Passenger Rail Security: Enhanced Federal Leadership Needed to	 
Prioritize and Guide Security Efforts (09-SEP-05, GAO-05-851).	 
                                                                 
The U.S. passenger rail system is a vital component of the	 
nation's transportation infrastructure, carrying more than 11	 
million passengers each weekday. The Department of Homeland	 
Security (DHS) and the Department of Transportation (DOT) share  
responsibility for ensuring the safety and security of rail	 
systems. In this report, GAO addressed (1) DHS actions to assess 
the risks to the U.S. passenger rail system in the context of	 
prevailing risk management principles, (2) federal actions taken 
to enhance the security of the U.S. passenger rail system, and	 
(3) security practices that domestic and selected foreign	 
passenger rail operators have implemented.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-851 					        
    ACCNO:   A36223						        
  TITLE:     Passenger Rail Security: Enhanced Federal Leadership     
Needed to Prioritize and Guide Security Efforts 		 
     DATE:   09/09/2005 
  SUBJECT:   Comparative analysis				 
	     Counterterrorism					 
	     Emergency preparedness				 
	     Foreign governments				 
	     Homeland security					 
	     Interagency relations				 
	     Mass transit					 
	     Passengers 					 
	     Rail security					 
	     Railroad industry					 
	     Railroad safety					 
	     Risk assessment					 
	     Terrorism						 
	     Transportation security				 

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GAO-05-851

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

September 2005

PASSENGER RAIL SECURITY

  Enhanced Federal Leadership Needed to Prioritize and Guide Security Efforts

GAO-05-851

[IMG]

September 2005

PASSENGER RAIL SECURITY

Enhanced Federal Leadership Needed to Prioritize and Guide Security Efforts

  What GAO Found

Within DHS, the Office for Domestic Preparedness has completed 7 risk
assessments of passenger rail systems around the country, with 12 more
under way. TSA has begun to conduct risk assessments and to establish a
methodology for determining how to analyze and characterize risks that
have been identified but has not yet completed either effort or set
timelines for doing so. TSA will not be able to prioritize passenger rail
assets and help guide security investment decisions until these efforts
are completed. At the department level, DHS has begun developing, but has
not yet completed, a framework to help agencies and the private sector
develop a consistent approach for analyzing and comparing risks to
transportation and other sectors. Until this framework is finalized and
shared with stakeholders, it may not be possible to compare risks across
different sectors, prioritize them, and allocate resources accordingly.

The Federal Transit Administration and Federal Railroad Administration
within DOT have ongoing initiatives to enhance passenger rail security. In
addition, in 2004, TSA issued emergency security directives to domestic
rail operators after terrorist attacks on the rail system in Madrid,
Spain, and piloted a test of explosive detection technology for use in
passenger rail systems. However, federal and rail industry officials
raised questions about the feasibility of implementing and complying with
the directives, citing limited opportunities to collaborate with TSA to
ensure that industry best practices were incorporated. In September 2004,
DHS and DOT signed a memorandum of understanding to improve coordination
between the two agencies, and they are developing agreements to address
specific rail security issues.

Domestic and foreign passenger rail operators we contacted have taken a
range of actions to help secure their systems. We also observed security
practices among certain foreign passenger rail systems or their
governments that are not currently used by the domestic rail operators we
contacted, or by the U.S. government, and which could be considered for
use in the United States. For example, some foreign rail operators
randomly screen passengers, and some foreign governments maintain
centralized clearinghouses on rail security technologies and best
practices.

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

United States Government Accountability Office

Contents

Letter

Results in Brief
Background
DHS Has Taken Steps to Assess Risk to Passenger Rail Systems,

but Additional Work Is Needed to Guide Security Investments
Multiple Federal Agencies Have Taken Actions to Enhance
Passenger Rail Security

U.S. and Foreign Rail Operators Have Taken Similar Actions to Secure Rail
Systems, and Opportunities for Additional Domestic Security Actions May
Exist

Conclusions
Recommendations for Executive Action
Agency Comments and Our Evaluation

                                       1

                                      4 8

20

32

45 68 71 72

Appendix I Objectives, Scope, and Methodology

Appendix IIElements of a Typical Homeland Security Risk Assessment

Appendix III FTA and ODP Passenger Rail Risk Assessments

Conducted or In Progress 85

FTA Risk Assessments Conducted 85
ODP Risk Assessments 86

Appendix IVComments from the Department of Homeland Security

Appendix V GAO Contacts and Staff Acknowledgments 94

Tables

Table 1: Selected Roles and Responsibilities of Federal Agencies
Related to Risk Management and Critical Infrastructure
Protection 18

                   Page i GAO-05-851 Passenger Rail Security

Table 2: Selected Steps in ODP's Risk Assessment Process 22 Table 3:
Examples of Measures Required by TSA Security Directives Issued to
Passenger Rail Operators and Amtrak 36 Table 4: Domestic Passenger Rail
Agencies We Visited or Interviewed for the Purposes of this Review 80
Table 5: Foreign Passenger Rail and Government Agencies We Visited or
Interviewed for the Purposes of This Review 82

Figures

Figure 1: Geographic Distribution of Amtrak and Rail Transit

Systems 9 Figure 2: Risk Management Cycle 14 Figure 3: Sample ODP Relative
Risk Diagram 23 Figure 4: Status of TSA's Passenger Rail Risk Assessment
Efforts,

as of July 2005 30 Figure 5: Summary Information on TSA's Transit and Rail

Inspection Pilot Program Phases 41 Figure 6: Example of Passenger Rail
Customer Awareness Poster 49 Figure 7: Wallet-size Cards Distributed to
BART Employees

Containing Anti-terrorism Information 52 Figure 8: Selected Security
Design Elements Incorporated into London's Underground 58 Figure 9:
Security Design Elements Incorporated into London's Underground 59 Figure
10: Composite of Selected Security Practices in the Passenger Rail
Environment 61

                   Page ii GAO-05-851 Passenger Rail Security

Abbreviations

AAR American Association of Railroads
APTA American Public Transportation Association
ATSA Aviation and Transportation Security Act

BART San Francisco Bay Area Rapid Transit
CCTV closed-circuit television
DHS Department of Homeland Security

DOT Department of Transportation
FRA Federal Railroad Administration
FTA Federal Transit Administration

HSPD-7 Homeland Security Presidential Directive-7
IAIP Information Analysis and Infrastructure Protection
MBTA Massachusetts Bay Transportation Authority

MOU memorandum of understanding
NIPP National Infrastructure Protection Plan
ODP Office for Domestic Preparedness

PANYNJ Port Authority of New York and New Jersey
PATH Port Authority Trans-Hudson
PDA personal digital assistant

RATP Regie Autonome des Transports Parisiens SLGCP Office of State and
Local Government Coordination and Preparedness

TRIP Transit and Rail Inspection Pilot
TSA Transportation Security Administration
TSSP transportation sector-specific plan

UASI Urban Area Security Initiative
WMATA Washington Metropolitan Area Transit Authority

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

                  Page iii GAO-05-851 Passenger Rail Security

United States Government Accountability Office Washington, DC 20548

September 9, 2005

The Honorable Steven LaTourette
Chairman
Subcommittee on Railroads
Committee on Transportation and Infrastructure
House of Representatives

The Honorable Olympia Snowe
United States Senate

The Honorable Barbara Boxer
United States Senate

The Honorable Michael Castle
House of Representatives

The July 7 and July 21, 2005, bomb attacks on London's subway system,
which resulted in over 50 fatalities and more than 700 injuries,
dramatically highlighted the vulnerability of passenger rail systems
worldwide to terrorist attacks and the need for an increased focus on
security for these systems. The U.S. passenger rail system is a vital
component of the nation's transportation infrastructure, encompassing rail
transit (heavy rail, commuter rail, and light rail) and intercity rail
systems.1
Together, these systems carry more than 11 million passengers each
weekday. One of the critical challenges facing rail system operators-and
the federal agencies that regulate and oversee them-is finding ways to
protect rail systems from potential terrorist attacks without compromising
the accessibility and efficiency of rail travel.

1The U.S. passenger rail system consists of heavy, commuter, light, and
intercity rail systems. Heavy rail is an electric railway that can carry a
heavy volume of traffic. Heavy rail is characterized by high speed and
rapid acceleration, passenger rail cars operating singly or in multi-car
trains on fixed rails, separate rights of way from which all other
vehicular and foot traffic is excluded, sophisticated signaling, and
high-platform loading. Most subway systems are considered heavy rail.
Commuter rail is characterized by passenger trains operating on railroad
tracks and providing regional service, such as between a central city and
its adjacent suburbs. Light rail systems typically operate passenger rail
cars singly (or in short, usually two-car, trains) and are driven
electrically with power being drawn from an overhead electric line. Amtrak
operates the nation's primary intercity rail system.

Several entities play a role in helping to fund and secure the passenger
rail industry. The Department of Homeland Security's (DHS) Transportation
Security Administration (TSA) is the primary regulator of the rail
system's security, while DHS's Office for Domestic Preparedness (ODP) has
been the primary federal source of security funding for passenger rail
systems. In addition, the Department of Transportation's (DOT) Federal
Transit Administration (FTA) and Federal Railroad Administration (FRA),
state and local agencies (which operate most rail transit rail systems),
and Amtrak are responsible for or have been involved in the security and
safety of the U.S. passenger rail system.

In the United States, passenger rail systems represent one of many modes
of transportation-along with aviation, maritime, and others-competing for
limited federal security resources. Within the passenger rail sector
itself, there is competition for resources, as federal, state, and local
agencies and rail operators seek to identify and invest in appropriate
security measures to safeguard these systems while also investing in other
capital and operational improvements. Moreover, given competing priorities
and limited homeland security resources, difficult policy decisions have
to be made by Congress and the executive branch to prioritize security
efforts and direct resources to areas of greatest risk within the
passenger rail system, among all transportation modes, and across other
nationally critical sectors.

In this regard, to help federal decision makers determine how to best
allocate limited resources, we have advocated, the National Commission on
Terrorist Attacks Upon the United States (the 9/11 Commission) has
recommended, and the subsequent Intelligence Reform and Terrorism
Prevention Act of 2004 requires, that a risk management approach be
employed to guide security decision making. 2 A risk management approach
entails a continuous process of managing risks through a series of
actions, including setting strategic goals and objectives, assessing and
quantifying risks, evaluating alternative security measures, selecting
which measures to undertake, and implementing and monitoring those
measures. In July 2005, in announcing his proposal for the reorganization
of DHS, the Secretary of the Department of Homeland Security declared that
as a core principle of the reorganization, the department must base its
work on priorities driven by risk.

2Pub. L. No. 108-458, 118 Stat. 3638.

You have expressed interest in the progress federal agencies and domestic
passenger rail operators have made in setting and implementing security
priorities in the wake of September 11 and terrorist attacks on rail
systems. In addition, you expressed interest in learning about the
security practices implemented by foreign passenger rail operators. For
this report, we analyzed (1) the actions that DHS and its component
agencies have taken to assess the risks posed by terrorism to the U.S.
passenger rail system in the context of prevailing risk management
principles; (2) the actions that federal agencies have taken to enhance
the security of the U.S. passenger rail system; and (3) the security
practices that domestic and selected foreign passenger rail operators have
implemented to mitigate risks and enhance security, and any differences in
these practices.

To perform our analyses, we conducted site visits at, or held
teleconferences with, a total of 32 passenger rail operators in the United
States that represent over 95 percent of the nation's total rail
ridership, as well as Amtrak. We also conducted site visits or met
elsewhere with 13 passenger rail operators in seven European and Asian
countries. During our domestic and international visits, we interviewed
management and security personnel, toured stations and other facilities
such as control centers, observed security practices, and obtained
documentation of security procedures. In addition, we interviewed
officials from domestic and foreign rail industry associations, foreign
governments and rail operators, and representatives of the European
Commission. Because we selected a nonprobability sample of both foreign
and domestic passenger rail operators, the information we obtained from
these interviews and visits cannot be generalized to all foreign or
domestic rail operators.

We also reviewed risk assessments of U.S. rail systems conducted by the
federal government. Risk assessments are used to identify and rank risks
to critical regional or national assets to further identify which would be
most vulnerable to attack based on various threat scenarios. Risk
assessments are an integral part of using a broader risk management
approach to guide investments that help enhance security. While a risk
management approach entails multiple iterative components, this report
primarily addresses the risk assessment component of such an approach as
applied in the homeland security context. (Additional information about
the risk assessment component is contained in app. II.) Although we
identified and cataloged security practices of the domestic and foreign
passenger rail operators we contacted, we did not evaluate the
appropriateness or effectiveness of these practices. We discussed foreign
security practices we observed with DHS, DOT, passenger rail industry
associations, select passenger rail operators, and transportation security

  Results in Brief

experts from the RAND Corporation and the Mineta Transportation Institute
to explore the potential applicability of these practices to U.S.
passenger rail systems. 3 Our work does not reflect the proposed

reorganization of DHS and its component agencies announced by the
Secretary of DHS. We conducted our work from May 2004 through July 2005 in
accordance with generally accepted government auditing standards. Appendix
I contains more details about our objectives, scope, and methodology.

Two component agencies with different missions within DHS are responsible
for, and have engaged in, conducting risk assessments for the passenger
rail industry, in an effort to identify and protect the assets most
vulnerable to attack and most critical to operations, such as stations,
tracks, and bridges. The first, the Office for Domestic Preparedness, is
responsible for, among other things, providing grant funds and technical
assistance to rail operators and others to improve preparedness at the
state and local level. As part of this mission, ODP has developed and
implemented a risk assessment methodology for mass transit agencies and
port authorities, and used it to complete 7 risk assessments at rail
facilities, with an additional 12 assessments in progress, as of July
2005. According to passenger rail operators we interviewed, ODP's risk
management approach has helped them to prioritize and allocate resources
to protect their systems. For example, one operator collaborated with ODP
on a risk assessment that resulted in justifying a $500 million
high-priority security capital investment program, which is to fund, among
other things, a security operations center for its passenger train
network, alarm monitoring systems, and an upgraded closed-circuit
television system. The second agency, TSA, has also recently begun to
conduct risk assessments of the rail sector as part of a broader effort to
assess risk to all transportation modes. As of July 2005, while TSA had
completed an overall threat assessment for mass transit and passenger
rail, the agency had not yet completed a risk assessment for the passenger
rail sector or a methodology for determining how to analyze and
characterize risk (as high, medium, or low) identified through
assessments, or indicated when this would be done. Until both of these
efforts have been accomplished, in collaboration with rail industry
stakeholders, TSA will not be able to prioritize passenger rail assets
based

3The institute was established by Congress as part of the Intermodal
Surface Transportation Efficiency Act of 1991 and focuses on international
surface transportation policy issues involving research, education, and
technology transfer. RAND is a nonprofit research organization that
analyzes security issues in the rail sector, among other things.

on risk and help guide investment decisions about protecting them. A 2003
presidential directive required DHS to, among other things, establish
uniform guidelines and methodologies for integrating federal
infrastructure protection and risk management activities within and across
entire economic sectors, such as transportation (including rail), energy,
and agriculture. To address this requirement, at the department level, DHS
has been developing a broad framework intended to help federal agencies,
the private sector, and state and local governments develop a consistent
approach to analyzing risk to critical infrastructure within and across
sectors. This framework is intended to enable risks across sectors to be
compared as a means of guiding resource allocation and emergency response
planning. Because DHS has not yet finalized this framework, it is not
known what impact, if any, it may have on risk assessment efforts now
under way by TSA, ODP, and other federal agencies with critical
infrastructure protection responsibilities. Until DHS finalizes this
framework, it may not be possible to compare risks across different
sectors, prioritize them, and then allocate resources accordingly.

