizes that building 
and maintaining partnerships with airport stakeholders is essential to 
FSDs' success in addressing security as well as maintaining an 
appropriate level of customer service. TSA established general guidance 
for FSDs to follow in building stakeholder partnerships but has left it 
to the FSDs to determine how best to achieve effective partnerships at 
their respective airports. FSDs need to partner with law enforcement 
stakeholders, for example, because they do not have a law enforcement 
body of their own to respond to security incidents. Partnerships can be 
of mutual benefit to FSDs and airport stakeholders and can enhance 
customer service. For example, FSDs rely on air carrier data on the 
number of passengers transiting through checkpoints to appropriately 
schedule screeners, and air carriers rely on the FSD to provide an 
efficient screening process to minimize wait times for passengers. At 
the airports we visited, FSDs and stakeholders cited several ways FSDs 
maintained partnerships, including being accessible to their 
stakeholders to help resolve problems and meeting with stakeholders to 
discuss how to implement new security policies. In addition, a variety 
of communication and coordination efforts were in place at the airports 
we visited, and many of these efforts existed before TSA assigned FSDs 
to airports. Formal mechanisms included security and general airport 
operations meetings, incident debriefings, and training exercises to 
help ensure a coordinated response in the event of a security incident. 

TSA made changes in 2004 to better support or empower the FSD position 
by providing FSDs with more authority and flexibility, and FSDs we 
interviewed generally viewed most of these efforts favorably. For 
example, TSA implemented a local hiring initiative designed to vest 
FSDs with more authority to address their screener staffing needs by, 
among other things, giving FSDs the flexibility to select their level 
of participation in the hiring process. Most of the 25 FSDs we 
interviewed stated that this new hiring method addressed their needs 
better than TSA's former highly centralized approach, although 12 of 
the 25 FSDs said that to a great or very great extent, they still 
wanted more authority in this area. When we originally posed the same 
question regarding FSD authority in hiring screeners in our March 2004 
survey of all 155 FSDs, 88 percent of those FSDs stated that to a great 
or very great extent they wanted more authority in selecting screeners. 
In another effort to move more decision making to the field, TSA 
physically relocated its five Area Director positions from headquarters 
to the field and established a group in headquarters to provide 
operational support and a communication link among headquarters, field- 
based Area Directors, and FSDs. FSDs we interviewed were split on 
whether they thought moving the Area Director position to the field was 
helpful, but most considered the group TSA established in headquarters 
to be a valuable resource. TSA had three other efforts under way that 
could significantly affect FSDs--the implementation of a new staffing 
model for allocating screeners at airports, a reassessment of the 
number of management positions allocated to each FSD, and a 
reassessment of which and how many airports are assigned to FSDs. TSA 
took steps to involve at least some FSDs in these efforts. However, 
most of the 25 FSDs we interviewed said that TSA had not involved them. 
TSA headquarters officials said that they acknowledge the importance of 
FSDs' involvement in agency planning efforts, and when practical and 
appropriate, have attempted to obtain a broad spectrum of FSD input. 

To assist TSA in fully communicating key areas of FSD authority to 
ensure organizational goals and objectives are achieved, we recommend 
that the Secretary of Homeland Security direct the Assistant Secretary 
of Homeland Security for TSA to update the Delegation of Authority to 
FSDs to clearly reflect their authority relative to other airport 
stakeholders during security incidents and communicate this information 
to FSDs and relevant stakeholders. 

We provided a draft of this report to DHS for review. DHS, in its 
written comments, generally concurred with our findings and 
recommendations and agreed that efforts to implement these 
recommendations are critical to enable FSDs to effectively oversee 
security at the nation's commercial airports. DHS described actions TSA 
has initiated to revise and update the Delegation of Authority to FSDs. 
Once approved, TSA plans to notify FSDs and airport stakeholders of 
their responsibilities under the new Delegation of Authority. A copy of 
DHS's comments is included as appendix III. 

Background: 

A federal position dedicated to overseeing security at commercial 
airports was first established in 1990 under the Federal Aviation 
Administration and was later transferred to TSA. The Federal Aviation 
Administration established the position of Federal Security Manager 
pursuant to a mandate in the Aviation Security Improvement Act of 
1990.[Footnote 3] Federal Security Managers, responsible for security 
at the nation's largest airports, developed airport security plans in 
concert with airport operators and air carriers; provided regulatory 
oversight to ensure security measures were contained in airport plans 
and were properly implemented; and coordinated daily federal aviation 
security activities, including those with local law enforcement. 
According to TSA officials, regional civil aviation security field 
offices, headed by Civil Aviation Security Field Officers and staffed 
with security inspectors, had been in place at commercial airports 
since the mid-1970s and eventually covered the more than 440 commercial 
airports required to have security programs. In practice, the field 
office staff performed compliance and enforcement inspections and 
assessed penalties, while the Federal Security Managers served in a 
liaison and coordination role as on-site security experts. To avoid 
duplication of effort, Civil Aviation Security Field Officers were not 
assigned responsibilities at airports where Federal Security Managers 
were designated or stationed. 

In November 2001, shortly after the terrorist attacks of September 11, 
2001, the President signed the Aviation and Transportation Security Act 
(ATSA) into law, shifting certain responsibilities for aviation 
security from air carriers to the federal government and the newly 
created TSA.[Footnote 4] Specifically, ATSA created TSA and granted it 
direct operational responsibility for, among other things, passenger 
and checked baggage screening. On February 17, 2002, pursuant to ATSA, 
TSA assumed responsibility from FAA for security at the nation's 
commercial airports, including FAA's existing aviation security 
programs, plans, contracts, regulations, orders, directives, and 
personnel.[Footnote 5] On February 22, 2002, FAA and TSA jointly 
published a final rule transferring the civil aviation security 
regulations from FAA to TSA and amending those rules to comport with 
ATSA and enhance security as required by the act. According to TSA 
officials, DOT and TSA leadership administratively changed the name of 
the Federal Security Manager to Federal Security Director to avoid 
confusion with the liaison role of the Federal Security Manager prior 
to September 11. The FSD role was more comprehensive and had 
responsibilities that included overseeing passenger and baggage 
screening. Airport operators retained responsibility for the security 
of the airport operating environment, that is, perimeter security, 
access control to secured areas, and other measures detailed in the 
approved airport security plan, while the FSD provided regulatory 
oversight over these efforts. 

FSDs report to one of five Area Directors, based on their geographic 
regions, on administrative matters. However, they report to TSA 
headquarters (the Aviation Security Program Office and Transportation 
Security Operations Center) on operational issues, such as reporting 
security incidents. FSDs are part of the Aviation Security Program 
Office within TSA's Office of Intermodal Programs, as shown in figure 
1. The Aviation Security Program Office focuses on specific functions 
related to TSA's Aviation Security Program, including staffing, 
training, and equipping the federal security work force. The 
Transportation Security Operations Center serves as a single point of 
contact for security-related operations, incidents, or crises in 
aviation and all surface modes of transportation. FSDs are to report 
any security incident at their airport immediately to the center, which 
is to provide guidance, if needed, as well as look for patterns among 
all incidents that occur throughout the country. The center provides 
FSDs daily intelligence briefings based on incident information from 
FSDs and information from TSA's Transportation Security Intelligence 
Service. The Transportation Security Intelligence Service provides 
FSDs, Deputy FSDs, and Assistant FSDs with a classified Daily 
Intelligence Summary containing the most current threat information 
from the intelligence community, law enforcement agencies, and 
stakeholders and provides the FSD staff with an unclassified TSA Field 
Intelligence Summary to be used in briefing screeners and screening 
management about current threats and other issues related to aviation 
security. 

Figure 1: Transportation Security Administration Organization Chart: 

[See PDF for image] 

[End of figure] 

TSA's Area Directors are responsible for monitoring and annually 
assessing the performance of FSDs. FSD performance is to be assessed in 
terms of successful accomplishment of organizational goals as well as 
specific performance metrics associated with aviation security within 
the FSD's area of responsibility. Area Directors are required to follow 
DHS's performance management guidance for FSDs who are part of the 
Transportation Senior Executive Service (TSES) and TSA's performance 
management guidance for FSDs who are not part of the TSES (non-TSES). 
According to TSA Human Resources officials, about one-third of the FSDs 
are part of the TSES, and they are generally assigned to larger 
airports. 

FSDs are responsible for overseeing security operations at the nation's 
commercial airports--443 airports as of January 2005--which TSA 
classifies in one of five airport security categories (X, I, II, III, 
IV).[Footnote 6] These categories are based on various factors such as 
the total number of takeoffs and landings annually, the extent to which 
passengers are screened at the airport, and other special security 
considerations. In general, category X airports have the greatest 
number of passenger boardings and category IV airports have the fewest. 
These airports can vary dramatically, not just in passenger and flight 
volume, but in other characteristics, including physical size and 
layout. Figure 2 identifies the number of commercial airports by 
airport security category, as of January 2005. 

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

[See PDF for image] 

Note: TSA periodically reviews and updates airport security categories 
to reflect current operations. We used the categories in place in 
January 2005 to conduct the above analysis. Percentages do not total 
100 because of rounding. 

[End of figure] 

TSA had 157 FSD positions at commercial airports nationwide, as of 
January 2005.[Footnote 7] Although an FSD is responsible for security 
at every commercial airport, not every airport has an FSD dedicated 
solely to that airport. Most category X airports have an FSD 
responsible for that airport alone. Other airports are arranged in a 
"hub and spoke" configuration, in which an FSD is located at or near a 
hub airport but also has responsibility over one or more spoke airports 
of the same or smaller size that are generally located in geographic 
proximity.[Footnote 8] At spoke airports, the top-ranking TSA official 
located at that airport might be a Deputy FSD, Screening Manager, or 
even Screening Supervisor, although the FSD has overall responsibility 
for the airport.[Footnote 9] Figure 3 identifies the number of FSDs 
responsible for specific numbers of airports. For example, figure 3 
shows that 44 FSDs are responsible for a single airport, 37 are 
responsible for two airports (one hub and one spoke), and 1 is 
responsible for nine airports (one hub and eight spokes). 

Figure 3: Number of FSD Positions with Responsibility for a Designated 
Number of Airports, as of January 2005: 

[See PDF for image] 

[End of figure] 

FSDs rely on their management staff to help carry out their 
responsibilities at airports, but the exact FSD management positions 
vary by airport. At larger airports, FSDs might have four Assistant 
FSDs--one for Law Enforcement, one for Regulatory Inspection, one for 
Screening, and another for Operations. However, not every FSD or 
airport has these Assistant FSD positions. Assistant FSDs for Law 
Enforcement coordinate law enforcement activities at the airport and 
often work with local Joint Terrorism Task Forces. Assistant FSDs for 
Regulatory Inspection are responsible for matters related to the 
enforcement of, and compliance with, approved security plans and 
directives pertaining to airport and aviation security. These 
responsibilities include a key function of the oversight of airport 
compliance with regulatory requirements and security measures contained 
in approved security plans and security directives. Assistant FSDs for 
Screening are responsible for passenger and baggage screening and 
managing all screener staff, and Assistant FSDs for Operations are 
responsible for managing nonscreening operations (e.g., exercise 
planning and execution, crisis management, and vulnerability 
assessments) and designated aspects of administrative support. An FSD 
responsible for a large airport may also have a Deputy FSD, and that 
position could be located at a hub airport where the FSD is located or 
at a spoke airport. Other FSD management staff positions vary by 
airport and airport size, but may include a Stakeholder Manager, 
Customer Support Manager, Training Coordinator, Human Resource 
Specialist, Financial Specialist, Scheduling Operations Officer, 
Screening Supervisors and Managers, administrative support personnel, 
as well as other positions. 

