Posted on 02/21/2006 6:11:34 PM PST by snowsislander
The Maritime Transportation Security Act of 2002, as implemented by the Coast Guard, calls for owners and operators of about 3,150 port facilities (such as shipping terminals or factories with hazardous materials) and about 9,200 vessels (such as cargo ships, ferries, and tugs and barges) to develop and implement security plans by July 1, 2004. The Coast Guard intends to conduct on-site compliance inspections of all facilities by January 1, 2005, and all vessels by July 1, 2005, to ensure plans are adequately implemented. The Coast Guard estimated the act's security improvements would cost $7.3 billion over 10 years -- most of it borne by facility and vessel owners and operators. GAO was asked to assess (1) the progress towards developing, reviewing, and approving plans by July 1, 2004, (2) the Coast Guard's monitoring and oversight strategy for ensuring that plans are implemented, and (3) the accuracy of the Coast Guard's cost estimate.
Owners and operators have made progress in developing security plans for their port facilities and vessels. However, the extent to which the Coast Guard will have reviewed and approved the approximately 12,300 individual plans by July 1, 2004, varies considerably. About 5,900 plans were being developed under an option allowing owners and operators to self-certify that they would develop and implement plans by July 1, using industry-developed, Coast Guard-approved standards and templates. These individual plans will not be reviewed before July 1 unless owners or operators choose to submit them for review. The remaining 6,400 plans went through a review process established by the Coast Guard. Every plan required revisions, some of which were significant. As of June 2004 -- 1 month before the deadline for implementation -- more than half of the 6,400 plans were still in process. The Coast Guard took steps to speed up the process and to allow facilities and vessels to continue operating with less than full plan approval after July 1, as long as the Coast Guard was satisfied with their progress. The Coast Guard's strategy for monitoring and overseeing security plan implementation will face numerous challenges. Whether the Coast Guard will be able to conduct timely on-site compliance inspections of all facilities and vessels is uncertain because questions remain about whether the Coast Guard will have enough inspectors; a training program sufficient to overcome major differences in experience levels; and adequate guidance to help inspectors conduct thorough, consistent reviews. Another challenge is to ensure inspections reflect assessments of the normal course of business at facilities and aboard vessels. The accuracy of the Coast Guard's $7.3 billion estimate for implementing security improvements is likewise uncertain. The estimate, while a goodfaith effort on the Coast Guard's part, is based on limited data and on assumptions that are subject to error. The estimate should be viewed more as a rough indicator than a precise measure of costs.
GAO recommends that the Coast Guard evaluate its initial compliance efforts and use them to strengthen the compliance process for its long-term strategy. As part of this strategy, the Coast Guard should clearly define inspector qualifications and consider including unscheduled and unannounced inspections and covert testing. The Coast Guard agreed.
Owners and operators have made progress in developing security plans for their port facilities and vessels. However, the extent to which the Coast Guard will have reviewed and approved the approximately 12,300 individual plans by July 1, 2004, varies considerably. About 5,900 plans were being developed under an option allowing owners and operators to self-certify that they would develop and implement plans by July 1, using industrydeveloped, Coast Guard-approved standards and templates. These individual plans will not be reviewed before July 1 unless owners or operators choose to submit them for review. The remaining 6,400 plans went through a review process established by the Coast Guard. Every plan required revisions, some of which were significant. As of June 2004 -- 1 month before the deadline for implementation -- more than half of the 6,400 plans were still in process. The Coast Guard took steps to speed up the process and to allow facilities and vessels to continue operating with less than full plan approval after July 1, as long as the Coast Guard was satisfied with their progress.
The Coast Guard's strategy for monitoring and overseeing security plan implementation will face numerous challenges. Whether the Coast Guard will be able to conduct timely on-site compliance inspections of all facilities and vessels is uncertain because questions remain about whether the Coast Guard will have enough inspectors; a training program sufficient to overcome major differences in experience levels; and adequate guidance to help inspectors conduct thorough, consistent reviews. Another challenge is to ensure inspections reflect assessments of the normal course of business at facilities and aboard vessels.