A number of federal departments and their component agencies have taken
actions to strengthen passenger rail security. FTA and FRA were the
primary federal agencies involved in passenger rail security matters prior
to the creation of TSA, and both undertook numerous initiatives both
before and after September 11, 2001. For example, FTA conducted security
readiness assessments, sponsored security training, and developed security
guidance for transit agencies. FRA conducted security inspections of
commuter railroads and researched various rail security technologies.
After taking over as the lead federal agency responsible for
transportation security, TSA issued security directives to the passenger
rail industry in May 2004, after terrorists attacked the commuter rail
system in Madrid, Spain. The directives-based upon industry best
practices, according to TSA-required rail operators to implement a number
of security measures, such as conducting frequent inspections of stations,
terminals, and other assets, or utilizing canine explosive detection
teams, if available. According to TSA officials, because of the need to
act quickly, the rule-making process for these security directives did not
include a public comment period. As a result, stakeholder input was
limited. The rapid issuance of these directives has posed challenges to
TSA and rail operators. For example, while rail operators are required to
implement the measures, and TSA has hired rail inspectors to enforce them,
operators told TSA they were unsure how to comply with the directives
because, for example, the directives include instructions requiring them
to perform "frequent inspections" of key facilities, without defining
relevant parameters. TSA told rail operators when the directives

were issued that additional performance-based guidance would be provided
to clarify the directives requirements, but this information has not been
supplied. Further, TSA has not yet developed criteria or procedures for
rail inspectors to use in enforcing compliance with the directives. In
addition, stakeholders we contacted questioned the extent to which the
security directives reflected industry best practices. For example, one
requirement of the directives was that the doors of the rail engineer's
compartment be locked, which conflicts with an existing FRA safety
regulation calling for these doors to remain unlocked for escape purposes.
In September 2004, in response to our prior recommendation, DHS and DOT
signed a memorandum of understanding (MOU) intended to identify ways to
improve coordination and collaboration between and among federal and rail
industry stakeholders. 4 As of July 2005, the departments were developing
agreements within the framework of this memorandum to delineate specific
security-related roles, responsibilities, and resources for mass transit,
rail, research and development, and other matters.5 However, none of the
agreements have been finalized and timelines have not been established for
doing so. Completing these agreements could help to ensure that federal
activities to secure passenger rail systems are coordinated and that
stakeholders are appropriately involved in the development and
implementation of these activities.

Domestic and foreign passenger rail operators we contacted or visited have
generally taken similar actions to help secure their systems against the
risk posed by terrorism. Specifically, most U.S. and foreign operators we
contacted had implemented customer awareness programs to encourage
passengers to remain vigilant and report suspicious activities, increased
the number and visibility of their security personnel, increased the usage
of canine teams to detect drugs and explosives, enhanced employee training
programs, upgraded security technology, tightened access controls, and
made system design improvements to enhance security. However, we observed
security practices among certain foreign passenger rail systems or their
governments that were not in use, at the

4GAO, Mass Transit: Federal Actions Could Help Transit Agencies Address
Security Challenges, GAO-03-263 (Washington, D.C.: Dec. 13, 2002), and
Transportation Security: Federal Action Needed to Help Address Security
Challenges, GAO-03-843 (Washington, D.C.: June 2003).

5The Safe, Accountable, Flexible, and Efficient Transportation Equity Act
of 2005 (P.L. 109

59) enacted on August 10, 2005, requires DOT and DHS to complete an
agreement within 45 days of enactment to define and clarify their
respective roles related to public transportation security.

time we completed our fieldwork in June 2005, by the domestic rail
operators we contacted or the U.S. government. For example, we found that
2 of 13 foreign rail operators we contacted utilize covert testing to help
keep employees alert to security threats. In one type of covert test,
suspicious items are placed throughout the rail system and employees are
observed to see how long it takes them to find the objects. In addition, 2
of 13 foreign rail operators we visited randomly screen passengers and
their baggage. After the July 7, 2005, London bombings, four domestic
passenger rail operators began randomly screening passengers and their
baggage on a limited basis. Further, in five countries we visited,
national governments have centralized research on security technologies
and maintain clearinghouses on these technologies and security best
practices, giving rail operators a single source for identifying and
comparing, among other things, chemical sensors, closed-circuit
television, and intrusion detection systems. Introducing any of these
security practices into the U.S. rail system may pose political, legal,
fiscal, and cultural challenges, but may nevertheless warrant examination
to determine whether they could enhance the security of domestic rail
systems.

To help ensure that the federal government has the information it needs to
prioritize passenger rail assets based on risk, and in order to evaluate,
select, and implement commensurate measures to help the nation's passenger
rail operators protect their systems against acts of terrorism, we are
making several recommendations. Among them, we recommend that TSA
establish a plan with timelines for completing its methodology for
conducting risk assessments, develop security standards that reflect
industry best practices and can be measured and enforced, and set
timelines for completing memorandum of understanding agreements. In
addition, we are recommending that the Secretary of DHS determine the
feasibility, in a risk management context, of implementing certain
security practices used by foreign rail operators. These recommendations
should be implemented in collaboration with DOT and the passenger rail
industry. We provided DHS, DOT, and Amtrak a draft of this report for
review and comment. DOT and Amtrak generally agreed with our findings and
recommendations and provided technical comments, which we have
incorporated where appropriate. DHS generally concurred with the report's
recommendations. However, DHS raised questions about, among other things,
the extent to which the report reflected the agency's efforts to involve
federal and rail industry stakeholders in the development of security
directives and criticality assessments. According to TSA, the emergency
circumstances under which the directives were issued allowed for only
limited input and review by federal and rail industry stakeholders.
However, we believe that using the federal rule-making process as a means

of establishing permanent standards would make the process more
transparent and could help TSA in developing standards that are most
appropriate for the industry and which can be measured, monitored, and
enforced. These stakeholders will be involved in administering,
implementing, and/or enforcing TSA standards and stakeholder buy-in would
be critical to the success of such initiatives. DHS's comments appear in
appendix IV.

                                   Background

    Overview of the U.S. Passenger Rail System

Each weekday, 11.3 million passengers in 35 metropolitan areas and 22
states use some form of rail transit.6 Heavy rail systems-subway systems
like New York City's transit system and Washington, D.C.'s Metro-
typically operate on fixed rail lines within a metropolitan area and have
the capacity for a heavy volume of traffic. Commuter rail systems
typically operate on railroad tracks and provide regional service (e.g.,
between a central city and adjacent suburbs). Commuter rail systems are
traditionally associated with older industrial cities, such as Boston, New
York, Philadelphia, and Chicago. Light rail systems are typically
characterized by lightweight passenger rail cars that operate on track
that is not separated from vehicular traffic for much of the way. All
types of rail transit systems in the United States are typically owned and
operated by public sector entities, such as state and regional
transportation authorities.

Amtrak operates the nation's primary intercity passenger rail service over
a 22,000-mile network, primarily over leased freight railroad tracks.7
Amtrak serves more than 500 stations (240 of which are staffed) in 46
states and the District of Columbia, and it carried more than 25 million
passengers in 2004. According to Amtrak, about two-thirds of its ridership
is wholly or partially on the "Northeast Corridor," between Boston and
Washington, D.C. Amtrak owns about 650 miles of track, primarily on the
Northeast Corridor. Stations are owned by Amtrak, freight carriers,
municipalities, and some private entities. Amtrak also operates commuter
rail services in certain jurisdictions on behalf of state and regional

6The American Public Transportation Association compiled this fiscal year
2003 ridership data from FTA's National Transit Database. These are the
most current data available. Rail transit systems in the District of
Columbia and Puerto Rico are included in these statistics.

7The Alaska Railroad Corporation also operates intercity passenger rail
service.

transportation authorities. Figure 1 identifies the geographic location of
rail transit systems and Amtrak within the United States.

Figure 1: Geographic Distribution of Amtrak and Rail Transit Systems

Number of Heavy rail systems in city
Number of commuter rail systems in city
Number of light rail systems in city
Amtrak train stations
Amtrak rail network

Source: Amtrak and National Transit Database.

    Passenger Rail Systems Are Inherently Vulnerable to Terrorist Attacks

To date, U.S. passenger rail systems have not been targets of terrorist
attacks. However, worldwide, public transportation in general and
passenger rail in particular, have been attacked multiple times, sometimes
with grave results. According to a database of worldwide terrorist
incidents maintained by the RAND Corporation, from 1995 to June 2005,
there have been over 250 terrorist attacks worldwide against rail targets,
resulting in almost 900 deaths and over 6,000 injuries.8 Among them were
the fatal 1995 sarin gas attack on the Tokyo subway system by the Aum
Shinri Kyo doomsday cult, resulting in 12 deaths and 5,000 injuries; the
December 2003 bomb attack by Chechen rebels on a Russian commuter train,
resulting in 46 fatalities and 165 injuries; and the March 2004 terrorist
bombing attacks on commuter trains in Madrid, for which an al Qaeda
affiliate organization claimed responsibility, and in which 191 people
were killed and 600 were injured.

According to passenger rail officials and passenger rail experts, certain
characteristics of domestic and foreign passenger rail systems make them
inherently vulnerable to terrorist attacks and therefore difficult to
secure. By design, passenger rail systems are open (i.e., have multiple
access points, hubs serving multiple carriers, and, in some cases, no
barriers) so that they can move large numbers of people quickly. In
contrast, the U.S. commercial aviation system is housed in closed and
controlled locations with few entry points. The openness of passenger rail
systems can leave them vulnerable because operator personnel cannot
completely monitor or control who enters or leaves the systems. In
addition, other characteristics of some passenger rail systems-high
ridership, expensive infrastructure, economic importance, and location
(e.g., large metropolitan areas or tourist destinations)-also make them
attractive targets for terrorists because of the potential for mass
casualties and economic damage and disruption. Moreover, some of these
same characteristics make passenger rail systems difficult to secure. For
example, the numbers of riders that pass through a subway system-
especially during peak hours-may make the sustained use of some security
measures, such as metal detectors, difficult because they could result in
long lines that could disrupt scheduled service. In addition, multiple
access points along extended routes could make the cost of securing each
location prohibitive. Balancing the potential economic

8These statistics do not include the July 2005 London attacks, which
resulted in over 50 fatalities and over 700 injuries.

impacts of security enhancements with the benefits of such measures is a
difficult challenge.

    Multiple Stakeholders Share Responsibility for Securing Passenger Rail
    Systems

Securing the nation's passenger rail systems is a shared responsibility
requiring coordinated action on the part of federal, state, and local
governments; the private sector; and rail passengers who ride these
systems. Since the September 11 attacks, the role of federal government
agencies in securing the nation's transportation systems, including
passenger rail, have continued to evolve. Prior to September 11, DOT-
namely FTA and FRA-was the primary federal entity involved in passenger
rail security matters. In response to the attacks of September 11,
Congress passed the Aviation and Transportation Security Act (ATSA), which
created TSA within DOT and defined its primary responsibility as ensuring
security in all modes of transportation.9 The act also gave TSA regulatory
authority for security over all transportation modes. ATSA does not
specify TSA's roles and responsibilities in securing the maritime and land
transportation modes at the level of detail it does for aviation security.
Instead, the act broadly identifies that TSA is responsible for ensuring
the security of all modes of transportation. With the passage of the
Homeland Security Act of 2002, TSA was transferred, along with over 20
other agencies, to the Department of Homeland Security.10

With the creation of DHS in 2002, one of its components, ODP, became the
primary federal source for security funding for passenger rail systems. 11
ODP is the principal component of DHS responsible for preparing the United
States for acts of terrorism and has primary responsibility within the
executive branch for assisting and supporting DHS, in coordination with
other directorates and entities outside of the department, in

9Pub. L. No. 107-71, 115 Stat. 597 (2001).

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

11The Department of Justice established ODP in 1998 within the Office of
Justice Programs. ODP was subsequently transferred to DHS's Directorate of
Border and Transportation Security upon DHS's creation in March 2003
(Homeland Security Act of 2002, section 403(5), 6 U.S.C. 203(5)). In March
2004, the Secretary of Homeland Security consolidated ODP with the Office
of State and Local Government Coordination to form the Office of State and
Local Government Coordination and Preparedness (SLGCP). SLGCP, which
reports directly to the DHS Secretary, was created to provide a "one-stop
shop" for the numerous federal preparedness initiatives applicable to
state and local governments. The proposed reorganization of DHS may result
in transferring portions of ODP to a newly established Directorate of
Preparedness.

conducting risk analysis and risk management activities of state and local
governments.12 In carrying out its mission, ODP provides training, funds
for the purchase of equipment, support for the planning and execution of
exercises, technical assistance, and other support to assist states, local
jurisdictions, and the private sector to prevent, prepare for, and respond
to acts of terrorism. Through the Urban Area Security Initiative (UASI)
grant program, ODP has provided grants to urban areas to help enhance
their overall security and preparedness level to prevent, respond to, and
recover from acts of terrorism. In 2003 and 2004, $65 million and $50
million, respectively, were allocated to rail transit agencies through the
UASI program. In addition, the DHS Appropriations Act of 2005 appropriated
$150 million for rail transit, intercity passenger rail, freight rail, and
transit agency security grants. 13 This funding has allowed ODP to build
upon the work under way through the UASI program and create and administer
two new programs focused specifically on transportation security, the
Transit Security Grant Program and the Intercity Passenger Rail Security
Grant Program. These programs provide financial assistance to address
security preparedness and enhancements for transit (to include commuter,
heavy, and light rail systems, intracity bus, and ferry), and intercity
rail (Amtrak) systems. The grant programs specifically provide funding for
the prevention and detection of explosive devices and chemical,
biological, radiological, and nuclear agents. About $108 million was
provided to rail transit agencies and $7.1 million to Amtrak through these
grant programs in 2005.14

While TSA is the lead federal agency for ensuring the security of all
transportation modes, FTA conducts nonregulatory safety and security
activities, including safety- and security-related training, research,
technical assistance, and demonstration projects. In addition, FTA
promotes safety and security through its grant-making authority. FTA
provides financial assistance to rail transit agencies to plan and develop
new systems and operate, maintain, and improve existing systems. FTA
stipulates conditions of grants, such as certain safety and security
statutory and regulatory requirements, and FTA may withhold funds for

12At the time of our review, DHS was undertaking a departmentwide
reorganization that will affect both the structure and functions of DHS
directorates and component agencies.