Federal Security Directors Have a Range of Responsibilities, but TSA's 
Guidance Regarding FSDs' Authority Is Unclear: 

TSA developed guidance that describes the many roles and 
responsibilities of the FSD position, most of which is associated with 
securing commercial airports from terrorist threats. However, its 
guidance addressing FSD authority is outdated and does not clearly 
describe the FSDs' authority relative to other airport stakeholders 
during a security incident. Furthermore, some of the stakeholders at 
airports we visited said that the FSDs' authority relative to others 
was not always clear during a security incident, and that the FSDs' 
authority in such cases had not been communicated to them. Most of the 
25 FSDs we interviewed by telephone said that TSA needed to do more to 
clarify the roles and responsibilities of the FSD position for the 
benefit of FSDs and stakeholders, with the majority of these FSDs 
stating that their authority needed further clarification. 

FSDs Have a Range of Responsibilities Related to Airport Security: 

The FSD is the ranking TSA authority responsible for the leadership and 
coordination of TSA security activities at the nation's commercial 
airports. As such, the FSD is responsible for providing day-to-day 
operational direction for federal security at the airport or airports 
to which the FSD is assigned. ATSA established broad authorities of the 
FSD, while specific responsibilities of the FSD are laid out in TSA 
Delegation Orders, the FSD position description, and TSA's 2004 
Executive FSD Guide,[Footnote 10] and include the following: 

Overseeing security screening of passengers, baggage, and air cargo. 
FSDs are responsible for providing direct oversight of passenger and 
baggage screening by managing the local screening force, which is 
typically composed of federal employees.[Footnote 11] To carry out this 
responsibility, FSDs engage in activities that include ensuring 
implementation of required screener-training programs, anticipating and 
preparing for training on new screening technologies and procedures, 
and developing local training initiatives to test and improve screener 
performance. In accordance with regulations, aircraft operators perform 
their own security screening of air cargo, and FSDs are responsible for 
overseeing operators' performance in implementing required security 
measures. 

Providing regulatory oversight of all U.S. air transportation 
facilities and operations. FSDs are responsible for ensuring that 
airports, airlines (foreign and domestic), air cargo carriers, and 
indirect air carriers comply with TSA regulations and security 
directives governing such things as perimeter security, access 
controls, procedures for challenging questionable identification 
documents, aircraft searches, and general security procedures.[Footnote 
12] This is accomplished through administering appropriate compliance 
and enforcement actions with the goal of discovering and correcting 
deficiencies and vulnerabilities in aviation security. FSDs oversee 
civil enforcement activities at their airports involving findings of 
noncompliance with security requirements by airlines, airports, and 
individuals, including passengers. To carry out their regulatory 
oversight responsibilities, FSDs and staff engage in activities that 
include conducting stakeholder meetings with all regulated parties to 
discuss regulatory changes or educate them on current aviation threats. 

Analyzing and addressing security threats. FSDs are responsible for 
conducting analyses of security threats and vulnerabilities in and 
around their airports. To carry out this responsibility, FSDs seek 
intelligence from sources external to TSA, build systems to analyze the 
information received from intelligence organizations and apply it to 
the local airport security, and direct TSA regulatory agents to test 
security measures and procedures and identify potential security 
weaknesses. 

Building and managing relationships with airport stakeholders. FSDs are 
responsible for building and managing relationships with local 
stakeholders (e.g., airport management, airlines, and concessionaires) 
to ensure that security operations run smoothly. To carry out this 
responsibility, FSDs engage in activities that include collaborating 
with airlines to identify and resolve issues of efficient passenger 
flow and customer service while maintaining security standards. FSDs 
also coordinate with airport and airline management; federal, state, 
and local governments; law enforcement agencies; and relevant private 
sector entities to organize and implement a Federal Security Crisis 
Management Plan at each airport. The plan is essentially a protocol for 
what TSA employees and airport stakeholders should do in the event of 
an emergency, including a terrorist incident, within the airport. 

Other FSD responsibilities include communicating information received 
from TSA headquarters to appropriate stakeholders, maintaining quality 
customer service for airlines and passengers, providing leadership to 
the TSA employee population, managing and coordinating their direct 
staff, and overseeing management of TSA facilities and equipment 
resources. In addition, TSA has directed FSDs to conduct outreach and 
liaison with the general aviation community in their areas, although it 
has not given FSDs regulatory oversight responsibility over general 
aviation airports.[Footnote 13] 

TSA's Guidance Regarding Aspects of FSDs' Authority Is Outdated, Lacks 
Clarity, and Has Not Been Adequately Communicated to Stakeholders: 

FSDs' roles and responsibilities have been fairly well documented, but 
their authority relative to other airport stakeholders during security 
incidents has not been clearly defined. Section 103 of ATSA addressed 
FSD authority at the broadest level by giving FSDs responsibility for 
overseeing the screening of passengers and property and for carrying 
out any other duties prescribed by the TSA Administrator.[Footnote 14] 
TSA's Executive FSD Guide, discussed earlier, describes FSD 
responsibilities, but it does not address the FSDs' authority in 
security incidents. That authority is addressed more specifically in 
TSA's June 2002 Delegation of Authority to Federal Security Directors 
(Delegation Order), which gives FSDs the authority to provide for 
overall security of aviation, including the security of aircraft and 
airports and related facilities to which they are assigned.[Footnote 
15] 

The Delegation Order is outdated in that it gives FSDs the authority to 
train, supervise, equip, and deploy a TSA law enforcement force that 
was never established. Officials from TSA's Aviation Security Program 
Office acknowledged that the document is outdated and has not been 
updated since FSDs were first assigned to airports. According to 
officials from TSA's Office of Law Enforcement, TSA originally 
envisioned that all FSDs would be federal law enforcement officers 
(e.g., GS-1811--criminal investigators) and would command a TSA police 
force. However, the force was never established, and FSDs were not 
given federal law enforcement status. TSA has assigned an Assistant FSD 
for Law Enforcement to about half the FSDs in the country, but this is 
the only law enforcement position on their staff. Instead, airport 
police or state or local law enforcement agencies primarily carry out 
the law enforcement function at airports.[Footnote 16] 

Furthermore, the Delegation Order does not clearly address the extent 
of FSD authority relative to other parties with responsibilities 
related to airport security, including law enforcement agencies. For 
example, the Delegation Order gives the FSD authority to clear, close, 
or otherwise secure facilities under certain circumstances, and after 
taking such action, requires the FSD to provide feedback to the airport 
operator on the reasons the security action was taken. The document 
also provides that, under certain circumstances, the FSD has the 
authority to cancel, delay, return, or divert flights and search and 
detain persons or property. However, it does not clearly address what 
authority, if any, FSDs have over other parties, such as airport law 
enforcement personnel, on which it would need to rely to take these 
actions. In August 2005, TSA officials told us that they had drafted a 
revised Delegation Order that clarified the authority of FSDs and that 
it is was being reviewed internally. They stated that the revised 
document restates some of the FSDs' previous authority and provides for 
some new ones, such as entering into interagency agreements. 

Stakeholders at some of the airports we visited told us that the FSDs' 
role, particularly regarding their authority relative to other parties, 
was not sufficiently clear, and at least one stakeholder at every 
airport we visited said such information had never been communicated to 
them. At three of the seven airports, stakeholders said that aspects of 
the FSD's authority during a security incident lacked clarity. For 
example, at two airports, confusion or conflicting opinions developed 
over whether the FSD had the authority to take certain actions during 
particular security incidents. Furthermore, six stakeholders at two of 
the airports we visited were also unclear about the FSD's authority 
regarding control over airport law enforcement personnel and canine 
teams, access to secured information, and specific operational changes. 
Additionally, at least one stakeholder at each of the seven airports we 
visited said he or she had never been briefed or given information on 
the role of the FSD. Among these stakeholders was an airport manager 
who said he had specifically sought out documents detailing the FSD's 
roles and authority, including how the FSD would fit into the airport's 
incident command system. At another airport, airport management 
officials said they had to take the initiative, in conjunction with the 
FSD and law enforcement stakeholders, to develop a matrix identifying 
first responders and the lead agency for various types of incidents 
after a potential hijacking situation highlighted the need to document 
and share such guidance. 

Several stakeholders at the national level also raised questions 
regarding the clarity of the FSD's authority relative to that of other 
parties, including FSDs' authority in particular security incidents. 
Specifically, FBI headquarters officials and representatives of two 
industry associations representing airports and airport law enforcement 
officials voiced concern about the clarity of FSDs' authority, noting 
that initially some of the first FSDs attempted to assert control over 
airport stakeholders, such as the airport police department. FBI 
headquarters officials were concerned, on the basis of past airport 
exercises, that relationships between FSDs and the FBI had not been 
explicitly delineated. Officials stated that if a conflict with local 
FBI authorities occurred during an actual security incident, it might 
create confusion and result in a longer response time. As of October 
2004, FBI headquarters officials informed us that the FBI was 
attempting to enter into a memorandum of understanding with TSA to 
clarify certain aspects of each agency's authority. TSA officials said 
that, as of August 2005, TSA and the FBI had not entered into a 
memorandum of understanding and were not able to provide us any 
additional information on this issue. 

Our telephone interviews with selected FSDs also indicated a need for a 
clearer statement of their authority. Most (18) of the 25 FSDs we 
interviewed said, to varying degrees, that TSA needed to do more to 
clarify the role and responsibilities of the FSD position--not just for 
the benefit of FSDs and their staff, but for the benefit of airport 
stakeholders as well. (These and other responses to selected questions 
we posed during our interviews with 25 FSDs are contained in app. II.) 
More specifically, when we asked those 18 FSDs what needed further 
clarification, 11 said that their authority needed to be further 
defined. Among these 11 were 6 FSDs who believed TSA should develop a 
document that delineates the authority of the position or update the 
Delegation Order. For example, FSDs told us that other agencies do not 
understand the authority of the FSD or TSA, and have asked for a 
document to be made widely available to federal agencies, state and 
local law enforcement, emergency responders, and other airport 
stakeholders. Four FSDs explained that clarification of the FSDs' 
authority is needed with respect to critical incident response. 