The accuracy of the Coast Guard's $7.3 billion estimate for implementing security improvements is likewise uncertain. The estimate, while a goodfaith effort on the Coast Guard's part, is based on limited data and on assumptions that are subject to error. The estimate should be viewed more as a rough indicator than a precise measure of costs.
[... EDITORIAL: The following is the "transmittal letter" for the report ...]
United States General Accounting Office
Washington, DC 20548
June 30, 2004
The Honorable Don Young
Chairman, Committee on Transportation and Infrastructure
House of Representatives
The Honorable Frank A. LoBiondo
Chairman, Subcommittee on Coast Guard and Maritime Transportation Committee on Transportation and Infrastructure
House of Representatives
Since the terrorist attacks of September 11, 2001, the nation's 361 ports have increasingly been viewed as potential targets for future attacks for many reasons. For example, security experts remain concerned about the potential for using the maritime transportation system as a conduit for smuggling weapons of mass destruction or other dangerous materials into the country. Further, cargo and cruise ships present potentially desirable terrorist targets, given the potential for loss of life, ecological destruction, or disruption of commerce. And ports often are not only gateways for the movement of goods, but also industrial hubs and close to population centers, presenting additional opportunities for terrorists bent on urban destruction. Coordinating a security response for this myriad of potential targets is a daunting proposition, in part because so many different stakeholders are involved. These stakeholders include law enforcement and other government agencies at every level (federal, state, and local); vessel owners and operators; railroads; port authorities; factories and other businesses; and people who work in port areas or live nearby. Although perspectives may vary, the specter of further terrorist incidents has led to widespread agreement that port security should be strengthened--and soon.
The Maritime Transportation Security Act (MTSA) contains much of the federal government's approach to addressing these security vulnerabilities. Enacted in November 2002 and largely administered by the United States Coast Guard, an agency within the Department of Homeland Security, MTSA is designed, in part, to help protect the nation's ports and waterways from terrorist attacks through a wide range of security improvements. One of its central maritime transportation security provisions is a requirement that security plans be developed and implemented for specific facilities (such as factories, cargo terminals, and power plants); certain individual cargo and passenger vessels; and entire ports. The basic aim of such plans is to address potential vulnerabilities that could be exploited to kill people, cause environmental damage, or disrupt transportation systems and the economy, by developing measures to mitigate these vulnerabilities. The Coast Guard established regulations determining which facilities and vessels were to be covered by these security planning requirements3 and consistent with MTSA, set a deadline of July 1, 2004, for facility and vessel owners and operators to operate under an approved or self-certified security plan. Further, the Coast Guard intends to conduct on-site compliance inspections of all facilities by January 1, 2005, and all vessels by July 1, 2005, to ensure that they have satisfactorily implemented their plans. This aggressive timeline for both developing and implementing security plans reflects the seriousness of the port security issue. However, the timeline also creates a substantial and immediate workload for the Coast Guard and for owners and operators who collectively must develop plans for thousands of facilities and vessels. The Coast Guard estimated that the security improvements imposed by these requirements would likely cost port stakeholders $7.3 billion over 10 years--most of it borne by facility and vessel owners and operators.
You asked us to examine the efforts of stakeholders and the Coast Guard in carrying out these security plan requirements. Our objectives were to assess (1) the progress made to develop, review, and approve facility and
[ FOOTNOTE: The portwide security plan, called an Area Maritime Security Plan, is to be developed by the Coast Guard's local Captains of the Port and a committee comprised of federal, state, and local agencies; law enforcement and security agencies; and other port stakeholders such as owners and operators of facilities and vessels, trade and labor organizations, and railroad and trucking companies among others. The plan is designed to provide a framework for communication and coordination among port stakeholders and law enforcement officials. Our review focused on plans being developed by entities other than the Coast Guard, and we, therefore, do not discuss these area plans in this report. We will, however, be addressing aspects of these plans in a subsequent report.