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

14The remaining funds were used to provide security grants for intracity
bus and freight rail systems and for technical assistance and management
and administration purposes. 49 USC 5307 (d)(1)(J)(i).

noncompliance with the conditions of a grant.15 While FTA cannot regulate
safety and security operations at transit agencies,16 FRA has regulatory
authority for rail safety over commuter rail operators and Amtrak, and
employs over 400 rail inspectors that periodically monitor the
implementation of safety and security plans at these systems.17

State and local governments, passenger rail operators, and private
industry are also important stakeholders in the nation's rail security
efforts. State and local governments play a vital role, in part, because
they may own or operate a significant portion of the passenger rail
system. Even when state and local governments are not owners and
operators, they are directly affected by passenger rail systems that run
within and through their jurisdictions. Consequently, the responsibility
for responding to emergencies involving the passenger rail infrastructure
often falls to state and local governments.

Passenger rail operators, which can be public or private entities, are
responsible for administering and managing passenger rail activities and
services, including security. Passenger rail operators can directly
operate the service provided or contract for all or part of the total
service. Although all levels of government are involved in passenger rail
security, the primary responsibility for securing passenger rail systems
rests with the passenger rail operators. We discuss actions taken by
federal agencies and passenger rail operators to enhance security in more
detail later in this report.

15For example, transit agencies must spend 1 percent of their urbanized
area formula funds on security improvements. FTA is to verify that
agencies comply with this requirement and may withhold funding from
agencies that it finds are not in compliance. Agencies are not required to
comply with this spending rule if a valid justification can be documented,
such as state and local funds for security are inadequate or security
trend data do not warrant security spending.

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

17FRA administers and enforces the federal laws and related regulations
that are designed to promote safety on railroads, such as track
maintenance, inspection standards, equipment standards, and operating
practices. FRA exercises jurisdiction over all areas of railroad safety
under 49 U.S.C. 20103.

    Assessing and Managing Risks to Rail Infrastructure Using a Risk Management
    Approach

In recent years, we, along with Congress (most recently through the
Intelligence Reform and Terrorism Prevention Act of 2004),18 the executive
branch (e.g., in presidential directives), and the 9/11 Commission have
required or advocated that federal agencies with homeland security
responsibilities utilize a risk management approach to help ensure that
finite national resources are dedicated to assets or activities considered
to have the highest security priority. We have concluded that without a
risk management approach, there is limited assurance that programs
designed to combat terrorism are properly prioritized and focused. Thus,
risk management, as applied in the homeland security context, can help to
more effectively and efficiently prepare defenses against acts of
terrorism and other threats.

A risk management approach entails a continuous process of managing risk
through a series of actions, including setting strategic goals and
objectives, performing risk assessments, evaluating alternative actions to
reduce identified risks by preventing or mitigating their impact,
selecting actions to undertake by management, and implementing and
monitoring those actions. Figure 2 depicts a risk management cycle that is
our synthesis of government requirements and prevailing best practices
previously reported.

                        Figure 2: Risk Management Cycle

                                  Source: GAO.

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

Setting strategic goals, objectives, and constraints is a key first step
in implementing a risk management approach and helps to ensure that
management decisions are focused on achieving a strategic purpose. These
decisions should take place in the context of an agency's strategic plan
that includes goals and objectives that are clear, concise, and
measurable.

Risk assessment, a critical element of a risk management approach, helps
decision makers identify and evaluate potential risks so that
countermeasures can be designed and implemented to prevent or mitigate the
effects of the risks. Risk assessment is a qualitative and/or quantitative
determination of the likelihood of an adverse event occurring and the
severity, or impact, of its consequences. Risk assessment in a homeland
security application often involves assessing three key elements-threat,
criticality, and vulnerability:

o  	A threat assessment identifies and evaluates potential threats on the
basis of factors such as capabilities, intentions, and past activities.

o  	A criticality or consequence assessment evaluates and prioritizes
assets and functions in terms of specific criteria, such as their
importance to public safety and the economy, as a basis for identifying
which structures or processes are relatively more important to protect
from attack.

o  	A vulnerability assessment identifies weaknesses that may be exploited
by identified threats and suggests options to address those weaknesses.

Information from these three assessments contributes to an overall risk
assessment that characterizes risks on a scale such as high, medium, or
low and provides input for evaluating alternatives and management
prioritization of security initiatives.19 Additional details on these
assessment elements can be found in appendix II. The risk assessment
element in the overall risk management cycle may be the largest change
from standard management steps and is central to informing the remaining
steps of the cycle.

19GAO, Transportation Security: Systematic Planning Needed to Optimize
Resources, GAO-05-357T (Washington D.C.: Feb. 15, 2005); Homeland
Security: A Risk Management Approach Can Guide Preparedness Efforts,
GAO-02-208T (Washington, D.C.: Oct. 31, 2001); and Combating Terrorism:
Threat and Risk Assessments Can Help Prioritize and Target Program
Investments, GAO/NSIAD-98-74 (Washington, D.C.: April 9, 1998).

The next step in a risk management approach-alternatives evaluation-
considers what actions may be needed to address identified risks, the
associated costs of taking these actions, and any resulting benefits. This
information is then to be provided to agency management to assist in the
selection of alternative actions best suited to the unique needs of the
organization. An additional step in the risk management approach is the
implementation and monitoring of actions taken to address the risks,
including evaluating the extent to which risk was mitigated by these
actions. Once the agency has implemented the actions to address risks, it
should develop criteria for and continually monitor the performance of
these actions to ensure that they are effective and also reflect evolving
risk.

    Federal Agencies with Risk Management Responsibilities

A number of federal departments and agencies have risk management and
critical infrastructure protection responsibilities stemming from various
requirements. The Homeland Security Act of 2002, which created DHS,
directed the department's Information Analysis and Infrastructure
Protection (IAIP) Directorate to utilize a risk management approach in
coordinating the nation's critical infrastructure protection efforts. This
includes using risk assessments to set priorities for protective and
support measures by the department, other federal agencies, state and
local government agencies and authorities, the private sector, and other
entities. Homeland Security Presidential Directive 7 (HSPD-7) defines
critical infrastructure protection responsibilities for DHS,
sector-specific agencies (those federal agencies given responsibility for
transportation, energy, telecommunications, and so forth), and other
departments and agencies. The President instructs federal departments and
agencies to identify, prioritize, and coordinate the protection of
critical infrastructure to prevent, deter, and mitigate the effects of
terrorist attacks. The Secretary of DHS is assigned several
responsibilities by HSPD-7, including establishing uniform polices,
approaches, guidelines, and methodologies for integrating federal
infrastructure protection and risk management activities within and across
sectors. To ensure the coverage of critical sectors, HSPD-7 designated
sector-specific agencies for 17 critical infrastructure sectors.20 These
agencies are responsible for infrastructure

20Sector-specific agencies have been designated for the following sectors:
transportation; agriculture and food; public health and health care;
drinking water and wastewater treatment; energy; banking and finance;
national monuments and icons; defense industrial base; information
technology; telecommunications; chemical; emergency services; postal and
package shipping; dams; government facilities; commercial facilities; and
nuclear reactors, materials, and waste.

protection activities in their assigned sectors, including coordinating
and collaborating with relevant federal agencies, state and local
governments, and the private sector to carry out their responsibilities
and facilitating the sharing of information about vulnerabilities,
incidents, potential protective measures, and best practices.

Pursuant to HSPD-7 and the National Infrastructure Protection Plan (NIPP),
DHS was designated as the sector-specific agency for the transportation
sector, a responsibility the department has delegated to TSA.21 As the
sector-specific agency for transportation, TSA is required to develop a
transportation sector-specific plan (TSSP) for identifying, prioritizing,
and protecting critical transportation infrastructure and key resources
that will provide key input to the broader NIPP to be prepared by IAIP.
DHS issued an interim NIPP in February 2005 that was intended to serve as
a road map for how DHS and stakeholders-including other federal agencies,
the private sector, and state and local governments- should use risk
management principles for determining how to prioritize activities related
to protecting critical infrastructure and key resources within and among
each of the 17 sectors in an integrated, coordinated fashion. DHS expects
the next iteration of the NIPP to be issued in November 2005, with the
sector-specific plans, including the TSSP, being incorporated into this
plan in February 2006. HSPD-7 also requires DHS to coordinate with DOT on
all transportation security matters. Table 1 summarizes selected
responsibilities for federal agencies with lead or supporting roles for
critical infrastructure protection and risk management efforts.

21The transportation sector includes mass transit; aviation; maritime;
ground/surface; and rail and pipeline systems.

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

                             Agency with lead         Related output 
                                                            of       
      Statute or       or supporting role Selected        action     Due date 
       directive             responsibilities                        
Homeland Security    IAIPa Coordinates national                   
          Act                    critical                            
        of 2002       infrastructure protection (CIP)                
                               efforts by:                           

                                       o

                                       o

                                       o

conducting risk assessments of key resources and critical infrastructure
to determine the risks posed by terrorist attacks within the United
States;

integrating relevant information, analyses, and assessments (whether
conducted by department or others) in order to identify priorities for
protective and support measures;

recommending measures to protect the key resources and critical
infrastructure of the United States in coordination with other federal
agencies and in cooperation with state and local government

Develop a Not specified
comprehensive national
plan for securing the key
resources and critical
infrastructure

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

ODPa 	As the principal federal agency in preparing the United States for
acts of terrorism:

o  	assists and supports DHS in conducting appropriate risk analysis and
risk management activities of state, local, and tribal governments;

o  	serves as primary office responsible for providing training, funds for
the purchase of equipment, support for the planning and execution of
exercises.

Risk analysis and risk Not applicable
management activities
for states and local
jurisdictions

                               Coordinate national CIP                        
Homeland Security                   efforts by:  o      National     
     Presidential    IAIPb  identifying, prioritizing,  Infrastructure  12/04
      Directive-7                 and coordinating the Protection Plan  
                                protection of critical                  
                           infrastructure, emphasizing                  
                               protection against                       
                                  catastrophic                          
                                health effects or mass                  
                                           casualties;                  
                             o  establishing uniform                    
                                    policies,                           
                           approaches, guidelines, and                  
                                methodologies for                       
                                   integrating                          
                                federal infrastructure                  
                                        protection and                  
                            risk management activities                  
                                                within                  
                               and across sectors.                      

Agency with lead Related output of Statute or directive or supporting role
Selected responsibilities action Due date

TSAc 	As sector-specific agency for transportation:

o  	identify, prioritize, and coordinate the protection of critical
transportation systems infrastructure, including conducting and
facilitating vulnerability assessments and encouraging risk management
strategies;

o  	coordinate and collaborate with relevant federal agencies, state and
local governments, and the private sector.

Transportation Sector-12/04 Specific Plan

     DOTd      Support CIP activities in       Not applicable  Not applicable 
               transportation sector by:                      
           o  collaborating with DHS on all                   
           matters relating to transportation                 
              security and transportation                     
              infrastructure protection.                      

Intelligence Reform and TSAe Develop, prepare, implement, and National
Strategy for 4/05 Terrorism Prevention Act update as needed a National
Transportation Security of 2004

Strategy for Transportation Security, including:

                                     o   o

                                       o

development of transportation modal security plans;

identification and evaluation of transportation assets that must be
protected from terrorist attack;

development of risk-based priorities across all transportation modes and
realistic deadlines for addressing security needs associated with those
assets.

DOT 	Works jointly with DHS to develop, Not applicable Not applicable
revise, and update the National Strategy for Transportation Security

Source: GAO analysis of federal roles and responsibilities related to risk
management and critical infrastructure protection.
aLead role designated by statute.
bLead role for all sectors; responsibility delegated by DHS.
cLead role for transportation sector; responsibility delegated by DHS.
dSupporting role for DHS.
eLead role delegated by DHS.

  DHS Has Taken Steps to Assess Risk to Passenger Rail Systems, but Additional
  Work Is Needed to Guide Security Investments

DHS component agencies have taken various steps to assess the risk posed
by terrorism to U.S. passenger rail systems. ODP has developed and
implemented a risk assessment methodology intended to help passenger rail
operators and others enhance their capacity to respond to terrorist
incidents and identify and prioritize security countermeasures. As of July
2005, ODP had completed 7 risk assessments with rail operators and 12
others were under way. Further, TSA completed a threat assessment for mass
transit and rail and has begun to identify critical rail assets, but it
has not yet completed an overall risk assessment for the passenger rail
industry. DHS is developing guidance to help these and other
sectorspecific agencies work with stakeholders to identify and analyze
risk.

    ODP Has Worked with Passenger Rail Operators to Develop Risk Assessments to
    Help Prioritize Rail Security Needs and Investments

In 2002, ODP began conducting risk assessments of passenger rail operators
through its Mass Transit Technical Assistance program. These assessments
are intended to help passenger rail operators and port authorities enhance
their capacity and preparedness to respond to terrorist incidents
involving weapons of mass destruction, and identify and prioritize
security countermeasures and emergency response capabilities. ODP's
approach to risk assessment is generally consistent with the risk
assessment component of our risk management approach. The agency has
worked with passenger rail operators and others to complete several risk
assessments. As of July 2005, ODP had completed 7 risk assessments in
collaboration with passenger rail operators.22 Twelve additional risk
assessments are under way, and an additional 11 transit agencies have
requested assistance through this program.

ODP's methodology for conducting risk assessments is articulated in a tool
kit designed to enable passenger rail operators and others to compare
relative risks among assets, identify assets with a perceived high level
of risk, and prioritize measures to mitigate those risks.23 Once ODP and a
rail operator agree to collaborate on the risk assessment, ODP sends a

22ODP has completed risk assessments with the Port Authority of New York
and New Jersey, New Jersey Transit, Massachusetts Bay Transportation
Authority, Washington Metropolitan Area Transit Authority, Southeastern
Pennsylvania Transportation Authority, Tri-County Metropolitan
Transportation District of Oregon, and the Delaware River Port Authority.

23According to ODP, risk assessment methodologies from a variety of
sources were reviewed as part of the tool kit's development, including
various state transportation risk assessment methods, airport
vulnerability methods, and DOT infrastructure assessment methods.

technical assistance team consisting of experts in the risk management and
emergency response field to visit the rail operator on-site to support the
implementation of the risk assessment process. The team assists the
operator in using the tool kit to generate information on criticality,
threat, vulnerability, impact, and risk. Once completed, the documented
results should serve as a guide for future applications of the risk
assessment process to keep pace with new threat information and newly
vulnerable assets.