TSA Provided Opportunities for Some FSDs to Participate in Developing 
TSA Aviation Security Policy: 

TSA does not charge FSDs with responsibility for developing TSA 
aviation security policy. However, TSA does expect FSDs to provide 
input on draft policy from TSA headquarters when called upon and to 
recommend policies and procedures for addressing emerging or unforeseen 
security risks and policy gaps. According to TSA officials, the agency 
provides several opportunities for some FSDs to be involved in 
developing some TSA aviation security policies through the FSD Advisory 
Council, ad hoc consultation groups, and the piloting of new security 
procedures and technology. 

The FSD Advisory Council provides a mechanism for selected FSDs to be 
involved in TSA's efforts to develop aviation security policy, 
according to TSA officials. The FSD Advisory Council was originally 
established as a way for the Aviation Security Program Office to 
conduct outreach among the FSDs. However, in May 2004, the TSA 
Administrator recast the council as an advisory board reporting 
directly to him and, for the most part, responding to his agenda items. 
The council consists of 22 FSDs who the Administrator selects based on 
factors such as geographic location, airport security category, and 
strong FSD leadership, according to a TSA official responsible for 
council coordination. Most FSDs do not serve on the council for more 
than 1 year, but their term is ultimately left to the Administrator's 
discretion. Council meetings occur over a 3-day period in Washington, 
D.C., generally on a monthly basis. According to TSA officials, during 
council meetings, the FSDs provide the Administrator their opinions and 
guidance on establishing and modifying TSA policies and procedures and 
have opportunities for input in other areas. Four of the five FSDs at 
airports we visited, including two who were council members, saw the 
council as an effective way for the Administrator to gather input on 
new TSA policy initiatives and issues confronting FSDs. The fifth FSD 
commented that most of the issues discussed by the council appeared to 
be more relevant to airports larger than his. 

On occasion, some FSDs have the opportunity to provide input on draft 
TSA aviation security policy through ad hoc consultation groups 
organized by the Aviation Security Program Office, according to TSA 
officials. For instance, when TSA establishes a new standard operating 
procedure, it typically consults a selected group drawn from, perhaps, 
9 or 10 airports. These groups are ad hoc and may include different 
combinations of FSDs, FSD staff, and airport stakeholders. For example, 
TSA formed a group of FSDs, screeners, and airport and air carrier 
staff from multiple airports to address anticipated increases in the 
2004 summer travel season. According to the TSA officials, TSA 
typically consults such groups on most significant policy developments. 
However, the more urgent or sensitive a new policy, the less likely TSA 
will have time to obtain input outside of headquarters. The official 
stated that TSA does not involve every FSD in every policy it develops 
but added that he could not think of any policy in the last 6 months 
that had not involved at least some FSDs in its development. 

Participating in pilots of new technology and procedures at their 
airports is another way FSDs can be involved in developing TSA aviation 
security policy. TSA has a variety of ongoing pilot programs that it 
generally characterizes as either technology-or procedure-based. For 
example, TSA has tested and evaluated at multiple airports a technology 
pilot--the Explosive Trace Detection Portal Program--that is designed 
to analyze the air around a passenger for traces of explosive material. 
TSA's procedure-based pilots include the Registered Traveler Program, 
which identifies participating travelers through biometric identifiers, 
such as fingerprints, and helps to expedite these passengers through 
required security screening for weapons and explosives. In addition, 
TSA has piloted other program initiatives, such as its Next Generation 
Hiring Program, which TSA reported provides a more localized approach 
to screener hiring that enables FSDs to influence the hiring process 
for their airports. TSA first piloted this initiative at Boston Logan 
International Airport and gradually expanded testing to other airports, 
continuing to make changes before implementing the program nationwide. 

Not all FSDs or their airports have been involved in piloting new 
technologies and procedures. According to TSA headquarters officials, 
TSA decided to limit the airports at which it conducts these types of 
pilots to a selected group of "model" airports, although it does 
conduct pilots not involving technology or procedures at other 
airports. As such, in December 2004, in an effort to streamline the 
airport selection process for technology pilots, TSA identified 15 
airports and recommended they be used for such pilots on an ongoing 
basis.[Footnote 17] According to these officials, the selected airports 
provide diversity in geography, demographics, and baggage and materials 
to be screened. Ten of the 25 FSDs we interviewed said TSA had offered 
their airports opportunities to pilot a new program or technology 
(collectively, more than 20 such opportunities), and all of them 
subsequently participated. 

Although TSA officials told us that opportunities exist for some FSDs 
to be involved in developing TSA aviation security policy, most of the 
FSDs (21 of 25) who we interviewed characterized themselves as not 
involved in developing such policy. Three of the five FSDs at airports 
we visited suggested that TSA should consult FSDs on security policies 
before issuing them, although some noted time may not permit this on 
urgent security measures. Two of these FSDs said it would be helpful if 
TSA allowed FSDs a comment period for new policy, and another said that 
because TSA does not involve FSDs in developing policy, its weekly 
national conference calls with FSDs are filled with questions and 
discussions about new security directives. 

FSDs Formed Partnerships with Key Stakeholders and Participated in 
Communication and Coordination Efforts: 

FSDs reported they entered into these partnerships at the seven 
airports we visited, and FSDs and stakeholders stated that these 
partnerships were generally working well. Furthermore, FSDs initiated 
communication and coordination efforts with stakeholders or were 
involved in efforts already established--such as meetings and 
briefings--to address a range of issues, including airport security, 
operations, and coordination. 

TSA Views Stakeholder Partnerships with FSDs as Essential: 

As discussed earlier, TSA has given FSDs responsibility for building 
and managing relationships with airport stakeholders and has generally 
left it to the FSDs to determine how to develop effective stakeholder 
relationships. According to TSA's Executive FSD Guide, building and 
maintaining stakeholder partnerships is a major responsibility of FSDs, 
and these partnerships can create capabilities at airports where the 
sum is greater than the parts. TSA further reinforces the importance of 
FSDs' building and managing partnerships by including this activity as 
a standard rating element on their annual performance assessments. TSA 
addressed the importance of partnerships in connection with planning 
for increased passenger traffic during the summer months of 2004 in its 
best practice guide--the Aviation Partnership Support Plan.[Footnote 
18] This document recognized the need for FSDs and airport stakeholders 
to work together toward achieving security and customer service. For 
example, the plan addressed the importance of TSA and air carrier 
station managers working together to identify a process for 
communicating, handling, and destroying sensitive passenger load data, 
and it encouraged FSDs to develop formal working groups to bring 
together local stakeholders. 

According to parties at the airports we visited and TSA guidance, 
developing partnerships with airport stakeholders is essential for FSDs 
to effectively do their job. First, according to FSDs, FSD staff, and 
law enforcement stakeholders at the airports we visited, FSDs lack law 
enforcement personnel to respond to a security incident and, therefore, 
must rely on federal, state, and local law enforcement agencies in 
these instances. TSA also recognizes that, for example, FSDs would have 
to work with the FBI and other law enforcement agencies to respond to a 
security incident on an aircraft where the door has been closed for 
embarkation, because FSDs do not have the resources needed to respond 
to such an incident. Second, developing partnerships can provide 
benefits to FSDs and airport stakeholders. For example, FSDs need air 
carrier data on the number of passengers transiting airport checkpoints 
to appropriately schedule screeners. At the same time, air carriers 
seek an efficient screening process to minimize wait times for their 
customers. Various parties we interviewed, including airport 
stakeholders, BTS and FBI officials, and an industry representative, 
recognized the importance of partnerships in helping the airport 
operate smoothly. For example, one industry representative said that 
airport management needs security and threat information from the FSD, 
and the FSD needs to understand nonsecurity issues that affect the 
FSD's job, such as an upcoming local event that may increase passenger 
traffic. 

FSDs and Stakeholders Reported Partnerships Were Generally Working 
Well: 

FSDs and most of the stakeholders at the seven airports we visited said 
that they had developed partnerships, and they described these 
partnerships as generally working well. The FSDs responsible for these 
airports reported having positive partnerships with airport 
stakeholders. More specifically, one FSD said that having common goals 
with stakeholders, such as ensuring security, enhanced their 
partnerships. Another FSD saw himself as a catalyst for partnerships at 
his airport and as a facilitator among stakeholders who did not always 
get along. At most of these airports, stakeholders also reported that 
FSD-stakeholder partnerships were working well and identified examples 
of successful practices. Some spoke of the value of an FSD being 
accessible to stakeholders to help resolve problems by, for example, 
being visible at the airport and maintaining an open-door policy. Seven 
stakeholders stated that the FSDs at their airports discussed TSA 
security directives and worked with them when it was not clear how to 
interpret or implement them.[Footnote 19] At one airport, the FSD, 
airport management, and air carriers teamed together to look for 
opportunities to enhance security and customer service. To this end, 
they formed a working group and developed a proposal for TSA that 
addressed issues involving technology, infrastructure, transportation 
assets, and local budgetary control for the FSD. Finally, at another 
airport, in an effort to manage stakeholders' concerns about wait times 
and customer service, the FSD arranged for staff to help screen all of 
the airport vendors and concessionaires, as required, but at an 
established time to ensure passengers were minimally affected. 

Partnerships at airports across the country were generally working well 
or better at the time of our review than when TSA first assigned FSDs 
to airports, according to several federal agency officials and industry 
representatives at the national level. Some airport stakeholders and 
industry representatives stated that some FSDs' authoritative 
management style and lack of airport knowledge contributed to tensions 
in earlier FSD-stakeholder relationships. However, during the course of 
our review, TSA officials said they received very few complaints about 
FSDs from airport stakeholders, and industry representatives and 
officials from BTS (which oversees CBP and ICE), and the FBI said that 
partnerships were generally working well or had improved. For example, 
FBI officials had queried 27 of their Airport Liaison Agents in October 
2004 about their relationships with FSDs, and 20 of the 22 agents who 
responded characterized these relationships as generally good. FBI 
officials told us that at one airport where coordination and 
partnerships stood out as being particularly strong, the FSD met with 
stakeholders every morning. 

TSA established 80 Assistant FSD for Law Enforcement positions across 
the country to help FSDs partner and act as liaison with law 
enforcement stakeholders and to conduct certain criminal 
investigations. This position is always filled by a federal law 
enforcement officer (a criminal investigator), and is the only law 
enforcement officer assigned to an FSD. Office of Law Enforcement 
officials stated that this position is essential for interacting with 
local law enforcement stakeholders, and they would like to see every 
FSD have at least one Assistant FSD for Law Enforcement and more than 
one at larger airports. Assistant FSDs for Law Enforcement report 
directly to their respective FSDs, and at smaller airports without this 
position, the FSD takes on responsibility for coordinating with law 
enforcement stakeholders.[Footnote 20] Given the number of positions 
authorized, not all FSDs have Assistant FSDs for Law Enforcement on 
their staff. Of the 25 FSDs we interviewed, 13 reported having this 
position on their staff, and 12 reported not having this position. 
Regardless of whether these FSDs had this position, almost all (23) 
said it was important to have the position on their staff to coordinate 
with the law enforcement and intelligence community and perform 
criminal investigations.[Footnote 21] An Assistant FSD for Law 
Enforcement explained during one airport visit that his familiarity 
with legal processes and procedures facilitated his working 
relationship with the FBI and U.S. Attorneys. FBI headquarters 
officials also reported that the Assistant FSD for Law Enforcement 
position has helped improve coordination between TSA and the FBI at 
airports. TSA did not provide an agency-level position on whether every 
FSD needs an Assistant FSD for Law Enforcement. 