FOOTNOTE: See generally 33 C.F.R. Parts 101, 104, and 105. Motorboats and other pleasure craft, for example, are generally, not subject to security plan requirements, as are a variety of other types of vessels below certain prescribed lengths or weights.
FOOTNOTE: This is the present value of costs incurred from 2003 to 2012. Unless otherwise noted, all cost figures cited are present values.
vessel security plans by July 1, 2004; (2) the Coast Guard's monitoring and oversight strategy for ensuring that facility and vessel security plans are implemented; and (3) the accuracy of the Coast Guard's estimates of costs for complying with MTSA security planning and implementation requirements.To address the first two objectives, we analyzed Coast Guard documents and spoke with officials at Coast Guard headquarters with responsibilities for the security planning process. We also visited seven port areas around the country, choosing locations that reflected diversity in strategic importance, geographic location, and local characteristics. During our visits, we spoke with Coast Guard Captains of the Port; numerous local stakeholders in the private sector; and government officials at the local, state, and federal levels, to understand what progress had been made to develop and implement security plans. We visited Coast Guard officials and contractor staff responsible for reviewing and approving MTSA-required security plans and examined the review and approval process used by the Coast Guard to determine what internal controls were in place to monitor the consistency of the process and ensure compliance with pertinent MTSA requirements. Our work did not include reviewing ports outside the United States or any "foreign-flagged" vessels--vessels registered in countries other than the United States. To address the third objective, we interviewed Coast Guard staff in charge of creating estimates of compliance costs and performed economic simulations to examine the impact of changing the assumptions the Coast Guard used in making its estimates. We asked Coast Guard officials responsible for these cost estimates what steps they took to ensure the reliability of the underlying data on which the estimates were based. We also reviewed the public comments provided to the Coast Guard on its estimates. Our work, which was conducted from June 2003 through June 2004, was done in accordance with generally accepted government auditing standards.
Although owners and operators have made progress in developing security plans, the extent to which the Coast Guard will have reviewed and approved the approximately 12,300 individual facility or vessel plans by July 1, 2004, varies considerably. Owners and operators are developing about 5,900 plans under an option allowing them to self-certify that the plans will be developed and implemented by July 1. In doing so, they are using standards and templates their trade association had developed and the Coast Guard had approved. Owners and operators who chose this option did not have to submit their plans for review and approval. The Coast Guard's first look at many of these plans will likely not come until after July 1, when inspectors begin compliance inspections to ensure that plans have been implemented. The remaining 6,400 plans, which were not developed through the self-certification process, underwent a detailed review process for which the Coast Guard hired contractors with security experience. The contractors conducting much of the review found that all of these plans needed to be revised, some extensively, and the Coast Guard concurred with the contractors' findings. As of June 2004 -- 1 month before the deadline --- more than half of these plans were still in process. To speed up the process, the Coast Guard added more personnel and began working more directly with owners and operators. Nonetheless, many of these plans will not be approved by July 1. Under MTSA and Coast Guard regulations, facilities and vessels without approved plans would have to cease operations. However, MTSA and the regulations also allow the Coast Guard to grant permission to such facilities and vessels to continue operating for up to 1 year after the plans are submitted on the condition that they continue to make sufficient progress through the review process toward the approval of their plans. The Coast Guard is currently allowing such facilities and vessels to operate through October 31, 2004.