ODP's risk assessment process involves, first, an analysis of four
elements-criticality, threat, vulnerability, and impact. Using the tool
kit, the operator begins by conducting the criticality assessment to
identify and prioritize critical assets based upon factors such as the
potential for serious injury or loss of life, or the economic implications
on the livelihood, resources, or wealth of the area, region, or country if
the asset was destroyed. Assets deemed to be "most critical" are then
evaluated using the remaining risk assessment components. The operator
then conducts the threat assessment to identify the range of weapon types
that terrorists might use against the operator's critical assets,
establish the likelihood that critical assets might be targeted, and
develop possible attack scenarios. These attack scenarios are then used to
perform a vulnerability assessment that evaluates the susceptibility of
critical assets to these scenarios and determines such things as the
probability of an attack succeeding and whether it can be stopped. Once
these first three assessment components are completed, the operator
determines the impact that the partial or complete destruction of a
critical asset would have on the asset's ability to function based upon
specific threat scenarios. Table 2 describes selected steps that operators
take, in conjunction with ODP, to carry out these four assessment
components using ODP's risk assessment tool kit.

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

Assessment component Assessment steps

Criticality

Step 1. Develop a worksheet of candidate critical assets (i.e.,
infrastructure, facilities, equipment, and personnel) that enable the
operator to achieve its mission.

Step 2. Establish critical asset factors-factors that describe the
characteristics of assets that would result in significant negative impact
to the operator given their loss in a terrorist event (i.e., economic
impact, symbolic importance, functional importance).

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

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

Step 5. Prioritize assets based upon their criticality scores. Rail
operator officials review rankings to determine their reasonableness and
to establish a threshold for the assets considered most critical.

Threat 	Step 1. Develop a list of weapons types (i.e., large or small
explosives, biological conventional explosive, nuclear device) that might
be used by terrorists.

Step 2. Evaluate the selected weapon types on the likelihood (using a
five-point scale) that terrorists have each weapon and would use it
against the operator's assets.

Step 3. Evaluate the attractiveness of targets based on the potential for
casualties, potential for economic disruption, and symbolic importance.

Step 4. Define attack scenarios (based on target asset, weapon, and mode
of delivery); the information will be used in subsequent assessment
components.

Vulnerability 	Step 1. Develop a rating to determine the probability of a
successful attack. Rating is based upon three factors: the ability to
limit or deny ingress and egress to an asset by a terrorist (access
control), the ability to expose or reveal an attack before it takes place
(detection capabilities), the ability to interdict once an attack has been
detected (interdiction capabilities).

Step 2. Using these probability ratings, develop an overall vulnerability
rating that represents the relative likelihood of an attack being
attempted and successfully carried out.

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

Step 2. Once each asset has been rated, use a mathematical formula to
calculate a total overall impact level-how each asset's mission is
affected based upon the extent to which it would be destroyed.

Source: GAO analysis of ODP information.

The results developed in the threat, criticality, vulnerability, and
impact assessments are then used to develop an overall risk assessment in
order to evaluate the relative risk among various assets, weapons, and
modes of attack. This is intended to give operators an indication of which
asset types and threat scenarios carry the highest risk and that,
accordingly, are likely candidates for early risk mitigation action. Using
the results of the risk assessment process, a diagram of relative risk is
developed by plotting

the assets and scenarios in terms of vulnerability and consequence, as
shown in figure 3. 24

Figure 3: Sample ODP Relative Risk Diagram

By showing the relative risk of all assets and scenarios identified, this
diagram identifies the assets and scenarios that have the greatest
estimated level of relative risk and provides critical information useful
to develop and prioritize security countermeasures. According to ODP,
assets with scenarios that fall in quadrants I and III have the greatest
potential negative impact (i.e., the greatest consequence) on an
operator's system if attacked. Assets with scenarios that fall in
quadrants I and II have the greatest vulnerability to attack. Therefore,
quadrant I contains the assets and scenarios that have the greatest
vulnerability and negative consequence and are likely candidates for early
mitigation action from a policy decision-making perspective.

According to rail operators who have used ODP's risk assessment
methodology and commented about it to DHS or us, the method has been
successful in helping to devise risk reduction strategies to guide
security

24"Consequence" is defined as the portion of an asset's criticality that
would be reduced as a result of a successful attack.

related investments. For example, between September 2002 and March 2003,
ODP's technical assistance team worked with the Port Authority of New York
and New Jersey (PANYNJ) to conduct a risk assessment of all of its
assets-its Port Authority Trans-Hudson (PATH) passenger rail system, as
well as airports, ports, interstate highway crossings, and commercial
properties.25 According to PANYNJ officials, the authority was able to
develop and implement a risk reduction strategy that enabled it to
identify and set priorities for improvements in security and emergency
response capability that are being used to guide security investments.

As part of this risk assessment, PANYNJ identified and prioritized
particular types of security countermeasures that, if implemented, would
improve the authority's overall risk profile by moving assets into the
lower parts of the risk diagram (as shown in fig. 3). Examples of
countermeasures considered include site-hardening of assets such as
bridges and tunnels; increased patrols, guards, and canine units;
eventactivated closed-circuit television (CCTV); and intrusion detection
systems. According to PANYNJ officials, the associated costs and benefits
of the countermeasures identified were considered, and management was
involved in choosing and prioritizing the actions included in the plan.
More specifically, according to authority officials, the risk assessment
was instrumental in obtaining management approval for a 5-year, $500
million security capital investment program, as it provided a risk-based
justification for these investments.26 Examples of passenger rail security
capital investments PANYNJ is making as part of this program include the
development of a state-of-the art system wide security operations center
for the PATH system, access control and alarm monitoring system
replacement at 45 locations, and digital video recording upgrades to its

25PANYNJ is a bistate public agency that manages and maintains bridges,
tunnels, bus terminals, airports, the PATH passenger rail system, and
seaports in the greater New York/New Jersey metropolitan area. PANYNJ was
also the property owner and operator of the World Trade Center site and
the PATH passenger rail station underneath the site that was destroyed by
the September 11 terrorist attacks. At the request of PANYNJ, ODP's
technical assistance team worked with authority personnel to conduct the
first risk assessment using ODP's model. This collaborative effort
provided the means for ODP to test and refine its methodology and develop
the tool kit now in use.

26On the basis of the ODP and prior risk assessments and identified risks,
PANYNJ identified approximately $1 billion dollars in security investments
or actions. The current $500 million capital investment program was based
directly on the highest risks identified in the assessment. The initial
$500 million program did not include countermeasures identified by the
assessments that could not be implemented immediately. For example, the
authority viewed countermeasures, such as weapons of mass destruction
detection systems, as cost-prohibitive until technological advances are
made in this arena.

CCTV system. At the time of our review, the authority was 2 years into
implementing the strategy and associated capital investment program and
had just completed its first risk assessment update. PANYNJ officials told
us they have formally incorporated the ODP risk assessment model into the
authority's annual planning and budgeting cycle and are able to track and
assess how security projects improve the authority's overall risk profile.
PANYNJ staff are now working on a cost-benefit module to be included in
the authority's risk assessment program, with the objective of making more
discrete trade-offs among high-cost security programs on the basis of
which ones provided the highest payoff.

The six other passenger rail operators that have completed ODP's risk
assessment process also stated that they valued the process. Specifically,
operators said that the assessments enabled them to prioritize investments
based on risk and are already allowing or are expected to allow them to
effectively target and allocate resources toward security measures that
will have the greatest impact on reducing risk across their system. For
example, one rail operator stated that it is planning on spending its
fiscal year 2005 Transit Security Grant Program funding to expand its CCTV
coverage, with a focus on stations that serve major public gatherings but
do not have such equipment, a measure identified by the risk assessment as
the second most effective risk reduction measure to implement. 27 In
addition, as a result of the assessment, the operator said that it has
incorporated CCTVs into its standard design criteria for new system
construction, such as stations and parking garages.

ODP Has Sought to On the basis of its own experience with conducting risk
assessments in the Promote Risk-Based field, and in keeping with its
mission to develop and implement a national Decision Making among program
to enhance the capacity of state and local agencies to respond to

incidents of terrorism, ODP has offered to help other DHS
componentsFederal Agencies and Rail and federal agencies to develop risk
assessment tools, according to ODPOperators officials. For example, ODP is
partnering with the FRA, TSA, the American

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

27The assessment identified the most effective risk reduction measure as
training employees and informing the public to serve as the "eyes and
ears" and report suspicious objects and behaviors. While, according to the
agency, it had undertaken comprehensive steps in these areas, the
assessment pointed out the usefulness of making these efforts a permanent
part of training, procedures, and public information.

tool for freight rail corridors. 28 In a separate federal outreach effort,
ODP worked with TSA to establish a Federal Risk Assessment Working Group
to promote interagency collaboration and information sharing.
Representatives from participating federal agencies meet monthly to
encourage information sharing regarding risk assessments and other related
homeland security issues.29 The working group has, among other things,
created a Web-based calendar so participating agencies can upload and
share information regarding planned assessments. The calendar also
contains detailed information on assessments, including locations, dates,
types of assessment, and points of contact.

In addition, in keeping with its mission to deliver technical assistance
and training, ODP has partnered with the American Public Transportation
Association (APTA) to inform passenger rail operators about its risk
assessment technical assistance program. 30 Since June 2004, ODP has
attended five APTA conferences or workshops where it has set up
information booths, made the tool kit available, and conducted seminars to
educate passenger rail operators about the risk assessment process and its
benefits. According to an APTA official, ODP's risk assessment technical
assistance program has been well received by the transit community. The
program is dependent on funding available in ODP's technical assistance
budget for support. In fiscal years 2004 and 2005, the program received
$5.2 million and $5.7 million, respectively, through ODP's technical
assistance budget.

ODP has leveraged its grant-making authority to promote risk-based funding
decisions for passenger rail. For example, passenger rail operators must
have completed a risk assessment to be eligible for financial

28The American Association of Railroads is an association representing the
interests of the rail industry, focused mostly at the federal level. Its
members are primarily freight rail operators in the United States, Canada,
and Mexico. However, it also represents some passenger rail interests,
including Amtrak.

29Participating agencies include DHS's Office of State and Local
Government Coordination and Preparedness, DHS's U.S. Coast Guard, DHS's
Information Analysis and Infrastructure Protection Directorate, the
Department of Defense's U.S. Transportation Command, DOT's Federal Transit
Administration, and DOT's Federal Highway Administration.

30The American Public Transportation Association is a nonprofit trade
association representing over 1,500 public and private member
organizations, including transit systems and commuter rail operators;
planning, design, construction, and finance firms; product and service
providers; academic institutions; transit associations; and state
departments of transportation.

assistance through the fiscal year 2005 Transit Security Grant program
administered by ODP. To receive these funds, passenger rail operators are
also required to have a security and emergency preparedness plan that
identifies how the operator intends to respond to security gaps identified
by risk assessments. This plan, along with a regional transit security
strategy prepared by regional transit stakeholders, will serve as the
basis for determining how the grant funds are to be allocated.

Risk assessments are also a key driver of federal funds distributed
through ODP's fiscal year 2005 Intercity Passenger Rail Grant Program.
This $7.1 million program provides financial assistance to Amtrak for the
protection of critical infrastructure and emergency preparedness
activities along Amtrak's Northeast Corridor and its hub in Chicago.
Amtrak is required to conduct a risk assessment of these areas in
collaboration with ODP, in order to receive the grant funds.31 A recent
review of Amtrak's security posture and programs conducted by the RAND
Corporation and funded by FRA in 2004 found that no comprehensive
terrorism risk assessment of Amtrak has been conducted that would provide
an empirical baseline for investment prioritization and decision making
for Amtrak's security policies and investment plans. As another condition
for receiving the grant funds, Amtrak is required to develop a security
and emergency preparedness plan that, along with the risk assessment, is
to serve as the basis for proposed allocations of grant funding. According
to an Amtrak security official, it welcomes the risk assessment effort and
plans to use the results of the assessment to guide its security plans and
investments. According to ODP officials, as of July 2005, the Amtrak risk
assessment was nearly 50 percent complete.

    TSA Has Begun to Assess Risks to Passenger Rail

As the agency responsible for ensuring the security of all modes of
transportation, TSA has been charged by DHS with fulfilling key
requirements of HSPD-7 and the Intelligence Reform and Terrorism
Prevention Act of 2004. Specifically, TSA is required to conduct and

31Up to 30 percent of the available funds will be available to assist
Amtrak in meeting its most pressing security needs in the Northeast
Corridor and Chicago (as identified through previously conducted
site-specific assessments) prior to completion of the risk assessment.
However, the remainder of the grant funds will not be released until
Amtrak has completed the risk assessment and also submitted a security and
emergency preparedness plan. Amtrak is also required to demonstrate that
its planning process and allocations of funds are fully coordinated with
regional planning efforts in the National Capitol Region, Philadelphia,
New York, Boston, and Chicago. Amtrak is using approximately $700,000 of
the grant funds for the ODP risk assessment.

facilitate risk assessments in order to identify, prioritize, and
coordinate the protection of critical transportation systems
infrastructure, as well as develop risk-based priorities across all
transportation modes. As part of this effort, TSA is required to develop
plans that, among other things, identify and prioritize critical
transportation assets for protection. At the time of our review, TSA had
taken steps to meet these responsibilities but had not yet completed the
risk assessments for the rail industry (among others) or the plans that
they support as required.

In October 2004, TSA completed an overall threat assessment for both mass
transit and passenger and freight rail modes.32 TSA began conducting a
second risk assessment element-criticality assessments of passenger rail
stations-in the spring of 2004, but the effort had not been completed at
the time of our review. According to TSA, a criticality assessment tool
was developed that considers multiple factors, such as the potential for
loss of life or effects on public health; the economic impact of the loss
of function of the asset and the cost of reconstitution; and the local,
regional, or national symbolic importance of the asset. These factors were
to be used to arrive at a criticality score that, in turn, would enable
the agency to rank assets and facilities based on relative importance,
according to TSA officials.

To date, TSA has assigned criticality scores to nearly 700 passenger rail
stations. In May 2005, TSA began conducting assessments for other
passenger rail assets such as bridges and tunnels. TSA officials told us
that as of July 2005, they had completed 73 criticality assessments for
bridge and tunnel assets and expect to conduct approximately 370
additional assessments in these categories. Once TSA has completed its
criticality assessment, a senior group of transportation security experts
will review these scores and subsequently rank and prioritize them. As of
July 2005, TSA had not established a time frame for completing criticality
assessments for passenger rail assets or for ranking assets, and had not
identified whether it planned to do so.