Although most of our contacts reported that partnerships between FSDs 
and airport stakeholders were generally working well, about half (13) 
of the 25 FSDs we interviewed said that it is challenging to foster 
partnerships with the parties they are responsible for regulating. 
Several FSDs stated that while it may be hard to partner with those one 
regulates, having good communication and relationships with 
stakeholders and a mutual understanding of the responsibility of 
regulating airport security makes such partnering possible. According 
to officials from TSA's Office of Compliance Programs, the office has 
articulated a policy of compliance through cooperation, which has 
helped FSDs foster partnerships with airport stakeholders while 
achieving TSA's regulatory oversight mission. For example, TSA 
established a Voluntary Disclosure Program that allows stakeholders to 
forgo civil penalty actions by bringing violations to the attention of 
TSA and taking prompt corrective action. The philosophy behind this 
program is that aviation security is well served by providing 
incentives to regulated parties to identify and correct their own 
instances of noncompliance and to invest more resources in efforts to 
preclude their recurrence.[Footnote 22] According to Office of 
Compliance Program officials, 75 percent of issues of noncompliance 
were closed by administrative action rather than civil enforcement 
during the past 2 fiscal years. Furthermore, in half the cases 
reported, FSDs were able to address the discovered security gaps and 
close the issue with a note to the inspection files, instead of writing 
a formal investigation report. 

At one airport we visited, not all stakeholders agreed that 
partnerships with the FSD were working well. Airport management, 
airport law enforcement, and air carriers at this airport said the FSD 
was not accessible, often did not attend meetings to which he had been 
invited, and sometimes did not send FSD staff to meetings in his place. 
These stakeholders also criticized the FSD for not distributing 
security directives and meeting to discuss their implementation. 
However, local federal stakeholders at this airport (representing the 
FBI, CBP, and ICE) said that the FSD had established positive 
partnerships with them and had communicated well. 

FSDs and Stakeholders Said They Participated in Many Communication and 
Coordination Efforts: 

According to TSA's Executive FSD Guide, FSDs are responsible for 
conducting group or one-on-one meetings with airport managers and air 
carriers. FSDs and stakeholders at all seven of the airports we visited 
told us that they were involved with these and other communication and 
coordination efforts. FSDs and stakeholders described a variety of such 
mechanisms, including meetings and training exercises, noting that many 
of these were in place before FSDs were assigned to airports. A BTS 
official explained that at larger airports, FSDs inherited coordination 
mechanisms and relationships established between federal agencies and 
other stakeholders. In contrast, at smaller airports, FSDs had to 
educate stakeholders on involving and communicating more with federal 
officials. At two of the larger airports we visited, stakeholders said 
that the FSDs initiated communication and coordination efforts on their 
own, such as holding routine intelligence briefings and meetings with 
law enforcement agencies and representatives of U.S. Attorneys' 
Offices. Aside from the more formal communication and coordination 
mechanisms, FSDs and some of the stakeholders at all seven airports we 
visited said they frequently shared information and developed 
partnerships informally through telephone calls, e-mails, and face-to- 
face interactions. 

At all of the airports we visited, FSDs and stakeholders reported that 
meetings to discuss improvements to airport security and operations and 
coordination meetings were held, although the type of participants and 
frequency of these meetings varied. FSDs and stakeholders reported that 
some of these meetings were held on a weekly, monthly, or quarterly 
basis, while others were held on an impromptu basis when FSDs or 
stakeholders had an issue to discuss. According to an FBI official, 
most of the Airport Liaison Agents they had queried were having monthly 
meetings with their FSDs. Similarly, a BTS official said that all FSDs 
had monthly meetings with representatives from other BTS agencies (ICE 
and CBP) to improve coordination of law enforcement and security 
efforts among these agencies at airports.[Footnote 23] Although five of 
the seven airports we visited had standing formal meetings, two of the 
smaller airports did not. Rather, at these airports, the FSD and 
stakeholders reported interacting daily and holding meetings on an as- 
needed basis. 

In addition to meetings, incident debriefings and training exercises to 
ensure a coordinated response in the event of a security incident were 
conducted at most of the airports we visited. Stakeholders at three of 
the airports mentioned that debriefings occurred after an actual 
incident to address questions and discuss how the incident had been 
handled. For example, at one airport, a stakeholder explained that a 
debriefing helped alleviate concerns he had regarding his lack of 
involvement during a particular incident. According to TSA, response to 
an actual event is typically only as good as the training for it; 
hence, TSA requires FSDs to hold quarterly training exercises at their 
airports. Training exercises included tabletop simulation 
exercises,[Footnote 24] hijacking scenarios, and Man Portable Air 
Defense Systems (MANPADS)[Footnote 25] vulnerability assessments to 
identify areas where a MANPADS attack could be launched. Sometimes 
protocols or security directives are written as a result of airport 
incidents and debriefings. At all seven airports we visited, protocols 
for responding to incidents existed, according to FSDs, their staff, or 
stakeholders, and at most of these airports, protocols were written 
into the Airport Security Plan. However, a TSA headquarters official 
explained that a protocol cannot exist for every possible incident, 
given that security incidents are often unique. 

TSA Made Changes to Better Support or Empower the FSD Position and Was 
Planning Additional Changes: 

TSA has made a number of changes intended to provide FSDs with more 
authority and flexibility in carrying out their responsibilities, and 
most FSDs we interviewed responded favorably to these changes. In 
addition, TSA was planning additional efforts during our review that 
could affect FSDs, and the majority of the 25 FSDs we interviewed said 
they were not involved in these efforts. 

Most FSDs We Interviewed Viewed the Changes TSA Made Favorably: 

To further support or empower the FSD position, TSA increased FSDs' 
authority to address performance and conduct problems, established a 
local hiring initiative, increased flexibility to provide screener 
training, relocated Area Director positions to the field, and 
established a report group and a mentoring program. The majority of 
FSDs we interviewed had positive views of most of these 
changes.[Footnote 26] 

Local hiring initiative. TSA developed a local screener hiring 
initiative that, among other things, vested more hiring authority with 
FSDs to address airport staffing needs. To meet a post-September 11 
statutory deadline, TSA brought a workforce of 57,000 federal screeners 
on board within 6 months using a highly centralized approach of 
recruiting, assessing, hiring, and training.[Footnote 27] With this 
accomplished, TSA began piloting a reengineered local hiring 
initiative, called Next Generation Hiring, in June 2004. Its goal was 
to ensure the involvement of FSDs and their staff in the hiring 
process, streamline the process, and make the process more responsive 
to the full range of airport needs. The program was designed to give 
FSDs and their staff the flexibility to determine which aspects, or 
phases, of local hiring they wish to participate in, and how much 
contractor support they need.[Footnote 28] TSA incorporated 
modifications as a result of lessons learned from its pilot and initial 
implementation sites as it gradually rolled out this initiative to 
additional locations. By March 2005, TSA had established 12 fully 
operational local hiring centers around the country, with locations 
based on various factors, including geography and operational need. 

When we asked all 155 FSDs in our March 2004 survey if they wanted more 
authority in selecting screeners, 136 (88 percent) said they wanted 
more authority to do this to a great or very great extent, and another 
9 percent said they wanted more authority in this area to a moderate 
extent. When we interviewed 25 FSDs during this review, approximately 1 
year after TSA began rolling out the Next Generation Hiring program, 12 
reported that they wanted more authority in selecting screeners to a 
great or very great extent, even given their participation options 
under Next Generation Hiring, and another 8 said they wanted more 
authority in this area to a moderate extent.[Footnote 29] 

Nevertheless, 18 of the 25 FSDs stated that Next Generation Hiring 
provided for their airports' screener staffing needs better than TSA's 
former hiring process to a very great, great, or moderate extent. In 
addition, 14 of the 25 FSDs stated that, overall, they were satisfied 
with the new program's ability to meet their screener staffing needs, 
but 7 said they were not satisfied.[Footnote 30] Comments from those 
dissatisfied FSDs included statements that the contractor had not done 
a good job in the recruiting aspect of the process and that the new 
hiring process still takes too long--a comment echoed by some FSDs we 
interviewed during our airport visits earlier in the program's rollout. 

TSA officials stated that the goal of Next Generation Hiring was not 
necessarily to reduce the time it takes to bring a new screener on 
board at every airport. Rather, the goal was to be more responsive to 
all local hiring needs--not just the needs of the largest airports. 
According to a program official, early data on Next Generation Hiring 
have been positive, though limited. For example, data from a 
nonscientific sample of several airports showed that under Next 
Generation Hiring, fewer screeners resigned within their first month 
than before the program was in place (about 18 percent resigned in the 
first month before Next Generation Hiring; about 7.5 percent resigned 
in the first month after the program was initiated at those airports). 
Officials also concluded, on the basis of their limited data and 
anecdotal information, that candidates selected at airports where the 
FSD and staff were conducting the hiring process were more selective in 
accepting offers because they had more knowledge of what the job would 
entail than contractors did when they handled the hiring process. 

Increased flexibility to provide screener training. TSA expanded FSDs' 
flexibility to offer training locally to screeners in two respects in 
April 2004. First, TSA developed and implemented a new basic screener 
training program to cover the technical aspects of both passenger and 
checked baggage screening, and allowed FSDs to choose whether new 
screeners would receive instruction in one or both of these screening 
functions during initial training. According to TSA officials, this 
approach provides the optimum training solution based on the specific 
needs of each airport and reflects the fact that, at some airports, the 
FSD does not need all screeners to be fully trained in both passenger 
and checked baggage screening. Second, TSA offered FSDs the flexibility 
to deliver basic screener training using either contractors or local 
TSA employees as instructors, provided they have experience as 
instructors and are approved by TSA.[Footnote 31] 

Prior to TSA providing FSDs with more training flexibility, 110 of the 
155 FSDs (71 percent) who responded to our March 2004 survey said that 
they wanted more flexibility to design and conduct local training to a 
great or very great extent.[Footnote 32] A year later, when we asked 25 
FSDs during this review about their satisfaction with the flexibility 
they had in offering training locally to screeners, 21 said they were 
satisfied. Several noted this was an area where they had seen 
improvement in the flexibility TSA had given them. 