In late May 2004, the Coast Guard issued its strategy for ensuring that facility and vessel owners and operators implement the security activities identified in their plans. It is clear that this strategy will face several challenges, both in the short and longer term. One challenge is the sheer size of the immediate effort: between July and December 2004, the Coast Guard plans to conduct on-site inspections of every facility and as many vessels as possible to ensure that owners and operators are complying with the actions called for in their security plans. Inspectors will have to make decisions about whether owners and operators have identified all vulnerabilities and adequately addressed them. These decisions are complicated, in part because owners and operators have considerable choice in how to mitigate vulnerabilities and because the Coast Guard will be seeing many of these plans for the first time. Other challenges include ensuring that enough inspectors are available, training them adequately, and equipping them with useful guidance for making on-site inspection decisions. In the short term, these challenges are formidable, because the Coast Guard expects to handle the added July-December inspection load mainly by using reservists with widely varying degrees of training and experience. In the longer term, when the Coast Guard plans to conduct annual compliance inspections for the approximately 12,300 facilities and vessels, it faces the challenge of ensuring that owners and operators continue implementing their plans. In this regard, our work has shown that there are options the Coast Guard could consider beyond regularly scheduled visits, such as unscheduled, unannounced visits and covert testing to help ensure owners and operators do not mask security problems in ways that do not represent the normal course of business.
The accuracy of the Coast Guard's $7.3 billion estimate of maritime industry costs for developing and implementing their security plans is uncertain. An estimate's accuracy is often tied to such factors as the complexity or straightforwardness of the issue, the quality of data and validity of assumptions, and the length of time available to conduct the work. The Coast Guard was heavily limited in all these factors. First, the issue was complex: for example, facilities and vessels are very diverse and they vary greatly in the degree to which they already have security measures in place. Second, to account for such differences, the Coast Guard was faced with having to develop many assumptions, and while the Coast Guard used government and industry expertise to help make these assumptions, it had limited data with which to work, and the potential margin for error was considerable. Our analysis found that changes in the Coast Guard's assumptions could raise or lower the estimate by more than $1 billion. Third, the Coast Guard had only a few months to develop the estimate. The Coast Guard vetted the estimate with stakeholders as a way of testing its reliability, but stakeholders were basically in no better position than the Coast Guard to generalize from their own specific situations. The Coast Guard appeared to make a good-faith effort to prepare an estimate and seek review of it from port stakeholders, but the limiting factors discussed here indicate the result can be viewed more as a rough indicator of costs, not a precise measure.
We recommend that the Coast Guard evaluate the compliance inspection efforts it takes during the initial 6-month period after July 1 and use the results as a means to strengthen its long-term strategy for ensuring compliance. As part of this strategy, the Coast Guard should clearly define inspector qualifications, link these qualifications to a certification process, and consider including unscheduled and unannounced inspections and covert testing. The Coast Guard reviewed our report and generally agreed with the facts and recommendation.
MTSA mandated major changes in the nation's approach to maritime security. The act called for a comprehensive security framework--one that included planning, personnel security, and careful monitoring of vessels and cargo. Among its specific provisions were the development of systems for tracking vessels, identifying maritime workers, and assessing foreign ports for security risks they posed for the United States. One of MTSA's central components is a systematic approach to strengthening security throughout the nation's port areas -- a difficult task, given the tremendous size and variety of activities and user groups involved. Ports present attractive targets: they are sprawling, easily accessible by water and land, close to crowded metropolitan areas, and interwoven with complex transportation networks designed to move cargo and commerce as quickly as possible. They contain not only terminals where goods bound for import or export are unloaded or loaded onto vessels, but also other facilities critical to the nation's economy, such as refineries, factories, and power plants.
Facilities and vessels can be vulnerable on many security-related fronts. Facilities such as container terminals, where containers are transferred between ships and railroad cars or trucks, must be able to screen vehicles entering the facility and routinely check cargo for evidence of tampering. Chemical factories and other installations where hazardous materials are present must be able to control access to areas containing dangerous goods or hazardous substances. Vessels, ranging from oil tankers and freighters to tugboats and passenger ferries, must be able to restrict access to areas on board the vessel such as the bridge or other control stations critical to the vessel's operation. To reduce the opportunity for terrorists to exploit these vulnerabilities, as well as to help minimize the effects of accidents or natural disasters, facilities and vessels need to take mitigation steps. For example, fences, security guards, and monitoring cameras can all be used to reduce the potential for unauthorized entry and help prevent vulnerabilities from being exploited.