In 2003, TSA officials stated that they planned to work with
transportation stakeholders to rank assets and facilities in terms of
their criticality. HSPD-7 requires sector-specific agencies such as TSA to
collaborate with all relevant stakeholders, including federal departments
and agencies,

32The results of TSA's passenger and freight rail threat assessments
contain information that is security sensitive or classified and therefore
cannot be disclosed in this report.

state and local governments, and others. In addition, DHS's interim NIPP
states that sector-specific agencies, such as TSA, are expected to work
with stakeholders-such as rail operators-to determine the most effective
means of obtaining and analyzing information on assets. While TSA's
methodology for conducting criticality assessments calls for "facilitated
sessions" involving TSA modal specialists, DOT modal specialists, and
trade association representatives, these sessions with stakeholders have
not been held. According to TSA officials, their final methodology for
conducting criticality assessments did not include DOT modal specialists
and trade associations. With respect to rail operators, TSA officials
explained that their risk assessment process does not require operators'
involvement. TSA analysts said they have access to a great deal of
information (such as open source records, satellite imagery, and insurance
industry data) that can facilitate the assessment process. However, when
asked to comment on TSA's ability to identify critical assets in passenger
rail systems, APTA officials and 10 rail operators we interviewed told us
it would be difficult for TSA to complete this task without their direct
input and rail system expertise.

TSA plans to rely on asset criticality rankings to prioritize which assets
it will focus on in conducting vulnerability assessments. That is, once an
asset, such as a passenger rail station, is deemed to be most critical,
then TSA would focus on determining the station's vulnerability to
attacks. TSA plans to conduct on-site vulnerability assessments for those
assets deemed most critical. For assets that are deemed to be less
critical, TSA has developed a software tool that it has made available to
passenger rail and other transportation operators for them to use on a
voluntary basis to assess the vulnerability of their assets. As of July
2005, the tool had not yet been used. According to APTA officials,
passenger rail operators may be reluctant to provide vulnerability
information to TSA without knowing how the agency intends to use such
information. According to TSA, it is difficult, if not impossible, to
project any timelines regarding completion of vulnerability assessments in
the transportation sector because rail operators are not required to
submit them. In this regard, while the rail operators are not required to
submit this information, as the sectorspecific agency for transportation,
TSA is required by HSPD-7 to complete vulnerability assessments for the
transportation sector. Figure 4 illustrates the overall progress TSA had
made in conducting risk assessments for passenger rail assets as of July
2005.

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

We recognize that TSA's risk assessment effort is still evolving and TSA
has had other pressing priorities, such as meeting the legislative
requirements related to aviation security. However, until all three
assessments of rail systems-threat, criticality, and vulnerability-have
been completed in sequence, and until TSA determines how to use the
results of these assessments to analyze and characterize risk (e.g.,
whether high, medium, or low), it may not be possible to prioritize
passenger rail assets and guide investment decisions about protecting
them.

Finalizing a methodology for assessing risk to passenger rail and other
transportation assets and conducting the assessments are key steps needed
to produce the plans required by HSPD-7 and the Intelligence Reform and
Terrorism Prevention Act of 2004. DHS and TSA have missed both deadlines
for producing these plans. Specifically, DHS and TSA have yet to produce
the TSSP required by HSPD-7 to be issued in December of 2004, though a
draft was prepared in November 2004. DHS and TSA officials told us that
they expected the first version of the TSSP to be completed in February
2006. DHS and TSA also missed the April 1, 2005, deadline for completing
the national strategy for transportation security required by the
Intelligence Reform and Terrorism Prevention Act of 2004. In an April 2005
letter to Congress addressing the missed deadline, the DHS Deputy
Secretary identified the need to more aggressively coordinate the
development of the strategy with other relevant planning work such as the
TSSP, to include further collaboration with DOT modal

administrations and DHS components. The Deputy Secretary further stated
that DHS expected to finish the strategy within 2 to 3 months. However, as
of July 31, 2005, the strategy had not been completed. In April 2005,
senior DHS and TSA officials told us that in addition to DOT, industry
groups such as APTA and AAR would also be more involved in developing the
TSSP and other strategic plans. However, as of July 2005, TSA had not yet
engaged these stakeholders in the development of these plans.

    DHS Faces Challenges in Comparing and Reconciling Risks and Prioritizing
    Investments within and across Sectors

As TSA, other sector-specific agencies, and ODP move forward with risk
assessment activities, DHS is concurrently developing guidance intended to
help these agencies work with their stakeholders to assess risk. HSPD-7
requires DHS to establish uniform policies, approaches, guidelines, and
methodologies for integrating federal infrastructure protection and risk
management activities within and across sectors. To meet this requirement,
DHS has, among other things, been working for nearly 2 years on a risk
assessment framework through IAIP.33 This framework is intended to help
the private sector and state and local governments to develop a consistent
approach to analyzing risk and vulnerability across infrastructure types
and across entire economic sectors, develop consistent terminology, and
foster consistent results. The framework is also intended to enable a
federal-level assessment of risk in general, and comparisons among risks,
for purposes of resource allocation and response planning. DHS has
informed TSA that this framework will provide overarching guidance to
sector-specific agencies on how various risk assessment methodologies may
be used to analyze, normalize, and prioritize risk within and among
sectors. The interim NIPP states that the ability to rationalize, or
normalize, results of different risk assessments is an important goal for
determining risk-related priorities and guiding investments. One core
element of the DHS framework-defining concepts, terminology, and metrics
for assessing risk-has yet to be completed. The completion date for this
element-initially due in September 2004-has been extended twice, with the
latest due date in June 2005. However, as of July 31, 2005, this element
has not been completed.

Because neither this element nor the framework as a whole has yet been
finalized or provided to TSA or other sector-specific agencies, it is not

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

clear what impact, if any, DHS's framework may have on ongoing risk
assessments conducted by, and the methodologies used by, TSA, ODP, and
others, and whether or how DHS will be able to use these results to
compare risks and prioritize homeland security investments among sectors.
Until DHS finalizes this framework, and until TSA completes its risk
assessment methodology, it may not be possible to determine whether
different methodologies used by TSA and ODP for conducting threat,
criticality, and vulnerability assessments generate disparate qualitative
and quantitative results or how they can best be compared and analyzed. In
addition, TSA and others will have difficulty taking into account whether
at some point TSA may be unnecessarily duplicating risk management
activities already under way at other agencies and whether other agencies'
risk assessment methodologies, and the data generated by these
methodologies, can be leveraged to complete the assessments required for
the transportation sector. In the future, the implementation of DHS's
departmentwide proposed reorganization could affect decisions relating to
critical infrastructure protection as new directorates are established,
such as the directorates of policy and preparedness, and other
preparedness assets are consolidated from across the department.

FTA and FRA were the primary federal agencies involved in passenger rail
security matters prior to the creation of TSA. Before and after September
11, these two agencies launched a number of initiatives designed to
strengthen passenger rail security. TSA also took steps to strengthen rail
security, including issuing emergency security directives to rail
operators and testing emerging rail security technologies for screening
passengers and baggage. Rail industry stakeholders and federal agency
officials raised questions about how effectively DHS had collaborated with
them on rail security issues. DHS and DOT have signed a memorandum of
understanding intended to identify ways that collaboration with federal
and industry stakeholders might be improved.

  Multiple Federal Agencies Have Taken Actions to Enhance Passenger Rail
  Security

    DOT Agencies Led Initial Efforts to Enhance Passenger Rail Security

Prior to the creation of TSA in November 2001, DOT agencies (i.e., modal
administrations)-notably FTA and FRA-were primarily responsible for the
security of passenger rail systems. These agencies undertook a number of
initiatives to enhance the security of passenger rail systems prior to and
after September 11. For example, prior to September 11, FTA offered
voluntary security assessments, sponsored training at the Transportation
Safety Institute, issued written guidelines to improve emergency response
planning, and partially funded a chemical detection demonstration project,
called PROTECT, at the Washington Metropolitan Area Transit Authority.

In response to the terrorist attacks on September 11, FTA, using an $18.7
million appropriation by the Department of Defense Emergency Supplemental
Act of 2002, launched a multipart transit security initiative, much of
which is still in place. The initiative included security assessments,
planning, drills, and training, as described below:

o  	Security readiness assessments: FTA deployed teams to assess security
at 32 rail transit operators. FTA chose these 32 agencies on the basis of
their ridership, vulnerability, and the potential consequences of a
terrorist attack. Each assessment included a threat and vulnerability
analysis, an evaluation of security and emergency plans, and a focused
review of the agency's unified command structure with external emergency
responders. FTA completed the assessments in late summer 2002.34

o  	Security and emergency management technical assistance: As of July
2005, FTA had provided technical assistance to 32 passenger rail agencies
on security and emergency plans and emergency response drills. This is
also a follow-on effort to the security assessments, as FTA is helping
transit agencies fill identified security gaps customized to the
individual agency's needs and operating characteristics.

o  	Emergency response drills: FTA offered transit agencies grants up to
$50,000 for organizing and conducting emergency preparedness drills.
According to FTA officials, FTA has awarded $3.4 million to over 80
transit agencies through these grants.

o  	Transit Safety and Security Roundtables program: FTA developed the
Transit Safety and Security Roundtables program, which brings together
safety and security chiefs of the 30 largest transit systems to share
information on technology and best practices and to develop relationships
between federal and local officials working in the areas of transit safety
and security. In October 2003, FTA and DHS, through TSA, sponsored the
most recent roundtable, in Washington, D.C. In October 2005, FTA and DHS
plan to hold a roundtable with safety and security representatives of the
50 largest transit agencies.

o  	Connecting Communities program: FTA developed and currently is
offering free emergency preparedness and security training to transit
agencies through its Connecting Communities Forums. These forums are

34FTA completed three additional assessments of rail transit agencies as
part of its technical assistance program.

designed to bring together personnel from small and medium-sized transit
agencies with their local emergency responders, including local
firefighters and police officers. The purposes of the forums are to give
the participants a better understanding of the roles played by transit
agencies and emergency responders and to allow participants to begin
developing the plans, tools, and relationships necessary to respond
effectively in an emergency. FTA sponsored 17 forums under this program
and has plans for the delivery of 12 more by the end of fiscal year 2006.
TSA has provided financial support to this program. In fiscal year 2005,
TSA transferred $100,000 to FTA to support the Connecting Communities
program.

o  	Transit Watch program: In 2003, FTA instituted the Transit Watch
campaign, a nationwide safety and security awareness program designed to
encourage the active participation of transit passengers and employees in
maintaining a safe transit environment. The program provides information
and instructions to transit passengers and employees so that they know
what to do and whom to contact in the event of an emergency in a transit
setting. Transit Watch invites riders and employees to be the "eyes and
ears" of their local transit system. FTA plans to continue this
initiative, in partnership with TSA and ODP, and offer additional security
awareness materials that address unattended bags and emergency evacuation
procedures for transit agencies.

o  	Additional security training: In addition to the programs and training
cited above, FTA worked with the National Transit Institute, Johns Hopkins
University, and the Transportation Safety Institute to expand safety and
security course offerings. For example, the National Transit Institute is
now offering a security awareness course to frontline transit employees
free of charge. The course covers skill sets for observing, determining,
and reporting people and items that are suspicious or out of place. FTA
also developed a training course for frontline transit employees to
recognize and react to terrorist activity. This course incorporates the
latest in international counterterrorism techniques.

o  	Security guidance: FTA also developed security guidance for transit
agencies based largely on the findings of the security readiness
assessments. For example, in November 2003, FTA issued its Top 20 Security
Program Action Items for Transit Agencies, which recommends measures for
transit agencies to implement into their security programs to improve both
security and emergency preparedness. Recommended practices include
performing background checks on employees, instituting access control
procedures, and providing security awareness training to frontline
employees. In 2003, FTA also issued recommended measures for

transit agencies to implement in responding to various DHS threat level
designations.

FTA has also used research and development funds to develop guidance for
security design strategies to reduce the vulnerability of transit systems
to acts of terrorism. In November 2004, FTA provided rail operators with
security considerations for transportation infrastructure. This guidance
provided recommendations intended to help operators deter and minimize
attacks against their facilities, riders, and employees by incorporating
security features into the design of rail infrastructure. (Additional
details on the use of this guidance are discussed later in this report.)

FRA has also taken a number of actions to enhance passenger rail security
since September 11. For example, it has assisted commuter railroads in
developing security plans, reviewed Amtrak's security plans, and helped
fund FTA security readiness assessments for commuter railroads. More
recently, in the wake of the Madrid terrorist bombings, nearly 200 FRA
inspectors, in cooperation with DHS, conducted multi-day team inspections
of each of the 18 commuter railroads and Amtrak to determine what
additional security measures had been put into place to prevent a similar
occurrence in the United States. FRA also conducted research and
development projects related to passenger rail security. These projects
included rail infrastructure security and trespasser monitoring systems
and passenger screening and manifest projects, including explosives
detection.

Although DOT modal administrations now play a supporting role in
transportation security matters since the creation of TSA, they remain
important partners in the federal government's efforts to improve rail
security, given their role in funding and regulating the safety of
passenger rail systems. Moreover, as TSA moves ahead with its passenger
rail security initiatives, FTA and FRA are continuing their passenger rail
security efforts.

    TSA Issued Mandatory Security Directives to Rail Operators but Faces
    Challenges Related to Compliance and Enforcement

In response to the March 2004 commuter rail attacks in Madrid and federal
intelligence on potential threats against U.S. passenger rail systems, TSA
issued security directives to the passenger rail industry in May 2004. TSA
issued these security directives to establish a consistent baseline
standard of protective measures for all passenger rail operators,
including Amtrak.35 The directives were not related to, and were issued
independent of, TSA's efforts to conduct risk assessments to prioritize
rail security needs. TSA considered the measures required by the
directives to constitute mandatory security standards that were required
to be implemented within 72 hours of issuance by all passenger rail
operators nationwide. In an effort to provide some flexibility to the
industry, the directives allowed rail operators to propose alternative
measures to TSA in order to meet the required measures. Table 3 contains
examples of security measures required by these directives.

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

TSA directives require passenger rail operators to:

o  designate coordinators to enhance security-related communications with
TSA

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

o  reinforce employee watch programs

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

o  	remove trash receptacles at stations determined by a vulnerability
assessment to be at significant risk and only to the extent practical,
except for clear plastic or bomb-resistant containers

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

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

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

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

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

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

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

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

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

Source: TSA.

Although TSA issued these directives, it is unclear how TSA developed the
required measures contained in the directives, how TSA plans to monitor

35According to TSA, in issuing the passenger rail and mass transit
security directives, TSA exercised its authorities under 49 U.S.C. 114. We
are currently examining whether TSA met all relevant legal requirements in
the promulgation of the directives.

and ensure compliance with the measures, how rail operators are to
implement the measures, and which entities are responsible for their
implementation. According to the former DHS Undersecretary for Border and
Transportation Security, the directives were developed based upon
consultation with the industry and a review of best practices in passenger
rail and mass transit systems across the country and were intended to
provide a federal baseline standard for security. TSA officials stated to
us that the directives were based upon FTA and APTA best practices for
rail security. Specifically, TSA stated that it consulted a list of the
top 20 actions FTA identified that rail operators can take to strengthen
security, FTA-recommended protective measures and activities for transit
agencies that may be followed based on current threat levels, and an APTA
member survey. While some of the directives correlate to information
contained in the FTA guidance, such as advocating that rail personnel
watch for abandoned parcels, vehicles, and the like, the source for many
of the directives is unclear. For example, the source material TSA
consulted does not support the requirement that train cabs or compartment
doors should be kept locked. Furthermore, the sources do not necessarily
reflect industry best practices, according to FTA and APTA officials.
FTA's list of recommended protective measures and the practices identified
in the APTA survey are not necessarily viewed as industry best practices.
For example, the APTA member survey that TSA used reports rail security
practices that are in use by operators but which are not best practices
endorsed by the group or other industry stakeholders.