Increased authority to address performance and conduct problems. TSA 
expanded FSDs' authority to address employee performance and conduct 
problems over time, beginning in 2003 when FSDs were delegated 
authority to suspend employees for up to 3 days. In July 2004, FSDs 
were delegated the authority to take the full range of disciplinary 
actions, including removal, in accordance with TSA policy. In September 
2004, TSA again increased the authority of FSDs by allowing them to use 
a streamlined, one-step process in taking certain disciplinary actions, 
such as the termination of employment for screeners involved in theft 
or the use of drugs or alcohol.[Footnote 33] During our telephone 
interviews with FSDs, conducted more than 6 months after the last of 
these increases in FSD authority, 24 of the 25 FSDs said they were 
satisfied with their current authority to address employee performance 
and conduct problems. Moreover, 2 of the 5 FSDs we interviewed during 
our airport visits said that their increased authority in this area was 
an important change that exemplified TSA's efforts to further empower 
FSDs. 

Relocation of Area Director positions. In September 2004, as part of an 
overall reorganization effort, TSA physically relocated its five Area 
Director positions from the Aviation Security Program Office in 
headquarters to the field. According to TSA headquarters officials, the 
goal was to move more TSA authority and decision making from 
headquarters to the field and to create efficiencies in TSA's processes 
and procedures. In making this change, TSA named five existing FSDs-- 
one in each of TSA's five geographic areas--to assume the 
responsibility of being Area Directors in addition to continuing to 
serve as FSDs of major airports. FSDs in each of the new Area 
Directors' geographic regions report to their respective Area Director 
on administrative matters. However, they report to TSA headquarters 
(the Aviation Security Program Office and Transportation Security 
Operations Center) on operational issues, such as reporting security 
incidents. To support these "dual hatted" FSDs with their additional 
Area Director responsibilities, TSA authorized each to hire five 
additional staff. 

The 25 FSDs we interviewed were divided on whether they thought having 
Area Directors in the field was helpful--12 said it was helpful and 12 
said it was not helpful--and some offered comments.[Footnote 34] On one 
hand, several FSDs said that field-based Area Directors who were also 
FSDs had a much better understanding of what FSDs encounter each day. 
On the other hand, several said that FSDs were better served by Area 
Directors located at headquarters because they were more aware of 
everything that was taking place and had more staff to support them. 
Views on this topic were also mixed among the five FSDs we interviewed 
during our airport visits. 

Two Area Directors were among the 25 FSDs we interviewed, and both 
thought the change to field-based Area Directors was helpful but 
thought that the position should be further empowered. One explained 
that the Area Directors should be involved in operational issues in 
addition to administrative matters, although he would need additional 
staff if he also had this responsibility. The other Area Director said 
that, as one of only five Area Directors, he is responsible for too 
many airports. 

Report Group.[Footnote 35] In conjunction with moving the Area Director 
positions out of headquarters, TSA established this group in September 
2004 to conduct some of the duties previously performed by Area 
Directors when at headquarters. It was also intended to provide 
operational support and a communication link between TSA headquarters 
and field-based Area Directors, and in turn, FSDs and their staff. The 
group manages and standardizes communications (including sending daily 
recaps of each day's business), continually updates point-of-contact 
lists that identified who FSDs and their staff should contact when a 
problem arises, and serves as a troubleshooter for unresolved issues. 
For example, FSDs and their staff may call the Report Group for 
assistance if they have already contacted the appropriate headquarters 
contacts and their issue or question was not resolved. 

Of the 25 FSDs we interviewed, 16 considered the Report Group to be a 
valuable resource, and 7 said they did not consider it valuable. 
Although TSA established the group just prior to our airport visits, 
FSDs we interviewed at that time saw the potential value of the group 
and noted that its daily recaps were already helpful in consolidating 
and sharing consistent information, as were the point-of-contact lists. 

Mentoring Program. TSA began offering an optional mentoring experience 
to newly appointed FSDs and Deputy FSDs in April 2004 to support their 
transition into their new positions. Under this program, mentor 
coordinators match new FSDs and Deputy FSDs (mentoring colleagues) with 
more experienced counterparts (mentors) at other airports somewhat 
comparable in size and complexity. As TSA names new FSDs and Deputies, 
the coordinators offer them a choice of prescreened volunteer mentors, 
give participants suggested steps for proceeding with the mentoring 
relationship, and provide a list of frequently asked questions and 
answers about the program. 

Only 2 of the 5 FSDs we visited and 4 of the 25 FSDs we interviewed had 
participated in the Mentoring Program--either by being a mentor or by 
being mentored--and all but one saw it as having value.[Footnote 36] 
One FSD, who had been mentored, explained that having a mentor helped 
him learn a very challenging job and provided the opportunity to bounce 
ideas off of an experienced FSD. About half (13) of the 25 FSDs said 
that they were not familiar with TSA's mentoring program. 

TSA Was Planning Additional Initiatives That Could Affect FSDs: 

At the time we interviewed FSDs, TSA was planning the following three 
additional initiatives that could affect at least some FSDs. The 
majority of the 25 FSDs we interviewed said they were not involved in 
these efforts. 

TSA's Screening Allocation Model. TSA has been developing a model for 
determining screener staffing levels after initially deploying its 
federal screener workforce in 2002 based on estimates of screeners 
performing screening functions under privatized agencies, instead of a 
model. In September 2003, in an effort to right-size and stabilize its 
screener workforce, TSA hired a consultant to conduct a study of 
screener staffing levels at the nation's commercial airports. Among 
other things, the consultant was tasked with (1) developing a 
comprehensive modeling approach with appropriate details to account for 
the considerable variability that occurs among airports, (2) creating a 
staffing analysis model to be used as a management tool to determine 
daily and weekly staffing levels and deploying the model to commercial 
airports nationwide, and (3) developing user-friendly simulation 
software to determine optimum screener staffing levels for each 
commercial airport with federal screeners. In March 2004, while 
awaiting the completion of this model, TSA established specific airport 
staffing limits to meet a congressionally mandated cap for screeners 
set at the level of 45,000 full-time-equivalent positions. In the 
summer of 2004, the model was selected, developed, and deployed for 
airport data input. That fall, TSA officials told us they expected the 
model, which was being validated with airports at the time, would 
demonstrate TSA's need for screeners beyond the mandated cap. FSDs we 
interviewed during our airport visits shared this view and the 
expectation that many airports would see increases in their screener 
allocations. In July 2005, TSA finalized and submitted to Congress its 
standards for determining aviation security staffing for all airports 
at which screening is required.[Footnote 37] 

The Screening Allocation Model does not give FSDs the authority to 
determine the number of screeners authorized for their airports, nor 
was it intended to do so. When asked if they would like to have greater 
authority in determining screener staffing levels for the airports they 
oversee, 23 of the 25 FSDs we interviewed answered that, to a great or 
very great extent, they would like greater authority. One FSD 
commented, for example, that there will always be a need for FSDs to 
have a way to adjust screener numbers and that the screener staffing 
system needs to have sufficient flexibility to address sudden changes 
in screening demands. This view was fairly consistent with what FSDs 
had said a year earlier in our March 2004 survey, when we posed the 
same question to all FSDs. At that time, 145 of 154 FSDs (94 percent) 
answered in the same way when asked if they wanted more authority in 
determining the number of screeners for their airports. 

Although TSA officials said that they had obtained a variety of data 
from FSDs during the course of the development of its Screening 
Allocation Model, not all of the FSDs we contacted saw themselves as 
having been involved in the model's development. Of the 25 FSDs we 
interviewed, 14 said that TSA had not involved them or provided them 
with the opportunity to have input into the development of the model. 
Of the 14 FSDs who said they were not involved, 11 were dissatisfied 
regarding their lack of involvement. Furthermore, among the 11 FSDs who 
said they were involved in developing the model, 5 were dissatisfied 
regarding their level of involvement.[Footnote 38] According to TSA 
officials, FSDs provided information for the model regarding their 
respective airports, and headquarters validated the numbers the model 
generated for each airport. 

Reassessments of airport hub and spoke configurations and FSD 
management staff. TSA began two related reviews in June 2004: (1) a 
reassessment of the hub and spoke configurations of commercial airports 
and (2) a reassessment of the number of management and administrative 
positions allocated to each FSD.[Footnote 39] The hub and spoke 
reassessment could result in changes to the number or the specific 
airports for which some FSDs are responsible. According to TSA 
headquarters officials, TSA undertook this reassessment because some 
FSDs had airports in more than one state, and complexities arose when 
working with multiple state laws and regulations, as well as U.S. 
Attorneys and police departments from multiple state jurisdictions. 
Officials anticipated that after TSA completes its review, a few 
situations will continue in which FSDs have responsibility for airports 
in more than one state, but only when the distance between certain 
airports necessitates. 

Related to its review of hub and spoke configurations, TSA undertook a 
reassessment of FSD management staff levels, recognizing that some 
airports--typically smaller ones--were overstaffed, while others-- 
typically larger airports--were understaffed. According to TSA 
officials, TSA initially distributed FSD staff based on the security 
classification of the airport and, to a lesser extent, the size or 
annual number of aircraft boardings. This, coupled with resource 
constraints that resulted in fewer positions being authorized than were 
needed, resulted in an imbalance in FSD staff among airports. 
Authorizations for the FSD staff positions ranged from 1 position at 
category III and IV airports with a minimum threshold of boardings, to 
16 positions at category X and large category I airports. TSA made 
decisions regarding some of these positions (e.g., whether a particular 
FSD should be assigned a Deputy FSD or an Assistant FSD for Law 
Enforcement), while FSDs were left to make decisions about other 
positions (e.g., whether to include a Training Coordinator or a Human 
Resources Specialist as one of the FSD's management staff). Although 
TSA made adjustments to some FSDs' staff levels over time, officials 
recognized that an across-the-board reassessment was needed. 

The majority of the 25 FSDs we interviewed said that they were not 
involved in either of these two reassessment efforts, and most who were 
not involved were dissatisfied with their lack of involvement. Fourteen 
of the 25 FSDs said they had not been involved in TSA's reassessment of 
airport hub and spoke configurations, and 19 of the 25 FSDs said they 
had not been involved the reassessment of FSD management staff levels. 
TSA headquarters officials said that they acknowledge the importance of 
FSDs' involvement in agency planning efforts, and when practical and 
appropriate, TSA has attempted to obtain a broad spectrum of FSD input. 
They said that in conducting these two particular reassessments, they 
formed a team that included three FSDs and three Deputy FSDs. 

Conclusions: 

For FSDs to carry out their responsibilities effectively, FSDs, their 
staff, and airport stakeholders need a clear statement of the FSDs' 
authority, relative to other stakeholders, in the event of security 
incidents. TSA's primary document outlining FSDs' authority is 
outdated, and neither it, nor other statements TSA has issued, 
delineates the authority of the FSD in various security situations 
relative to other parties. The absence of a clear understanding of the 
authority of the position has reportedly resulted in confusion during 
past security incidents and has raised concerns among some stakeholders 
at both the national and airport levels about possible ambiguity 
regarding FSDs' authority during future incidents. Updating TSA's 
Delegation of Authority to FSDs to clarify their authority relative to 
others and developing other documents, as warranted, would benefit FSDs 
by further enabling them to communicate and share consistent 
information about their authority with their staff and airport 
stakeholders, including law enforcement agencies. Stakeholders need to 
be clear on which agency has authority or lead responsibility in the 
event of various types of security incidents to reduce the likelihood 
of confusion or a delayed response. 