Dealing with such vulnerabilities involves a careful balance between the benefits of added security and the potential economic impacts of security enhancements. While there is broad support for greater security, this task is a difficult one because the nation relies heavily on a free and expeditious flow of goods. Particularly with "just in time" deliveries, which require a smooth and expeditious flow through the transportation system, delays or disruptions in the supply chain could have serious economic impacts. Striking the right balance between increasing security and protecting economic vitality of the national economy and individual port stakeholders will remain an important and difficult task. It is also important to keep in mind that total security cannot be bought no matter how much is spent on it. It is difficult if not impossible to successfully anticipate and thwart all types of potential terrorist threats that highly motivated, well skilled, and adequately funded terrorist groups could devise.
In this environment, MTSA required owners and operators of facilities and vessels to conduct assessments that would identify their security vulnerabilities and to develop security plans to mitigate these vulnerabilities. Under the Coast Guard's implementing regulations, these plans are to include such items as measures for access control, responses to security threats, and drills and exercises to train staff and test the plan. The plans are "performance-based," meaning that the security outcomes were specified, but the stakeholders were free to identify and implement whatever measures they desired as long as these measures achieved the specified outcomes.
MTSA tasked the Secretary of the Department of Homeland Security with responsibility for reviewing, approving, and overseeing the implementation of these plans, and the Secretary delegated this task to the Coast Guard. MTSA imposed a specific date, July 1, 2004, for facilities and vessels to begin operating in compliance with the plans. The Coast Guard decided to adopt a schedule that would align the United States with ongoing international improvements in maritime security as well as the act. In December 2002, members of the International Maritime Organization (IMO) adopted the International Ship and Port Facility Security (ISPS) Code, an international agreement that called for security plans to be in place by July 1, 2004. The Coast Guard had to decide which facilities and vessels were subject to MTSA's requirements and develop an approach for reviewing and approving the plans. The categories of facilities and vessels were specified in implementing regulations, issued in final form on October 22, 2003. Overall, approximately 3,150 facilities and 9,200 vessels operating in more than 300 ports around the nation were required to comply with these requirements. The ports included not only those on the Atlantic, Gulf, and Pacific coasts, but also ports in the Great Lakes and various inland waterways like the Mississippi and Ohio rivers. (See fig. 1.)
FOOTNOTE: IMO is responsible for improving maritime safety, including combating acts of violence or crime at sea. The United States is a member. In November 2001, the Commandant of the Coast Guard addressed IMO's General Assembly, urging that body to consider an international scheme for port and shipping security. Recommendations and proposals for comprehensive security requirements, including amendments to International Convention for Safety of Life at Sea, 1974, (SOLAS) and the new ISPS Code, were developed at a series of intersessional maritime security work group meetings held at the direction of IMO's Maritime Safety Committee.
The key dates in the process established by the Coast Guard included the following:
The Coast Guard took a number of steps to help stakeholders understand and comply with requirements. The Coast Guard issued updated guidance and established a "help desk" to provide stakeholders with a single point of contact, both through the Internet and over the telephone. At the local level, Coast Guard marine safety offices at the ports provided stakeholders operating within their ports additional information and assistance through forums, training sessions, e-mails, letters, and telephone calls. The Coast Guard also hired two contractors to provide expertise in reviewing the facility and vessel security plans. In issuing the final rules, the Coast Guard also developed an estimate of the cost to implement MTSA's port security provisions. The Coast Guard estimated that implementing the various port and vessel security provisions, including the security plans, would cost $7.3 billion over 10 years. In fiscal years 2002-2004, the federal government awarded $516 million in grant funds for improvements in port security; in fiscal year 2005, the Department of Homeland Security expects another $50 million to be made available through federal grants to implement security improvements identified in the plans. However, the bulk of the cost burden is likely to be borne by facility and vessel owners and operators.