TSA officials have stated that they understood the importance of
partnering with the rail industry on security matters, and that they would
draw on the expertise and knowledge of the transportation industry and
other DHS agencies, as well as all stakeholders, in developing security
standards for all modes of transportation, including rail. TSA officials
held an initial meeting with APTA, AAR, and Amtrak officials to discuss
the draft directives prior to their issuance and told them that they would
continue to be consulted prior to their final issuance. However, these
stakeholders were not given an opportunity to comment on a final draft of
the directives before their release because, according to TSA, DHS
determined that it was important to release the directives as soon as
possible to address a current threat to passenger rail. In addition, TSA
stated that because the directives needed to be issued quickly, there was
no public comment as part of the rule-making process. Shortly after the
directives were issued, TSA's Deputy Assistant Administrator for Maritime
and Land Security told rail operators at an APTA conference we attended in
June 2004 that if TSA determined that there is a need for the directives
to become permanent, they would undergo a notice-and-comment period

as part of the regulatory process. As of July 2005, TSA had not yet
determined whether it intends to pursue the rule-making process with a
notice-and-comment period.

APTA and AAR officials stated that because they were not consulted
throughout the development of the directives, the directives did not, in
their view, reflect a complete understanding of the passenger rail
environment or necessarily incorporate industry best practices. For
example, APTA, AAR, and some rail operators raised concerns about the
feasibility of installing bomb-resistant trash cans in rail stations
because they could direct the force of a bomb blast upward, possibly
causing structural damage in underground or enclosed stations. DHS's
Office for State and Local Government Coordination and Preparedness
recently conducted tests to determine the safety and effectiveness of 13
models of commercially available bomb-resistant trash receptacles. At the
time of our review, the results of these tests were not yet available.

Amtrak and FRA officials raised concerns about some of the directives, as
well, and told us they questioned whether the requirements reflected
industry best practices. For example, before the directives were issued,
Amtrak expressed concerns to TSA about the feasibility of the requirement
to check the identification of all adult passengers boarding its trains
because they did not have enough staff to perform these checks. However,
the final directive included this requirement, and after they were
released, Amtrak told TSA it could not comply with this requirement
"without incurring substantial additional costs and significant
detrimental impacts to its operations and revenues." Amtrak officials told
us that since passenger names would not be compared against any criminal
or terrorist watch list or database, the benefits of requiring such
identification checks were open to debate. To resolve its concern, and as
allowed by the directive, Amtrak proposed, and TSA accepted, random
identification checks of passengers as an alternative measure. FRA
officials further stated that current FRA safety regulations requiring
engineer compartment doors be kept unlocked to facilitate emergency
escapes36 conflicts with the security directive requirement that doors
equipped with locking mechanisms be kept locked. This requirement was not
included in the draft directives provided to stakeholders. TSA did call
one commuter rail operator prior to issuing the directives to discuss this
potential proposed measure, and the operator raised a concern about the
safety of the locked

3649 CFR 238.235.

door requirement. TSA nevertheless included this requirement in the
directives.

With respect to how the directives were to be enforced, rail operators
were required to allow TSA and DHS to perform inspections, evaluations, or
tests based on execution of the directives at any time or location. Upon
learning of any instance of noncompliance with TSA security measures, rail
operators were to immediately initiate corrective action. Monitoring and
ensuring compliance with the directives has posed challenges for TSA. In
the year after the directives were issued, TSA did not have dedicated
field staff to conduct on-site inspections. When the rail security
directives were issued, the former DHS Undersecretary for Border and
Transportation Security stated that TSA planned to form security
partnership teams with DOT, including FRA rail inspectors, to help ensure
that industry stakeholders complied with the directives. These teams were
to be established in order to tap into existing capabilities and avoid
duplication of effort across agencies. As of July 2005, these teams had
not yet been utilized to perform inspections. TSA has, however, hired rail
compliance inspectors to, among other things, monitor and enforce
compliance with the security directives. As of July 2005, TSA had hired 57
of up to 100 inspector positions authorized by Congress.37 However, TSA
has not yet established processes or criteria for determining and
enforcing compliance, including determining how rail inspectors or DOT
partnership teams will be used in this regard.

Establishing criteria for monitoring compliance with the directives may be
challenging because the language describing the required measures allows
for flexibility and does not define parameters. In an effort to
acknowledge the variable conditions that existed in passenger rail
environments, TSA designed the directives to allow flexibility in
implementation through the use of such phrases as "to the extent resources
allow," "to the extent practicable," and "if available." The directives
also include non-specific instructions that may be difficult to measure or
monitor, telling operators to, for example, perform inspections of key
facilities at "regular periodic intervals" or to conduct "frequent
inspections" of passenger rail cars. When the directives were issued, TSA
stated that it would provide rail operators with performance-based
guidance and examples of

37These positions were funded through the DHS Appropriations Act of 2005
and its accompanying conference report, which provided TSA with $12
million in funding for rail security activities.

announcements and signs that could be used to meet the requirements of the
directives, including guidance on the appropriate frequency and method for
inspecting rail cars and facilities. However, as of July 2005, this
information had not been provided.

Industry stakeholders we interviewed raised questions about how they were
to comply with the measures contained in the directives and which entities
were responsible for implementing the measures. According to an AAR
official, in June 2004, AAR officials and rail operators held a conference
call with TSA to obtain clarification on these issues. According to AAR
officials, in response to an inquiry about what would constitute
compliance for some of the measures, the then-TSA Assistant Administrator
for Maritime and Land Security told participants that the directives were
not intended to be overly prescriptive but were guidelines, and that
operators would have the flexibility to implement the directives as they
saw fit. The officials also asked for clarification on who was legally
responsible for ensuring compliance for measures where assets, such as
rail stations, were owned by freight railroads or private real estate
companies. According to AAR officials, TSA told them it was the
responsibility of the rail operators and asset owners to work together to
determine these responsibilities. However, according to AAR and rail
operators, given that TSA has hired rail inspectors and indicated its
intention to enforce compliance with the directives, it is critical that
TSA clarify what compliance entails for measures required by the
directives and which entities are responsible for compliance with measures
when rail assets are owned by one party but operated by another-such as
when private companies that own terminals or stations provide services for
commuter rail operations.

The challenges TSA has faced in developing security directives as
standards that reflect industry best practices-and which can be measured
and enforced-stem from the original emergency nature of the directives,
which were issued with limited input and review. TSA told rail industry
stakeholders when the directives were issued 15 months ago that the agency
would consider using the federal rule-making process as a means of making
the standards permanent. Doing so would require TSA to hold a
notice-and-comment period, resulting in a public record that reflects
stakeholders' input on the applicability and feasibility of implementing
the directives, along with TSA's rationale for accepting or rejecting this
input. While there is no guarantee that this process would produce more
effective security directives, it would be more transparent and could help
TSA in developing standards that are most appropriate for the industry and
can be measured, monitored, and enforced.

    TSA Has Begun Testing Rail Security Technologies

In addition to issuing security directives, TSA also sought to enhance
passenger rail security by conducting research on technologies related to
screening passengers and checked baggage in the passenger rail
environment. Beginning in May 2004, TSA conducted a Transit and Rail
Inspection Pilot (TRIP) study, in partnership with DOT, Amtrak, the
Connecticut Department of Transportation, the Maryland Transit
Administration, and the Washington Metropolitan Area Transit Authority
(WMATA). TRIP was a $1.5 million, three-phase effort to test the
feasibility of using existing and emerging technologies to screen
passengers, carry-on items, checked baggage, cargo, and parcels for
explosives. Figure 5 summarizes TRIP's three-phased approach.

Figure 5: Summary Information on TSA's Transit and Rail Inspection Pilot
Program Phases

Phase I: Screen commuter rail passengers and carry-on baggage before
trains are boarded using an explosive detection device similar in
appearance to an airport metal detector and other explosive screening
technologies.

Phase II: Screen passenger baggage including checked baggage, unclaimed
baggage, and cargo on longhaul Amtrak trains prior to departure.

Phase III: Screen passengers and their carry-on baggage on board a moving
commuter rail train. All passengers are required to enter the train in the
specially designed screening car, which was a commuter rail passenger car
that been reconfigured to hold screening equipment and security personnel.

Source: TSA.

According to TSA, all three phases of the TRIP program were completed by
July 2004. However, TSA has not yet issued a planned report analyzing
whether the technologies could be used effectively to screen rail
passengers and their baggage. According to TSA officials, a report on
results and lessons learned from TRIP is under review by DHS. TSA
officials told us that based upon preliminary analyses, the screening
technologies and processes tested would be very difficult to implement on
more heavily used passenger rail systems, such as mass transit systems in
large urban areas, because these systems carry high volumes of passengers
and have multiple points of entry. However, TSA officials stated to us
that the screening processes used in TRIP may be useful on certain
long-distance intercity train routes, which make fewer stops. Further,
officials stated that screening could be used either randomly or for all
passengers during certain high-risk events or in areas where a particular
terrorist threat is known to exist. For example, screening

technology similar to that used in TRIP was used by TSA to screen certain
passengers and belongings in Boston and New York during the Democratic and
Republican national conventions, respectively, in 2004.

APTA officials and the 28 passenger rail operators we interviewed-all who
are not directly involved in the pilot-agreed with TSA's preliminary
assessment. They told us they believed that the TRIP screening procedures
could not work in most passenger rail systems, given the number of
passengers using these systems and the open nature (e.g., multiple entry
points) of the systems. For example, as one operator noted, over 1,600
people pass through dozens of access points in New York's Penn Station per
minute during a typical rush hour, making screening of all passengers very
challenging, if not impossible. Passenger rail operators were also
concerned that screening delays could result in passengers opting to use
other modes of transportation. APTA officials and some rail operators we
interviewed said that had they been consulted by TSA, they would have
recommended alternative technologies to explore and indicated that they
hoped to be consulted on security technology pilot programs in the future.
FRA officials further stated that TSA could have benefited from earlier
and more frequent collaboration with them during the TRIP pilot than
occurred, and could have tapped their expertise to analyze TRIP results
and develop the final report. TSA research and development officials told
us that the agency has begun to consider and test security technologies
other than those used in TRIP, which may be more applicable to the
passenger rail environment. For example, TSA's and DHS's Science and
Technology Directorate are currently evaluating infrared cameras and
electronic metal detectors, among other things.

    DHS and DOT Are Taking Steps to Improve Coordination and Collaboration with
    Federal Agencies and Industry Stakeholders

In our prior transportation security work, we have called for improved
coordination among all levels of government and the private sector, as a
means of enhancing security across all transportation modes.38 In
September 2004, DHS and DOT signed a memorandum of understanding to
develop procedures by which the two departments could improve their
cooperation and coordination for promoting the safe, secure, and efficient
movement of people and goods throughout the transportation system. The MOU
defines broad areas of responsibility for each department. For example, it
states that DHS, in consultation with DOT and affected stakeholders, will
identify, prioritize, and coordinate the protection of

38GAO-03-263 and GAO-03-843.

critical infrastructure. The MOU was developed in response to a
recommendation we made in June 2003 in which we noted that the roles and
responsibilities of DOT and TSA for transportation security matters had
not been clearly defined. We emphasized the need for greater coordination
between DOT and TSA on transportation security efforts- noting that the
lack of coordination can lead to duplication or conflicting efforts and
gaps in preparedness. To improve coordination between DOT and DHS on
transportation security matters, we recommended that DOT and DHS develop a
mechanism, such as a memorandum, to clearly define roles and
responsibilities for transportation security matters, in such areas as the
development and implementation of security standards and regulations,
determining funding priorities, and interfacing with the transportation
industry.

The MOU between DHS and DOT represents an overall framework for
cooperation that is to be supplemented by additional signed agreements, or
annexes, between the departments. These annexes are to delineate the
specific security-related roles, responsibilities, resources, and
commitments for mass transit, rail, research and development, and other
matters. As of July 2005, separate annexes for mass transit security, rail
security, and research and development were at various stages of
development, according to DHS and DOT officials. DHS and DOT officials
told us that an annex for mass transit security had been prepared and was
undergoing final review by both departments. According to DHS and DOT
officials, the annex is intended to ensure that the programs and protocols
for incorporating stakeholder feedback and making enhancements to security
measures are coordinated.

According to officials, the mass transit annex will address how DHS's
Office of State and Local Government Coordination and Preparedness, TSA,
FTA, and DOT's Office of Intelligence, Security, and Emergency Management
are to coordinate their programs and services, including grants, training,
exercises, risk assessments, and technical assistance, in order to better
assist transit agencies in prioritizing and addressing their security
needs. For example, officials stated to us that the annex would likely
address coordination on such programs as FTA's Transit Watch and Transit
Safety and Security Roundtables programs, which are designed to raise
transit employees' on-the-job awareness about security and provide a forum
for stakeholders to share information on technology and best practices. In
addition, according to officials, the annex will require DHS and DOT to
consult on such matters as regulations and security directives that affect
security and will identify points of contact for coordinating this
consultation.

In addition to the annexes currently under development, DHS and DOT must
also complete an annex to define and clarify the respective roles and
responsibilities of DHS and DOT relating to public transportation security
within 45 days of the enactment of The Safe, Accountable, Flexible, and
Efficient Transportation Equity Act of 2005, which President Bush signed
on August 10, 2005. According to the law, this annex shall establish a
process to develop security standards for public transportation agencies;
create a method of direct coordination with public transportation agencies
on security matters; address any other issues determined to be appropriate
by the Secretary of Transportation and the Secretary of Homeland Security;
and include a formal and permanent mechanism to ensure coordination and
involvement by DOT, as appropriate, in public transportation security.39

In addition to their work on the MOU and related annexes, DHS and TSA have
taken other steps in an attempt to improve collaboration with DOT and
industry stakeholders. In April 2005, DHS officials stated that better
collaboration with DOT and industry stakeholders was needed to develop
strategic security plans associated with various homeland security
presidential directives and statutory mandates, such as the Intelligence
Reform and Terrorism Prevention Act of 2004, which required DHS to develop
a national strategy for transportation security in conjunction with DOT.
Responding to the need for better collaboration, DHS established a
senior-level steering committee in conjunction with DOT to coordinate
development of this national strategy. In addition, senior DHS and TSA
officials stated that industry groups will also be involved in developing
the national strategy for transportation security and other strategic
plans. Moreover, according to TSA's assistant administrator for intermodal
programs, TSA intends to work with APTA and other industry stakeholders in
developing security standards for the passenger rail industry.40

39Section 3028 of Pub. L. No. 109-59.