Recommendations for Executive Action: 

To clarify the authority of the Federal Security Director during 
various security incidents and help ensure a consistent understanding 
of the authority of FSDs among FSDs, their staff, and airport 
stakeholders, we recommend that the Secretary of Homeland Security 
direct the Assistant Secretary of Homeland Security for the 
Transportation Security Administration to take the following two 
actions: 

* update TSA's Delegation of Authority to FSDs to clearly reflect the 
authority of FSDs relative to other airport stakeholders during 
security incidents and: 

* communicate the authority of the FSD position, as warranted, to FSDs 
and all airport stakeholders. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS for its review and comment. 
On September 15, 2005, we received written comments on the draft 
report, which are reproduced in full in appendix III. DHS, in its 
written comments, generally concurred with our findings and 
recommendations, and agreed that efforts to implement these 
recommendations are critical to enable FSDs to effectively oversee 
security at the nation's commercial airports. Regarding our 
recommendation that TSA update its Delegation of Authority to FSDs and 
communicate this information to FSDs and relevant stakeholders, DHS 
stated that a new restatement of the Delegation Order has been drafted 
by a working group composed of FSDs from the FSD Advisory Council and 
the Office of Chief Counsel. The Delegation Order has a new concise 
format that restates some of the FSDs' previous authorities and 
proposes some new authorities, such as entering into interagency 
agreements and administering oaths, consistent with the evolving 
operational requirements in the field. DHS further stated that the 
Delegation Order is being internally coordinated for comment and 
clearance and will be presented for consideration of senior leadership 
and the Administrator. At that time, FSDs and airport stakeholders will 
be notified of their responsibilities under the new Delegation Order. 

TSA also provided additional technical comments on our draft report, 
which we have incorporated where appropriate. 

As agreed with your offices, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from the date of this report. At that time, we will send copies to 
appropriate congressional committees and subcommittees, the Secretary 
of Homeland Security, the Assistant Secretary of Homeland Security for 
TSA, and other interested parties. We will also make copies available 
to others upon request. In addition, the report will be available at no 
charge on GAO's Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3404 or at berrickc@gao.gov. Contact points for 
our Offices of: 

Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix IV. 

Sincerely yours, 

Signed by: 

Cathleen A. Berrick: 
Director, Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Objective, Scope, and Methodology: 

To examine the role of the Federal Security Director (FSD), we 
addressed the following questions: (1) What are the roles and the 
responsibilities of FSDs and how clear is their authority relative to 
that of other airport stakeholders during security incidents? (2) To 
what extent are FSDs involved in the development of federal aviation 
security policy? (3) How have FSDs at selected airports formed and 
facilitated partnerships with airport stakeholders, and how are these 
partnerships working? (4) What key changes has the Transportation 
Security Administration (TSA) made or planned to make to better support 
or empower the FSD position, and how have selected FSDs viewed these 
efforts? 

To address aspects of each of these objectives, we interviewed TSA's 
Chief Operating Officer and other TSA officials from headquarters 
offices, including the Aviation Security Program Office, Office of Law 
Enforcement, Office of Compliance Programs, and Office of Human 
Resources. We reviewed the Aviation and Transportation Security Act, 
and other relevant laws, as well as TSA documents related to the FSD 
position, including delegations of authority, position descriptions, 
the Executive FSD Guide, performance management guidance, and the FSD 
Advisory Council Charter. We also reviewed TSA documents related to its 
recent operational changes, such as the Next Generation Hiring Guide, 
Communication Liaison Group Mission Statement,[Footnote 40] and the TSA 
Management Directive on Addressing Performance and Conduct Problems. We 
met with Department of Homeland Security (DHS) headquarters officials 
from the Border and Transportation Security Directorate, which oversees 
TSA, and Counter-Terrorism Division and Criminal Investigations 
Division officials within the Federal Bureau of Investigation (FBI) 
headquarters. To address all but the fourth objective, we also met with 
representatives of four national associations--the American Association 
of Airport Executives, Airports Council International, Air Transport 
Association, and Airport Law Enforcement Agencies Network. [Footnote 
41] 

In addition, to address all of this report's objectives, we conducted 
field visits to seven airports. We selected these airports because they 
were close to our staff and incorporated all five airport security 
categories--three airports with an FSD dedicated to a single airport 
and two sets of airports where the FSD was responsible for at least two 
airports. Specifically, we visited three category X airports (Los 
Angeles International Airport, California; Washington Dulles 
International Airport, Virginia; and Ronald Reagan Washington National 
Airport, Virginia); Bob Hope Airport, California (category I); Long 
Beach-Daugherty Field Airport, California (category II); 
Charlottesville-Albemarle Airport, Virginia (category III); and 
Shenandoah Valley Airport, Virginia (category IV). 

At each airport we visited, we met with local TSA officials and key 
airport stakeholders to discuss the role of the FSD and FSD-stakeholder 
partnerships and communication mechanisms. We met with the FSD (at the 
three airports with dedicated FSDs and the two hub airports) or the top-
ranking TSA official (at the two spoke airports), as well as the 
Assistant FSDs for Law Enforcement and Regulatory Inspection, where 
these positions existed. During our meetings with FSDs, we also 
obtained their views on changes TSA had made or planned to make to 
enhance the FSD position. We also met with key airport stakeholders, 
including airport managers, airport law enforcement officials, station 
managers representing selected air carriers (15 representatives of 12 
air carriers and, additionally, two air carrier representative groups 
specific to two airports we visited), and FBI Airport Liaison Agents 
and officials from DHS's Customs and Border Protection as well as 
Immigration and Customs Enforcement (at the two international airports 
we visited). At each airport, we conducted a single joint interview 
with representatives from multiple air carriers, and we selected air 
carriers through different means. At airports with an air carrier 
council, we asked the council head to identify approximately three 
carriers. Although we left the final decision to the council head, we 
suggested that he or she include the largest or one of the largest 
carriers (according to the percentage of the airport's passenger 
travel) at the airport, an independent air carrier, and an 
international carrier, if it was an international airport. At airports 
without an air carrier council, the Air Transport Association or the 
airport operator recommended the air carriers. At the smallest 
airports, we met with all air carriers because of the small numbers. 
Because we selected a nonprobability sample of airports to visit, the 
information we obtained during these visits cannot be generalized to 
all airports or FSDs across the nation. 

To corroborate what we learned from the five FSDs during our field 
visits, we telephoned 25 additional FSDs to obtain their views on a 
range of topics including recent TSA initiatives and federal aviation 
security policy. We also included selected questions--regarding their 
need for greater authority and flexibility--that we had posed in our 
March 2004 Web-based survey of all 155 FSDs, conducted to support other 
GAO aviation security reviews. This allowed us to make a rough 
comparison between the 2004 responses and 2005 responses to these 
questions. We selected a random sample of FSDs in place since September 
1, 2004, to ensure they had an experience base from which to answer our 
questions.[Footnote 42] We excluded from the list the five FSDs we 
interviewed during our airport visits and individuals who were no 
longer FSDs.[Footnote 43] TSA reviewed our selection procedures but did 
not know the identities of the specific 25 FSDs we interviewed. The 25 
FSDs were from a cross section of all five airport security categories. 
A GAO survey specialist who was involved in designing the Web-based 
survey, along with GAO staff knowledgeable about issues facing FSDs 
developed the structured telephone interview instrument. We conducted 
pretest interviews with 3 FSDs to ensure that the questions were clear 
and concise, and subsequently conducted the 25 telephone interviews 
from late April to early May 2005. Although the telephone interviews 
were conducted with a random sample of FSDs, the sample is too small to 
generalize the interview results to all FSDs across the nation with 
reliable statistical precision. 

The practical difficulties of conducting interviews may introduce 
errors, commonly referred to as nonsampling errors. For example, 
difficulties in how a particular question is interpreted, in the 
sources of information that are available to respondents, or in how the 
data were analyzed can introduce unwanted variability into the results. 
We took steps in the development of the questions, the data collection, 
and the data analysis to minimize these nonsampling errors. For 
example, a survey specialist helped develop the interview questions in 
collaboration with GAO staff with subject matter expertise. Then, as 
mentioned earlier, the draft questions were pretested to ensure that 
the questions were relevant, clearly stated, and easy to comprehend. 
Interviews were conducted by GAO staff familiar with the subject matter 
and proper interviewing procedures. Finally, when the data were 
analyzed, a second, independent analyst checked to make sure that the 
results were correct. 

We conducted our work from August 2004 through September 2005 in 
accordance with generally accepted government auditing standards. 

[End of section] 

Appendix II: Responses to Selected Questions from Interviews with 25 
Federal Security Directors: 

Note. GAO interviewers did not read "no opinion" or "don't know" 
response options to respondents, however they recorded these responses 
when provided. Interviewers informed respondents that if they had any 
comments to any question, the interviewer would record the comment. 

1. To what extent, if at all, do you need or would you like to have 
greater authority in determining the number of screeners to better 
address airport specific staffing or security needs at the airport(s) 
you oversee? 

Very great extent: 14; 
Great extent: 9; 
Moderate extent: 1; 
Some or little extent: 1; 
No extent: 0. 

2. Did TSA involve you or provide you any opportunity to have input 
into the development of the REGAL screener staffing model? 

Yes: 11; 
No: 14. 

3. How satisfied are you with that involvement? Would you say you are: 

Very satisfied: 4; 
Generally satisfied: 5; 
Not satisfied: 16. 

4. In your opinion, to what extent, if at all, does the Next Generation 
Hiring program provide for your airport(s)'s screener staffing needs 
better than TSA's former hiring process? 

Very great extent: 3. 
Great extent: 7. 
Moderate extent: 8. 
Some or little extent: 2. 
No extent: 4. 
No opinion: 1. 

5. Overall, how satisfied are you with Next Generation Hiring's ability 
to meet your airport's screener staffing needs? Would you say you are: 

Very satisfied: 4. 
Generally satisfied: 10. 
Not satisfied: 7. 
No opinion: 4. 

6. Given the options FSDs have for participating in the selection of 
screeners under Next Generation Hiring, to what extent, if at all, do 
you need or would you like to have greater authority in the selection 
of screeners in order to better address airport specific staffing or 
security needs at the airport(s) that you oversee? 

Very great extent: 7; 
Great extent: 5; 
Moderate extent: 8; 
Some or little extent: 1; 
No extent: 3; 
No opinion: 1. 

7. Did you participate in TSA's orientation program for new FSDs? 

Yes: 23; 
No (Skip to Question 9): 2. 

8. How valuable do you think this orientation program was in preparing 
you for your duties as an FSD? Would you say it was: 

Very valuable: 10. 
Generally valuable: 12. 
Not valuable: 1. 

9. With the exception of the orientation program that you may have 
attended, has TSA provided you any additional or follow-up training? 