While the Coast Guard expects owners and operators to implement the approximately 12,300 facility and vessel plans by July 1, 2004, the extent it will have reviewed and approved these plans varies widely, for two main reasons. First, about 5,900 of these plans were developed under an option that essentially deferred Coast Guard review of individual plans until after July 1. Under this option, owners and operators self-certified that their plans would be based on industry-developed, Coast Guard-approved standards and templates. Owners and operators choosing this option did not have to submit their plans for review. Second, while the remaining 6,400 plans did undergo detailed review, all of them had deficiencies, and many are not likely to be corrected and fully approved by July 1. Under MTSA and Coast Guard regulations, facilities and vessels without fully approved plans would have to cease operations on July 1. However, the Coast Guard has put procedures in place to allow such facilities and vessels to continue operating after the deadline, provided certain conditions are met.
The Coast Guard established two options, referred to in this report as options A and B, which owners and operators could follow in developing their plans. (See fig. 2.) These options differed in the documents that had to be supplied to the Coast Guard and the extent of review that would be applied to individual plans by July 1.
These two options both involved review by the Coast Guard, but there was considerable difference in what was being reviewed before the start of the compliance phase on July 1, 2004. Under option A, the Coast Guard and its contractors would review the individual plans themselves; under option B, Coast Guard review would center on the organization's standards and templates and would not extend to the individual plans. These reviews
FOOTNOTE: Under both options, facilities also had to submit a "Vulnerability and Security Measures Summary" (Form CG-6025), which lists the vulnerabilities and specific security measures to be taken. Owners and operators submitting plans under option A also had to submit a security assessment report, a document based on background information and an on-scene survey, identifying possible threats, vulnerabilities, consequences, and existing protective measures. Those who chose option B did not have to submit this report.
were not the same, in that industry standards and templates are a framework for developing a plan, but are not analogous to individual vessel or facility security plans. To adapt the standards and templates to specific facilities and vessels, owners and operators still need to do considerable work.
Coast Guard records indicate that 90 percent of facilities and vessels met the December 31, 2003, deadline for complying with one of the two options. Most owners and operators who did not meet the December 31 deadline subsequently complied. However, the Coast Guard issued notices of violation with a $10,000 penalty assessment against owners or operators of 67 facilities and 90 vessels who had not responded by February 1. Eight of these owners or operators received a subsequent $25,000 penalty assessment for not responding by March 1.
In all, plans for 5,923 facilities or vessels are being prepared under option B. Of these, 234 were facilities and 5,689 were vessels. The Coast Guard granted approval to standards and templates submitted by nine trade organizations, most of them vessel-related, and the plans being developed under this option reflect the larger number of vessel-related groups. Overall, about 7 percent of facility plans are being developed under this option, compared with 62 percent of all vessel plans. (See fig. 3.)
The extensive use of option B meant that nearly half of the individual plans were not directly reviewed by the Coast Guard before they were to be implemented on July 1, 2004. Users of option B had to send the Coast Guard a letter stating which alternative security program they planned to use. The Coast Guard was to check to ensure that the owners or operators were members of the organization that developed the program. Inasmuch as option B reduced the number of individual plans to be reviewed, it lessened the Coast Guard's review workload. However, option B also had the effect of deferring review of these individual plans into the next phase of the process--the on-site compliance inspections to be conducted starting July 1. For these facilities and vessels, the Coast Guard's first look at the plans will occur when inspectors arrive to ensure that the plans have been implemented.