40APTA is a standards development organization recognized by DOT that has
set standards for commuter rail, mass transit, and bus safety and
operations.

  U.S. and Foreign Rail Operators Have Taken Similar Actions to Secure Rail
  Systems, and Opportunities for Additional Domestic Security Actions May Exist

U.S. passenger rail operators have taken numerous actions to secure their
rail systems since the terrorist attacks of September 11, in the United
States, and the March 11, 2004, attacks in Madrid. These actions included
both improvements to system operations and capital enhancements to a
system's facilities, such as track, buildings, and train cars. All of the
U.S. passenger rail operators we contacted have implemented some types of
security measures-such as increased numbers and visibility of security
personnel and customer awareness programs-that were generally consistent
with those we observed in select countries in Europe and Asia. We also
identified three rail security practices-covert testing, random screening
of passengers and their baggage, and centralized research and
testing-utilized by foreign operators or their governments that are not
currently utilized by domestic rail operators or the U.S. government.41

    Actions Taken by U.S. and Foreign Passenger Rail Operators to Strengthen
    Security Reflect Security Assessments, Budgetary Constraints, and Other
    Factors

All 32 of the U.S. rail operators we interviewed or visited reported
taking specific actions to improve the security and safety of their rail
systems by, among other things, investing in new security equipment,
utilizing more law enforcement personnel, and establishing public
awareness campaigns. Passenger rail operators we spoke with cited the 1995
sarin gas attacks on the Tokyo subway system and the September 11
terrorist attacks as catalysts for their security actions. After the
attacks, many passenger rail operators used FTA's security readiness
assessments of heavy and passenger rail systems as a guide to determine
how to prioritize their security efforts, as well as their own
understanding of their system's vulnerabilities, to determine what actions
to take to enhance security. Similarly, as previously mentioned, the rail
systems that underwent ODP risk assessments are currently using or plan to
use these assessments to guide their security actions. In addition, 20 of
the 32 U.S. operators we contacted or visited had conducted some type of
security assessment internally or through a contractor, separate from the
federally funded assessments. For example, some assessments evaluated
vulnerabilities of physical assets, such as tunnels and bridges,
throughout the passenger rail system. Passenger rail operators stated that
security-related spending by rail operators was also based, in part, on
budgetary considerations, as well as other practices used by other rail
operators that were identified through

41At the time we completed our work, in June 2005, these three practices
were not utilized. However, as discussed later in this report, some rail
operators began using random screening in the aftermath of the July bomb
attacks on the London subway system.

direct contact or during industry association meetings. 42 Passenger rail
operators frequently made capital investments to improve security, and
these investments often are not part of federal funding packages for new
construction unless they are part of new facilities being constructed.
According to APTA, 54 percent of transit agencies are facing increasing
deficits, and no operator covers expenses with fare revenue; thus,
balancing operational and capital improvements with security-related
investments has been an ongoing challenge for these operators. Several
foreign rail operators we interviewed also stated that funding for
security enhancements was limited in light of other funding priorities
within the rail system, such as personnel costs and infrastructure and
equipment maintenance.

Foreign rail operators we visited also told us that risk assessments
played an important role in guiding security-related spending for rail.
For example, one foreign rail operator with a daily ridership of 2.3
million passengers used a risk management methodology to assess risks,
threats, and vulnerabilities to rail in order to guide security spending.
The methodology is part of the rail operator's corporate focus on overall
safety and security and is intended to help protect the operator's various
rail systems against, among other things, terrorist attacks, as well as
other forms of corporate loss, such as service disruption and loss of
business viability. According to the operator, the methodology employs a
"riskinformed" approach to support management's business decision process
regarding security. Other than the results of risk assessments, issues
such as laws and regulations, and business requirements, are also taken
into consideration. The approach relies on a combination of risk, threat,
and vulnerability assessment and management, and focuses on proactive
prevention. Implementing the methodology involves all corporate
departments and staff at three activity levels:

o  	At the corporate level, the focus on security is articulated in a
threepart corporate security policy that states, among other things, that
managers are responsible for performing risk management activities in
their functional areas and maintaining cost-effective security measures.

42As we have previously reported, since the mid-1990s, federal funding for
transit and commuter rail operators has generally been limited to
assistance with capital projects involving building new transit service,
extensions of existing lines, or rehabilitation of existing transit
infrastructure, such as tracks, rolling stock, or stations. See
GAO-03-263.

o  	At the department level, department heads are responsible for
promoting security awareness, setting rules and guidelines, and allocating
security responsibilities (in the form of assigning "risk ownership").

o  	At the line level, managers are responsible for implementing the risk
assessment component of the methodology, consistent with the security
policy described earlier. This component, which involves an iterative
process, consists of identifying threats and quantifying risks (risk is
expressed as a function of likelihood and consequence); designing and
implementing security protective measures; and measuring compliance with
and the effectiveness of these measures, similar to our risk management
approach.

According to officials of the foreign rail operator, to measure
performance, the operator conducts periodic surveys to measure the
perceptions of riders and employees; rates the success of drills; and
measures the incidence of crime (such as pick pocketing). The operator's
security department also conducts audits to measure compliance and help
ensure that security procedures are being followed. Separately, the rail
operator's insurers review the security management of the rail system,
including the methodology, every 4 years.

    U.S. and Foreign Rail Operators Employ Similar Security Practices

Operational improvements

Both U. S. and foreign passenger rail operators we contacted have
implemented similar operational and capital improvements43 to enhance the
security of their systems.44 A summary of these efforts follows.

Customer awareness: Customer awareness programs we observed used signage
and announcements to encourage riders to alert train staff if they
observed suspicious packages, persons, or behavior. Of the 32 domestic
rail operators we interviewed, 30 had implemented a customer awareness
program or made enhancements to an existing program. FTA has assisted

43Operational enhancements are actions that involve changes to the way a
rail agency's staff operate their rail system on a day-to-day basis-such
as enhancing customer awareness, increasing the number and visibility of
security personnel, training employees, and implementing selective
passenger and baggage screening. Capital improvements include construction
of new facilities or rehabilitation of old facilities such as stations,
train yards, tracks, and so on, or purchase of new equipment to enhance
existing capabilities.

44Actions taken by Amtrak to enhance security are discussed later in this
report.

rail operators in this area by creating the Transit Watch program, in
cooperation with industry groups such as APTA. Transit Watch is a
nationwide safety and security awareness program designed to encourage the
active participation of transit passengers and employees in maintaining a
safe transit environment. FTA distributed education and training materials
to rail operators so these materials could be provided to customers and
employees. Rail operators stated that they attempt to entitle their
customer awareness programs so that customers can easily remember the
goals of the program. New York City Transit's "If You See Something, Say
Something" campaign and the WMATA program, "Is That Your Bag?" are
examples of this. (See fig. 6 for an example of public awareness signage).
Foreign rail operators we visited also attempt to enhance customer
awareness. For example, 11 of the 13 operators we interviewed had
implemented a customer awareness program. Similar to programs of U.S.
operators, these programs used signage, announcements, and brochures to
inform passengers and employees about the need to remain vigilant and
report any suspicious activities. Only one of the European passenger rail
operators that we interviewed has not implemented a customer security
awareness program, citing the fear or panic that it might cause among the
public.

Figure 6: Example of Passenger Rail Customer Awareness Poster

Source: WMATA.

Increased number and visibility of security personnel: Of the 32 U.S. rail
operators we interviewed, 23 had increased the number of security
personnel they utilized since September 11, to provide security throughout
their system or had taken steps to increase the visibility of their
security personnel. In addition to adding security personnel, many
operators stated that increasing the visibility of security was as
important as increasing the number of personnel. For example, several U.S.
and foreign rail operators we spoke with had instituted policies such as
requiring their security staff, in brightly colored vests, to patrol
trains or stations more frequently, so they are more visible to customers
and potential terrorists or criminals. These policies make it easier for
customers to contact security personnel in the event of an emergency, or
if they have spotted a suspicious item or person. At foreign sites we
visited, 10 of the 13 operators had increased the number of their security
officers throughout their systems in recent years because of the perceived
increase in risk of a terrorist attack. One rail operator, the Tokyo Metro
system, in addition to increasing the number of security personnel, has
also made them more visible. Tokyo Metro stations now include an elevated
security platform for security

personnel to stand on, which allows them to better see throughout the
station and allows passengers to see the security staff more easily.

Increased use of canine teams: Of the 32 U.S. passenger rail operators we
contacted, 21 had begun to use canine units, which include both dogs and
human handlers, to patrol their facilities or trains or had increased
their existing utilization of such teams. Often, these units are used to
detect the presence of explosives, or in some cases, drugs, and may be
called in when a suspicious package is detected. One operator we spoke
with uses its canines to patrol its system simply as a crime deterrent
rather than to detect explosives or drugs. Some operators that did not
maintain their own canine units stated that it was prohibitively expensive
to do so and that they could call in local police canine units if
necessary. In foreign countries we visited, passenger rail operators' use
of canines varied. In some Asian countries, canines were not culturally
accepted by the public and thus were not used for rail security purposes.
In contrast, most European passenger rail operators, as in the United
States, used canines for explosive detection or as deterrents.

Employee training: All of the domestic and foreign rail operators we
interviewed had provided some type of security training to their staff,
either through in-house personnel or an external provider. In many cases,
this training consisted of ways to identify suspicious items and persons
and how to respond to events once they occur. For example, the London
Underground and the British Transport Police developed the "HOT" method
for its employees to identify suspicious items in the rail system. In the
HOT method, employees are trained to look for packages or items that are
Hidden, Obviously suspicious, and not Typical of the environment. Items
that do not meet these criteria would likely receive a lower security
response than an item meeting all of the criteria. However, if items meet
all of these criteria, employees are to notify station managers, who would
call in the authorities and potentially shut down the station or take
other action. According to London Underground officials, the HOT method
has significantly reduced the number of system disruptions caused when a
suspicious item was identified. In addition, officials noted that the HOT
method is easy for rail employees to remember and is successful, in part,
because it provides rail employees with the discretion to make
securityrelated decisions on their own. According to British Transport
Police and London Underground officials, there have been no cases where
unattended packages that employees determined did not meet the HOT
criteria contained explosive devices. Several passenger rail operators in
the United States and abroad have trained their employees in the HOT
method. Several domestic operators had also trained their employees in

how to respond to terrorist attacks and provided them with wallet-size
cards highlighting actions they should take in response to various forms
of attack. (See fig. 7 for examples of cards that are distributed by the
San Francisco Bay Area Rapid Transit [BART] to their employees to help
them prevent or respond to terrorist attacks.) It is important to note
that training such as the HOT method is not designed to prevent acts of
terrorism like the July 2005 London attacks, where suicide bombers killed
themselves rather than leaving bombs behind.

      Figure 7: Wallet-size Cards Distributed to BART Employees Containing
                           Anti-terrorism Information

             Source: San Francisco Bay Area Rapid Transit District.

Officials from the London Underground also provided insights into the
importance of how training is provided to staff, in addition to the type
of training provided. In training rail station staff, London Underground
officials stressed the importance of direct supervisors or managers
providing security briefings to each employee or small groups of
employees. In doing so, officials stated that they believed it helps make
staff more aware of their responsibilities in certain situations, enables
supervisors to hold employees accountable for what they learned in
training, and allows employees to ask questions related to their specific
job duties.

Passenger and baggage screening practices: Some domestic and foreign rail
operators have trained employees to recognize suspicious behavior as a
means of screening passengers. Eight U.S. passenger rail operators we
contacted were utilizing some form of behavioral screening. For example,
the Massachusetts Bay Transportation Authority (MBTA), which operates
Boston's T system, has utilized a behavioral screening system to identify
passengers exhibiting suspicious behavior. The Massachusetts State Police
train all MBTA personnel to be on the lookout for behavior that may
indicate someone has criminal intent, and to approach and search such
persons and their baggage when appropriate. Massachusetts State Police
officers have been training rail operators on this behavior profiling
system, and WMATA and New Jersey Transit were among the first additional
operators to implement the system. According to MBTA personnel, several
other operators have expressed interest in this system. Abroad, we found
that 4 of 13 operators we interviewed had implemented forms of behavioral
screening similar to MBTA's system. (Rail operators' use of random
screening of passengers is discussed later in the report.)

All of the domestic and foreign rail operators we contacted have ruled out
an airport-style screening system for daily use in heavy traffic, where
each passenger and the passenger's baggage are screened by a magnetometer
or X-ray machine, based on cost, staffing, and customer convenience
factors, among others. For example, although the Spanish National Railway
screens passenger baggage using an X-ray machine on certain longdistance
trains that it believes could be at risk, all of the operators we
contacted stated that the cost, staffing requirements, delay of service,
and inconvenience to passengers would make such a system unworkable in
highly trafficked, inherently open systems like U.S. and foreign passenger
rail operations. In addition, one Asian rail official stated that his
organization was developing a contingency plan for implementing an
airport-style screening system, but that such a system would be used only
in the event of intelligence information indicating suicide bomb attacks

                              Capital improvements

were imminent, or if several attacks had already occurred during a short
period of time. According to this official, the plan was in the initial
stages of development, and the organization did not know how quickly such
a system could be implemented.

Upgrading technology: Many rail operators we interviewed had embarked on
programs designed to upgrade their existing security technology. For
example, we found that 29 of the 32 U.S. operators had implemented a form
of CCTV to monitor their stations, yards, or trains. While these cameras
cannot be monitored closely at all times, because of the large number of
staff they said this would require, many rail operators felt the cameras
acted as a deterrent, assisted security personnel in determining how to
respond to incidents that have already occurred, and could be monitored if
an operator has received information that an incident may occur at a
certain time or place in their system. One rail operator, New Jersey
Transit, had installed "smart" cameras, which were programmed to alert
security personnel when suspicious activity occurred, such as if a
passenger left a bag in a certain location or if a boat were to dock under
a bridge. According to the New Jersey Transit officials, this technology
was relatively inexpensive and not difficult to implement. Several other
operators stated they were interested in exploring this technology.

Abroad, all 13 of the foreign rail operators we visited had CCTV systems
in place. For example, the London Underground uses an extensive system of
CCTV cameras to monitor all of its passenger rail system stations and
respond to both criminal and emergency incidents. In addition, one Asian
system we visited had over 1,000 cameras recording activity in some of its
busier stations. However, as in the United States, foreign rail operators
use these cameras primarily as a crime deterrent and to respond to
incidents after they occur, because they do not have enough staff to
continuously monitor all of these cameras. The Madrid Metro is currently
testing the use of personal digital assistants (PDA), which would have the
ability to operate all security functions in passenger rail stations.
These PDAs would enable security staff to monitor any station CCTV camera
that they chose from the PDA and respond to a potential emergency, such as
a terrorist attack, by shutting down rail or station operations
(escalators or ventilation systems, amongst others) from the PDA itself.
Madrid Metro officials said that they plan to make the use of the PDAs
operational in the future, but did not know when they would do so.