Yes: 15; 
No: 10. 

10. In your opinion, does TSA need to provide additional training to 
either new or experienced FSDs to help them do their job more 
effectively? 

Yes: 23; 
No (Skip to Question 12): 2. 

11. In what areas does TSA need to provide more training to FSDs? [NOTE 
1] (Respondents could provide more than one response.) 

Regulatory Matters: 11. 
Human Resources: 10. 
Depends on the FSD's Background: 6. 
Leadership: 6. 
General Management: 5. 
FSD Roles and Responsibilities: 3. 
Aviation Industry: 2. 
Technical Training on Equipment: 2. 

[1] This was an open-ended question; respondents were not provided 
response categories. 

12. How involved have you been in TSA's effort to reassess hub and 
spoke configurations of airports across the country? Would you say you 
have been: 

Very involved: 6; 
Generally involved: 5; 
Not involved: 14. 

13. How satisfied are you with that level of involvement? Would you say 
you are: 

Very satisfied: 6. 
Generally satisfied: 6. 
Not satisfied: 12. 
No opinion: 1; 

14. Given your airport's security needs, would you say that the current 
number of FSD management positions TSA has allocated to you is: 

More than adequate: 1. 
Adequate: 17. 
Not adequate: 7. 

15. How involved have you been in TSA's effort to reassess the number 
of management positions each FSD should be allocated? Would you say you 
have been: 

Very involved: 3; 
Generally involved: 3; 
Not involved: 19. 

16. How satisfied are you with that level of involvement? Would you say 
you are: 

Very satisfied: 1; 
Generally satisfied: 6; 
Not satisfied: 17; 
No opinion: 1. 

17. Do you currently have an 1811 (that is, a criminal investigator) on 
your FSD management staff? 

Yes: 13; 
No: 12. 

18. Regardless of whether you currently have an 1811, how important do 
you think it is to have an 1811 on your staff to support your airport's 
security needs? Would you say it is: 

Very important: 19; 
Generally important: 4; 
Not important (Skip to Question 20): 2. 

19. Please respond to the following questions: 

a. How important is it to you to have an 1811 on your staff to 
facilitate communication and/or coordination with the law enforcement 
and/or Intelligence community? 
Very important: 20; 
Generally important: 3; 
Not important: 0. 

b. How important is it to you to have an 1811 on your staff to perform 
the duties of a criminal investigator? 
Very important: 16; 
Generally important: 7; 
Not important: 0. 

[End of table] 

20. In your opinion, how helpful is it having TSA Area Directors 
located in the field rather than in headquarters? Would you say it is: 

Very helpful: 8; 
Generally helpful: 4; 
Not helpful: 12; 
No opinion: 1. 

21. How valuable a resource do you think TSA's Report Group, previously 
named the Communication Liaison Group, is for FSDs? Would you say it 
is: 

Very valuable: 2; 
Generally valuable: 14; 
Not valuable: 7; 
No opinion: 2. 

22. Which of the following statements best describes your familiarity 
with TSA's mentoring program for new FSDs and Deputy FSDs? 

I am familiar with it and have been a mentor: 1; 
I am familiar with it and have been a mentee: 3; 
I am familiar with it, but have not been a participant: 8; 
I am not familiar with it (Skip to Question 24): 13. 

23. In your opinion, how valuable is the mentoring program in preparing 
new FSDs or Deputy FSDs for their roles? Would you say it's: 

Very valuable: 6; 
Generally valuable: 4; 
Not valuable: 1; 
No opinion: 1. 

24. How satisfied are you with your current authority to take 
disciplinary or adverse actions to address employee performance or 
conduct problems? Would you say you are: 

Very satisfied: 11; 
Generally satisfied: 13; 
Not satisfied: 1. 

25. How satisfied are you with the flexibility TSA has given you to 
offer training locally to your screeners? 

Very satisfied: 9; 
Generally satisfied: 12; 
Not satisfied: 3; 
No opinion: 1. 

26. To what extent, if at all, do you think TSA needs to do more to 
clarify the role and responsibilities of the FSD position? 

Very great extent: 3; 
Great extent: 8; 
Moderate extent: 5; 
Some or little extent: 2; 
No extent (Skip to Question 29): 7. 

27. What do you think needs further clarification? (See page 18 of this 
report for a discussion of the responses received.) 

28. Who would need that clarification? (Respondents could provide more 
than one response.) 

FSDs: 16; 
FSD management staff: 16; 
airport stakeholders: 16; 
Other: 10. 

29. To what extent, if at all, do the demands of screening keep you 
from focusing on other significant aspects of airport security as much 
as you would like? 

Very great extent: 1; 
Great extent: 2; 
Moderate extent: 6; 
Some or little extent: 6; 
No extent + (Skip to Question 31): 10. 

30. In your opinion, how challenging, if at all, is it to develop 
partnerships with stakeholders you regulate? Would you say it's: 

Very challenging: 2; 
Generally challenging: 11; 
Not challenging: 12. 

31. Given FSDs' responsibilities for ensuring airport security, how 
adequately do you think TSA headquarters has focused on its regulatory 
oversight mission? Would you say it's been: 

More than adequate: 1; 
Adequate: 17; 
Not adequate: 7. 

32. Has TSA ever offered any of your airports the opportunity to pilot 
a new program or technology? 

Yes: 10; 
No: 14; 
Don't know: 1. 

33. Have any of your airports ever participated in a TSA pilot of a new 
program or technology? 

Yes: 10; 
No (Skip to Question 35): 14; 
Don't know (Skip to Question 35): 1. 

34. Overall, how satisfied have you been with the level of involvement 
you've had in evaluating this pilot program or technology? Would you 
say you have been: 

Very satisfied: 8; 
Generally satisfied: 1; 
Not satisfied: 1. 

35. Overall, how satisfied have you been with your airport's level of 
involvement in piloting new TSA programs or technologies? Would you say 
you have been: 

Very satisfied: 4; 
Generally satisfied: 10; 
Not satisfied: 8; 
No opinion: 3. 

36. Overall, how involved have you been as an FSD in developing federal 
airport security policy? Would you say that you've been: 

Very involved: 1; 
Generally involved: 3; 
Not involved: 21. 

37. How satisfied are you with that level of involvement? Would you say 
you are: 

Very satisfied: 1; 
Generally satisfied: 8; 
Not satisfied: 16. 

38. How often, if ever, do you think that TSA security policies, as 
they are initially issued, need clarification? 

Most of the time: 7; 
Sometimes: 15; 
Never (Skip to Question 40): 3. 

39. More specifically, which types of security policies-security 
directives, policy directives, and/or standard operating procedures-
need clarification at times? For each type, please tell me if you think 
they need clarification. (Respondents could provide more than one 
response): 

Security Directives: 19; 
Policy Directives: 12; 
Standard Operating Procedures: 19; 
Other: 0. 

40. At your airport(s), how often, if ever, do you find that it is not 
feasible to implement TSA security policies as they are initially 
issued? 

Most of the time: 0; 
Sometimes: 7; 
Never (Skip to Question 42): 18. 

41. More specifically, which types of security policies-security 
directives, policy directives, and/or standard operating procedures-
are not feasible to implement at times. (Respondents could provide more 
than one response.) 

Security Directives: 5; 
Policy Directives: 3; 
Standard Operating Procedures: 5; 
Other: 0. 

42. When questions arise, how satisfied are you with TSA's efforts to 
clarify security policy? 

Very satisfied: 4; 
Generally satisfied: 19; 
Not satisfied: 2. 

[End of section] 

Appendix III: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

September 15, 2005: 

Ms. Cathleen Berrick: 
Director, Homeland Security & Justice Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Berrick: 

RE: Draft Report GAO-05-935, Transportation Security Administration: 
More Clarity on the Authority of Federal Security Directors Is Needed. 

Thank you for the opportunity to comment on the subject draft report. 
The Department of Homeland Security (DHS) appreciates the work done to 
identify areas for improvement in the Transportation Security 
Administration's (TSA's) review of Federal Security Directors roles and 
responsibilities. We generally concur with the report and its 
recommendations and appreciate the discussion of challenges, and 
related on-going and planned work designed to fully meet our 
responsibilities. 

The report acknowledges the substantial progress TSA has made to better 
support and empower the Federal Security Director position through 
increased communication and coordination efforts. To clarify the 
authority of the Federal Security Director during various security 
incidents and help ensure a consistent understanding of this authority, 
GAO recommends that "the Secretary of Homeland Security direct TSA to 
update its Delegation of Authority to FSDs and communicate this 
information to FSDs and airport stakeholders". DHS agrees that efforts 
to implement these recommendations are critical to enable Federal 
Security Director's to effectively oversee security at the nation's 
commercial airports. 

TSA already has initiated efforts to revise and update the Delegation 
of Authority for the Federal Security Directors. A new restatement of 
the FSD Delegation has been drafted by a working group composed of FSDs 
from the Advisory Council and the Office of Chief Counsel. The 
Delegation has a new concise format that restates some of the FSDs 
previous authorities and proposes some new authorities (e.g., inter- 
agency agreements, administering oaths, etc.) consistent with the 
evolving operational requirements in the field. The Delegation is being 
internally coordinated for comment and clearance. The Delegation will 
be presented for consideration of senior leadership and the 
Administrator. 

At that time, FSDs and airport stakeholders will be notified of their 
responsibilities under the new Delegation. 

In summary, DHS appreciates your review of the roles and 
responsibilities of Federal Security Directors and thanks you for the 
thorough analysis and discussion that comprises this report. We 
continue to be cognizant of the areas upon which we can improve. 

Sincerely, 

Steven J. Pecinovsky: 
Director: 
Departmental GAO/OIG Liaison Office: 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Cathleen A. Berrick, (202) 512-8777 or berrickc@gao.gov: 

Acknowledgments: 

In addition to the contact mentioned above, Glenn Davis, Assistant 
Director; David Alexander; Grace Coleman; Tracey Cross; Wayne Ekblad; 
David Hancock; Stuart Kaufman; Janice Latimer; Thomas Lombardi; and 
Lori Weiss made key contributions to this report. 

FOOTNOTES 

[1] BTS, one of five operational directorates within DHS, is tasked 
with securing the nation's borders and safeguarding its transportation 
infrastructure. TSA is part of the BTS organization. As part of his 
July 2005 announcement to reorganize the department, the Secretary of 
DHS proposed the dissolution of BTS, pending the enactment of 
legislation to effect this change. 

[2] TSA classifies commercial airports in five airport security 
categories based on factors such as the number of takeoffs and 
landings, the extent of passenger screening, and other security 
considerations. 

[3] Aviation Security Improvement Act of 1990, Pub. L. No. 101-604, § 
104, 104 Stat. 3066, 3070-71. 

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

[5] ATSA created TSA as an agency within the Department of 
Transportation. The Homeland Security Act of 2002, Pub. L. No.107-296, 
116 Stat 2135, enacted in November 2002, transferred TSA to the newly 
created Department of Homeland Security, where TSA presently resides as 
a distinct entity within the Border and Transportation Security 
Directorate. 