For plans submitted under option A, the Coast Guard established a comprehensive review and approval process that relies on contractors with security planning expertise to review and evaluate the plans. Plans move through a two- or three-stage process, depending on whether they are for vessels or facilities. In stage I, at least two contract personnel independently reviewed the plans to ensure they contain material covering all required items such as measures for access control, responses to security threats, and drills and exercises to train staff and test the plan. Plans passing this stage move to stage II, where comprehensive assessments are conducted as to whether the plans address all of MTSA's requirements. Vessel plans are approved once the Coast Guard determines they have passed this stage II review. Facility plans continue on to a stage III review, in which the local Coast Guard marine safety office verifies the information in the security assessment against the facility's physical characteristics and determines whether the plan is adequate to meet security needs. This last stage may include an on-site visit, but if conducted, this verification review is not the same as the post-July 1 compliance inspection for determining whether the facility has implemented the plan. Facility plans are approved once the Coast Guard determines they have passed this stage III review.
This review and approval process flagged problems. Every one of the more than 6,400 facility and vessel plans submitted under this option had deficiencies that needed to be revised before the plan could be approved. As table 1 shows, of the 2,913 facility plans and 3,505 vessel plans submitted under option A, more than half were still undergoing the detailed review as of June 2004. Most of these plans still in review were facility security plans.
Footnote: The Coast Guard has issued guidance to Captains of the Port to encourage them to "engage" with users of option B to review their progress prior to July 1, 2004. However, these users are not required to agree to these reviews.
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The vulnerability of the nation's ports and the importance of addressing these vulnerabilities cannot be overemphasized. Since MTSA's enactment in November 2002, the Coast Guard has worked hard to address these vulnerabilities by spurring the development of meaningful security plans for thousands of facilities and vessels in the nation's ports. Progress has been made, though the extent to which all facilities and vessels will have adequate plans ready to implement as of July 1, 2004, is still unclear. This is particularly true for the thousands of self-certified plans. The Coast Guard has approved the guidelines and templates for these plans, but in most instances it has not seen the plans themselves.
As hard as the Coast Guard has worked to ensure that plans are developed, the most important part of the process still lies ahead because plans mean little if they do not actually produce better security. Many challenges lie ahead as the Coast Guard attempts to develop a complete picture of the security environment at the nation's seaports and take whatever actions are needed, when they are needed to protect those ports. The uncertainty about whether the Coast Guard will be able to meet its timeframes for conducting on-site compliance inspections of the more than 12,300 facilities and vessels and questions about whether it will have enough staff and a sufficient experience base to handle so many inspections will undoubtedly challenge management and staff to effectively implement the strategy. In addition, the complexity of compliance inspections that call for sophisticated judgments about vulnerabilities and the actions taken to address them will likely create the need for up-to-date training and guidance to help ensure that such decisions are thorough and consistent. During the initial surge period, these challenges make it important for the Coast Guard to carefully evaluate its efforts, so that problems or inadequacies can be identified. In the longer term, the Coast Guard can benefit from the lessons learned from this evaluation and use them to refine its long-term inspection strategy.
Several points stand out in particular as important in this evaluation effort.
[ .... A few more pages .... ]
As is clear from this GAO report, owners and operators do have a significant role in security at ports. They are intimately involved in security planning.
Private companies have also received considerable public funds (in the form of matching grants) to improve port security.
It's my opinion that (1) we should not allow a foreign government to have a significant security role in our port security and (2) we should not put a foreign government in a position where it can legitimately put such direct demands on U.S. taxpayer funds, as these private companies can.
Does that mean that the UAE will know all our security percautions and plans?
No, I wouldn't think that their knowledge would involve all of our security precautions and plans, even for such a large operator.
But certainly to the extent that their own company is involved in those precautions and plans, then I would expect management to have knowledge of those areas, and their roles and responsibilities in executing those plans.
Thank you. I'm still not comfortable with this.
I am against allowing the UAE, North Korea, Iran, Syria, and Red China such access. Just because they wouldn't have access to the whole body of our security planning doesn't mean that whatever maleficence that might be associated with any of them can immediately dismissed out of hand.
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