[6] According to TSA, the total number of commercial airports regulated 
for security in the United States varies depending on various factors 
such as the type and level of commercial operations that an aircraft 
operator conducts at that particular airport, the time of year or 
season where a particular airport is located, and the economic 
stability of that airport's region. 

[7] The number of FSDs was based on the most current list TSA had at 
the time of our review. 

[8] In contrast to how TSA uses the terms "hub airport" and "hub and 
spoke," airlines refer to an airline hub as an airport that an airline 
uses as a transfer point to get passengers to their intended 
destination. It is part of a hub and spoke model, where travelers 
moving between airports not served by direct flights change planes en 
route to their destination. 

[9] A Screening Manager is responsible for individuals at screening 
checkpoints and maintains communication with supervisors regarding any 
issues that might reveal a weakness or vulnerable area of security 
screening that is discovered during the course of screening duties. A 
Screening Supervisor is responsible for supervising personnel 
performing preboard security screening of persons and their carry-on 
and checked baggage. 

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

[11] As of August 2005, five airports rely on a private screening 
contractor instead of a federal TSA screening force, and two additional 
airports have applied to TSA to use private screeners. Section 108 of 
ATSA required TSA to establish a pilot program permitting a small 
number of commercial airports to use private screening contractors to 
conduct passenger and baggage screening operations rather than federal 
screeners. Beginning on November 19, 2004, all commercial airports with 
federal security screening became eligible to apply to opt out of using 
federal screeners through the Screening Partnership Program. According 
to TSA guidance, the FSD at a privately screened airport would not have 
direct administrative control over the screening workforce but would 
still be responsible for overall security at the airport. For more 
information see GAO, Aviation Security: Preliminary Observations on 
TSA's Progress to Allow Airports to Use Private Passenger and Baggage 
Screening Services, GAO-05-126 (Washington, D.C.: Nov. 19, 2004). 

[12] Indirect air carriers, sometimes referred to as freight 
forwarders, consolidate cargo shipments and deliver them to air 
carriers and cargo facilities of passenger and all-cargo air carriers 
that store cargo until it is placed aboard an aircraft. 

[13] General aviation includes a wide range of on-demand activities 
such as pilot training, flying for business and personal reasons, 
delivery of emergency medical services, and sightseeing. Most of the 
responsibility for determining vulnerabilities and enhancing security 
at general aviation airports lies with airport operators. For more 
information on TSA activities related to general aviation, see GAO, 
General Aviation Security: Increased Federal Oversight Is Needed, but 
Continued Partnership with the Private Sector Is Critical to Long-Term 
Success, GAO-05-144 (Washington, D.C.: Nov. 10, 2004). 

[14] Pursuant to ATSA, the head of TSA was referred to as the Under 
Secretary of Transportation for Security. Since TSA transferred to DHS, 
the head of TSA is now referred to as the Assistant Secretary of 
Homeland Security for TSA. This position is also referred to as the TSA 
Administrator. 

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

[16] Some airports have their own independent airport police forces; 
others rely on state and city police forces. Still others have 
contractual agreements for airport security with local sheriff's 
departments. 

[17] TSA may add other airports to its recommended model airport list 
on a case-by-case basis on the recommendation of the Assistant 
Administrator for Aviation Security Programs. 

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

[19] According to TSA officials, FSDs are responsible for ensuring 
affected parties receive security directives, but they do not expect 
FSDs to hand-deliver every security directive to every stakeholder. 

[20] According to TSA Office of Law Enforcement officials, if a 
specific need should arise at an airport without an Assistant FSD for 
Law Enforcement, the Office of Law Enforcement will instruct the 
nearest Assistant FSD for Law Enforcement to respond to the situation. 

[21] About half (13) of the 25 FSDs said they had a criminal 
investigator as part of their management staff (when FSDs have criminal 
investigators on their staff, they hold the position of an Assistant 
FSD for Law Enforcement), and all of those FSDs considered this 
position to be important in addressing their airports' security needs-
-12 of the 13 considered it very important--and several added that they 
needed more than one of these positions on their staff. In addition, 10 
of the 12 FSDs who did not have this position on their staff considered 
it a position that would be important in supporting their airports' 
security needs. 

[22] TSA's voluntary disclosure policy directive relates to information 
and guidance that may be used by aircraft operators (except 
individuals), indirect air carriers, foreign air carriers, airports, 
and flight training providers when voluntarily disclosing to TSA 
apparent violations of TSA regulations (applicable regulations include 
49 C.F.R. parts 1542, 1544, 1546, 1548, and 1552). The TSA Voluntary 
Disclosure program does not apply to violations or apparent violations 
committed by individuals serving as agents of covered regulated 
entities. 

[23] In August 2004, the Under Secretary of BTS directed all DHS 
agencies with an airport presence to establish a formal committee to 
ensure that senior operational managers were communicating across 
agency lines and fully coordinating law enforcement and security 
efforts. The FSD was tasked with coordinating the establishment of 
these committees. 

[24] A tabletop exercise is a focused practice activity that places the 
participants in a simulated situation requiring them to function in the 
capacity that would be expected of them in a real event. Its purpose is 
to promote preparedness by testing policies and plans and by training 
personnel. 

[25] MANPADS are shoulder-launched surface-to-air guided missiles that 
are accurate, concealable, transportable, and designed to be user- 
friendly. DHS, in partnership with other federal agencies, is working 
to counter the threat of MANPADS to civilian commercial aircraft. As 
part of its overall MANPADS strategy, TSA is performing airport 
vulnerability assessments to identify and map the areas around an 
airport from which a MANPADS attack could be initiated, and it is 
working with surrounding communities to coordinate the efforts of 
agencies responsible for responding to this type of threat. 

[26] Some of the changes we discussed with FSDs during airport visits 
had just recently been implemented by TSA. 

[27] We previously reported that TSA's hiring process hindered the 
ability of some FSDs to adequately staff passenger and baggage 
screening checkpoints. See GAO, Aviation Security: Challenges Exist in 
Stabilizing and Enhancing Passenger and Baggage Screening Operations, 
GAO-04-440T (Washington, D.C.: Feb. 12, 2004). 

[28] For each of the three basic phases of hiring (recruiting, 
interviewing, and job offer and acceptance), FSDs may choose whether 
they want to conduct the phase primarily on their own, work in 
partnership with the TSA contractor, or turn the execution over to the 
contractor. Joint execution is not an option for the third phase--job 
offer and orientation. 

[29] Of the 25 FSDs we interviewed in the spring of 2005 as part of 
this review, 21 had responded to our Web-based survey of all FSDs, 
which we conducted in March 2004 as part of other GAO reviews. 

[30] The remaining 4 FSDs said they had no opinion on this issue. 

[31] For local employees to be approved as instructors by TSA, they 
must be nominated by an FSD and have a current or prior instructor 
certification by a recognized training and development organization or 
have at least 2 years of experience as an instructor. In addition, 
local TSA instructors must have successfully completed the course of 
instruction they will be teaching and demonstrate instructional skills 
by assisting a TSA-approved instructor in classroom instruction and 
monitoring actual classroom instruction. We reported this and other 
information related to TSA screener training and performance issues in 
GAO, Aviation Security: Screener Training and Performance Measurement 
Strengthened, but More Work Remains, GAO-05-457 (Washington, D.C: May 
2, 2005). 

[32] The question posed in that survey asked FSDs about their need for 
more flexibility to design and conduct local training and did not 
specify screener training. 

[33] In addition, the one-step process may be used to suspend screener 
personnel for 3 days or less; suspend, remove, or reduce pay band or 
rate of pay for any employee serving a trial period; and to 
indefinitely suspend screeners for serious misconduct that necessitates 
immediate action under certain designated conditions. All indefinite 
suspensions must be reviewed for legal sufficiency by a TSA counsel and 
may be coordinated with a designated Employee Relations Specialist 
prior to issuance. 

[34] One FSD had no opinion. 

[35] This group was named the Communications Liaison Group when it was 
initially established in September 2004 and was later renamed the 
Report Group. When established, the group was composed of former Area 
Directors and their staff. 

[36] Of the 25 FSDs we interviewed by telephone, only 4 were named FSDs 
after TSA established the Mentoring Program. 

[37] The Intelligence Reform and Terrorism Prevention Act of 2004, Pub. 
L. No. 108-458, 118 Stat. 3638, required TSA to develop and submit, to 
the Committee on Commerce, Science and Transportation of the Senate and 
the Committee on Transportation and Infrastructure of the House of 
Representatives, standards for determining aviation security staffing 
at commercial airports no later than 90 days after December 17, 2004, 
the date of the act's enactment, and GAO to conduct an analysis of 
these standards. TSA's submission of its Report to Congress--Aviation 
Security Staffing Standards--constituted TSA's submission to meet this 
reporting requirement of the law. 

[38] Ten of the 25 FSDs pointed out that the model, as modified, 
functions under a 45,000 screener cap, which is too low and does not 
take into account real-life factors such as screener vacation time, 
military time, training time, or sick leave. As a result, according to 
one FSD, security lines are longer and service is poorer. 

[39] According to TSA officials, the hub and spoke reconfigurations and 
new FSD staffing numbers were rolled out to the field in late July 
2005--about 1 year after TSA began the reassessment and several months 
after we conducted telephone interviews with FSDs. 

[40] The Communications Liaison Group was subsequently renamed the 
Report Group, but the original mission statement remained in effect. 

[41] The American Association of Airport Executives, which represents 
over 800 airports (mostly domestic) and has approximately 4,000 
members, works to shape federal policy governing aviation and ensure 
that the airport perspective is included as legislation and regulations 
are developed. The Airports Council International, with 567 members 
operating over 1,540 airports in 175 countries and territories, is an 
international association of airports whose primary purpose is to 
advance the interests of airports and to promote professional 
excellence in airport management and operations. The Air Transport 
Association is the only trade association of principal U.S. airlines. 
Among other things, it works with its members to support measures that 
enhance airport safety and security. The Airport Law Enforcement 
Agencies Network is composed of domestic and foreign airport law 
enforcement agencies, or port authorities and their associated national 
law enforcement, regulatory, or intelligence agencies. Its mandates 
include facilitating the exchange of information concerning airport- 
related crimes among member agencies and providing insight and 
experience to governmental agencies. 

[42] Twenty-one of the 25 FSDs we interviewed had responded to our 
March 2004 survey of all FSDs. Twenty of the 21 FSDs were named as FSDs 
in 2002, and the other 1 became an FSD in 2003. The 4 FSDs who were not 
included in the March 2004 survey were not named as FSDs until later in 
2004, after we conducted the initial survey. 

[43] We based our sample on a September 2004 list of FSDs. We 
subsequently updated this list based on our review of TSA press 
releases of new FSD assignments made from September 2004 through March 
2005, and then verified our revised list with TSA for accuracy and 
completeness before drawing our sample of FSDs. 

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