In addition, 18 of the 32 U.S. rail operators we interviewed had installed
new emergency phones or enhanced the visibility of the intercom systems
they already had. Passengers can use these systems to contact train

operators or security personnel to report suspicious activity, crimes in
progress, or other problems. Furthermore, while most rail operators we
spoke with had not installed chemical or biological agent detection
equipment because of the costs involved, a few operators had this
equipment or were exploring purchasing it. For example, WMATA, in
Washington, D.C., has installed these sensors in some of its stations,
thanks to a program jointly sponsored by DOT and the Department of Energy
that provided this equipment to WMATA because of the high perceived
likelihood of an attack in Washington, D.C. Also, at least three other
domestic rail operators we spoke with are exploring the possibility of
partnering with federal agencies to install such equipment in their
facilities on an experimental basis.

Also, as in the United States, a few foreign operators had implemented
chemical or biological detection devices at these rail stations, but their
use was not widespread. Two of the 13 foreign operators we interviewed had
implemented these sensors, and both were doing so on an experimental
basis. In addition, police officers from the British Transport Police-
responsible for policing the rail system in the United Kingdom-were
equipped with pagers to detect chemical, biological, or radiological
elements in the air, allowing them to respond quickly in case of a
terrorist attack using one of these methods. The British Transit Police
also has three vehicles carrying devices to determine if unattended
baggage contains explosives-these vehicles patrol the system 24 hours per
day.

Access control: Tightening access procedures at key facilities or
rights-ofway is another way many rail operators have attempted to enhance
security. A majority of domestic and selected foreign passenger rail
operators had invested in enhanced systems to control unauthorized access
at employee facilities and stations. Specifically, 23 of the 32 U.S.
operators had installed a form of access control at key facilities and
stations. This often involved installing a system where employees had to
swipe an access card to gain access to control rooms, repair facilities,
and other key locations. For example, the Greater Cleveland Regional
Transit Authority had a particularly comprehensive system where all doors
throughout its rail system are linked to a central alarm and intrusion
detection system. If an unauthorized employee or customer attempts to gain
access to any facility system wide, alarms are to activate in the control
center. Also, BART in California has a modern system utilizing lasers to
detect intruders at tunnel portals and other key facilities. Finally, all
13 foreign operators had implemented some form of access control to their
critical facilities or rights-of-way. However, these measures varied from
simple alarms on doors at electrical substations on one subway

system we visited to infrared sensors monitoring every inch of
right-of-way along the track on three of the high-speed interurban rail
systems. The high-speed systems had these extensive systems because of the
potential for catastrophe if a train traveling at over 200 miles per hour
were to hit a vehicle placed along the tracks or travel over rail that had
been sabotaged.

Rail system design and configuration: In an effort to reduce
vulnerabilities to terrorist attack and increase overall security,
passenger rail operators in the United States and abroad have been, or are
now beginning to, incorporate security features into the design of new and
existing rail infrastructure, primarily rail stations. For example, of the
32 domestic rail operators we contacted, 22 of them had removed their
conventional trash bins entirely, or replaced them with transparent or
bomb-resistant trash bins, as TSA instructed in its May 2004 security
directives. In past terrorist attacks on rail systems, particularly in
Great Britain, trash bins have been used as a means for hiding explosive
devices. Removing trash bins entirely, as PATH in New Jersey has done,
eliminates the trash bin as a place to hide an explosive device.
Installing transparent trash bins, as a few operators have done, might
allow security personnel to see inside trash bins to determine if
suspicious items are inside. Three operators have installed bomb-resistant
trash bins to contain the impact of a blast and minimize the amount of
dangerous shrapnel that could be expelled. Conversely, one rail operator
told us that his agency was not removing any of its conventional trash
bins because it feared litter would become an unmanageable problem without
them and that bomb-resistant and transparent trash bins were
ineffective-specifically, that they simply directed the force of a bomb
blast upward toward the ceiling, which could cause severe structural
damage in an underground station. Similarly, while only a limited number
of domestic rail operators we contacted ever had bicycle or storage
lockers in their systems, many of those operators that did, at one time,
have those lockers told us that they had removed them to avoid the
possibility of someone using them as a hiding place for an explosive, or
had moved them to locations farther away from stations and crowded places
to minimize the impact of a potential attack. Also, foreign rail operators
had taken steps to remove traditional trash bins from their systems. Of
the 13 operators we visited, 8 had either removed their trash bins
entirely or replaced them with blast-resistant cans or transparent
receptacles. In fact, the London Underground rail system was the first
system worldwide to begin using clear plastic trash bags to eliminate
places to hide an explosive. Officials from the Underground stated that
this technique helped to deter terrorists from the Irish Republican Army
from placing bombs in conventional trash cans during the height of that
organization's terrorist campaign against the rail system.

Many foreign rail operators are also incorporating aspects of security
into the design of their rail infrastructure. Of the 13 operators we
visited, 11 have attempted to design new facilities with security in mind
and have attempted to retrofit older facilities to incorporate
security-related modifications. For example, one foreign operator we
visited is retrofitting its train cars with windows that passengers could
open in the event of a chemical attack. In addition, the London
Underground, one of the oldest rail systems in the world, incorporates
security into the design of all its new stations as well as when existing
stations are modified. We observed several security features in the design
of Underground stations, such as using vending machines that have no holes
that someone could use to hide a bomb, and sloped tops to reduce the
likelihood that a bomb can be placed on top of the machine. In addition,
stations are designed to provide staff with clear lines of sight to all
areas of the station, such as underneath benches or ticket machines, and
station designers try to eliminate or restrict access to any recessed
areas where a bomb could be hidden. Figure 8 shows selected security
design elements incorporated into London Underground stations.

Figure 8: Selected Security Design Elements Incorporated into London's
Underground

Source: London Underground.

Vending machines, as well as ticket vendors, can be designed to minimize
opportunities for hiding objects above or behind them; clear plastic trash
bags and clean lines of sight minimize opportunities to hide objects on
the platform.

In one London station, we observed the use of netting throughout the
station to help prevent objects, such as bombs, from being placed in a
recessed area, such as beneath a stairwell or escalator. In this station
and other stations we visited, Underground officials have installed "help
posts" at which customers can call for help if an incident occurs. When
these posts are activated, CCTV cameras display a video image of the help
post and surrounding area to staff at a central command center. This
allows the staff to directly observe the situation and respond
appropriately. See figure 9 for a photograph of a help post.

Figure 9: Security Design Elements Incorporated into London's Underground

Source: London Underground.

The "help post" in this London Underground rail station allows passengers
to contact station security staff in an emergency. Once activated, the
CCTV camera would be turned on so security staff could monitor the
situation and identify what actions to take.

Underground officials stated that the incorporation of security features
in station design is an effective measure in deterring some terrorists
from attacking the system. For example, officials told us that CCTV video
recorded the efforts by Irish Republican Army terrorists attempting to
place an explosive device inside a station-and when they could not find a
suitable location to hide the device, they placed it outside in a trash
can instead, thereby mitigating the impact of the explosion.

In the United States, several passenger rail operators stated that they
were taking security into account when designing new facilities or
remodeling older ones. Twenty-two of 32 rail operators we interviewed told
us that they were incorporating security into the design of new or
existing rail infrastructure. For example, New York City Transit and PATH
officials told us they are incorporating security into the design of its
new stations, including the redesigned Fulton Street station and the World
Trade Center Hub that were damaged or destroyed during the September 11
attacks.

Under FTA's New Starts program-a discretionary grant-making program
available to transit agencies seeking federal funds for new or expanded
fixed-guideway system construction-a security management plan must be
developed and security must be taken into consideration when designing or
constructing federally funded projects. Although securityspecific design
considerations are required for these security plans, the plans need not
incorporate a particular set of security design principles or guidelines.
In June 2005, FTA issued guidelines for use by the transit industry
encouraging the incorporation of particular security features into the
design of transit infrastructure. These guidelines include, for example,
increasing visibility for onboard staff, reducing the areas where someone
could hide an explosive device on a transit vehicle, and enhancing
emergency exits in transit stations. The program guidance for New Starts
does not require that agencies consider these particular guidelines to
further enhance station security and mitigate exposures to terrorist
attack when enhancing new systems or expansions. In response to our
inquiry about the feasibility and appropriateness of such a requirement,
FTA officials stated that they planned to incorporate such a requirement
into the program's regulations after legislation reauthorizing the New
Starts program is approved.45

Figure 10 shows a diagram of several security measures that we observed in
passenger rail stations both in the United States and abroad. It should be
noted that this represents an amalgam of stations we visited, not any
particular station.

45The New Starts program was reauthorized through the enactment of Pub. L.
No. 109-59 on August 10, 2005.

    Amtrak Faces Challenges Specific to Intercity Passenger Rail in Securing Its
    System

In securing its extensive system, Amtrak faces its own set of
securityrelated challenges, some of which are different from those facing
a commuter rail or transit operator. First, Amtrak operates over thousands
of miles, often far from large population centers. This makes its route
system much more difficult to patrol and monitor than one contained in a
particular metropolitan region, and it causes delays in responding to
incidents when they occur in remote areas. Also, outside the Northeast
Corridor, Amtrak operates almost exclusively on tracks owned by freight
rail companies. Amtrak also utilizes stations owned by freight rail
companies, transit and commuter rail authorities, private corporations,
and municipal governments. This means that Amtrak often cannot
unilaterally make security improvements to others' rights-of-way or
station facilities and that it is reliant on the staff of other
organizations to patrol their facilities and respond to incidents that may
occur. Furthermore, with over 500 stations, only half of which are
staffed, screening even a small portion of the passengers and baggage
boarding Amtrak trains is difficult. Last, Amtrak's financial condition
has never been strong-Amtrak has been on the edge of bankruptcy several
times-and the future of Amtrak operations is in question pending the
outcome of the fiscal year 2006 budget.46

Amid the ongoing challenges of securing its coast-to-coast railway, Amtrak
has taken some actions to enhance security throughout its intercity
passenger rail system. For example, Amtrak has initiated a passenger
awareness campaign, similar to those described elsewhere in this report.
Also, Amtrak has begun enforcing existing restrictions on carry-on luggage
that limit passengers to two carry-on bags, not exceeding 50 pounds. All
bags also must have identification tags on them. Furthermore, Amtrak has
begun requiring passengers to show positive identification after boarding
trains when asked by staff to ensure that tickets have not been
transferred or stolen, although Amtrak officials acknowledge their onboard
staffs only sporadically enforce this requirement because of the numerous
tasks these staff members must perform before a train departs. However, in
November 2004, Amtrak implemented the Tactical Intensive Patrols (TIPS)
program, under which its security staff flood selected platforms to ensure
Amtrak baggage and identification requirements are met by passengers
boarding

46The President's fiscal year 2006 budget proposed eliminating the federal
government's subsidy to Amtrak. According to Amtrak officials, while the
outcome of the budget is unknown at this time, severe cutbacks in Amtrak
funding could reduce the amount of personnel Amtrak has available to
perform security functions, while a total elimination of federal funding
for Amtrak could cause a system shutdown.

trains. In addition, Amtrak increased the number of canine units
patrolling its system, most of which are located in the Northeast
Corridor, looking for explosives or narcotics and assigned some of its
police to ride trains in the Northeast Corridor. Also, Amtrak has
instituted a policy of randomly inspecting checked luggage on its trains.
Finally, Amtrak is making improvements to the emergency exits in certain
tunnels to make evacuating trains in the tunnels easier in the event of a
crash or terrorist attack.

To ensure that security measures are applied consistently throughout
Amtrak's system, Amtrak has established a series of Security Coordinating
Committees, which include representatives of all Amtrak departments. These
committees are to review and establish security policies, in coordination
with Amtrak's police department, and have worked to develop
countermeasures to specific threats. According to Amtrak, in the aftermath
of the July 2005 London bombings, these committees met with Amtrak police
and security staff to ensure additional security measures were
implemented. Also in the wake of the London attacks, Amtrak began working
with the police forces of several large east coast cities, allowing them
to patrol Amtrak stations to provide extra security. In addition, all
Amtrak employees now receive a "Daily Security Awareness Tip" and are
receiving computer-based security training. Amtrak police officers are
also now receiving specialized counterterrorism training.

While Amtrak has taken the actions outlined above, it is difficult to
determine if these actions appropriately or sufficiently addressed
pressing security needs. As discussed earlier, Amtrak has not performed a
comprehensive terrorism risk assessment that would provide an empirical
baseline for investment prioritization and decision making for Amtrak's
security policies and investment plans. However, as part of the 2005
Intercity Passenger Rail Grant Program, Amtrak is required to produce a
security and emergency preparedness plan, which is to include a risk
assessment that Amtrak expects to finish by September 30, 2005. Upon
completing this plan, Amtrak management should have a more informed basis
regarding which security enhancements should receive the highest priority
for implementation.

Three Foreign Rail While many of the security practices we observed in
foreign rail systems Security Practices Are Not are similar to those U.S.
passenger rail operators are implementing, we Currently Used in the
encountered three practices in other countries that were not currently in
United States use among the domestic passenger rail operators we contacted
at the time

we completed our field work in June 2005, nor were they performed by the
U.S. government. These practices are discussed below.

Covert testing: Two of the 13 foreign rail systems we visited utilize
covert testing to keep employees alert about their security
responsibilities. Covert testing involves security staff staging
unannounced events to test the response of railroad staff to incidents
such as suspicious packages or setting off alarms. In one European system,
this covert testing involves security staff placing suspicious items
throughout their system to see how long it takes operating staff to
respond to the item. Similarly, one Asian rail operator's security staff
will break security seals on fire extinguishers and open alarmed emergency
doors randomly to see how long it takes staff to respond. Officials of
these operators stated that these tests are carried out on a daily basis
and are beneficial because their staff know they could be tested at any
moment, and they, therefore, are more likely to be vigilant with respect
to security.

Random screening: Of the 13 foreign operators we interviewed, 2 have some
form of random screening of passengers and their baggage in place. In the
systems where this is in place, security personnel can approach passengers
either in stations or on the trains and ask them to submit their persons
or their baggage to a search. Passengers declining to cooperate must leave
the system. For example, in Singapore, rail agency officials rotate the
stations where they conduct random searches so that the searches are
carried out at a different station each day. Prior to the July 2005 London
bombings, no passenger rail operators in the United States were practicing
a form of random passenger or baggage screening on a continuing daily
basis. However, during the Democratic National Convention in 2004, MBTA
instituted a system of random screening of passengers, where every 11th
passenger at certain stations and times of the day was asked to provide
his or her bags to be screened. Those who refused were not allowed to ride
the system. MBTA officials recognized that it is impossible to implement
such a system comprehensively throughout the rail network without massive
amounts of additional staff, and that even doing random screening on a
regular basis would be a drain on resources. However, officials stated
that such a system is workable during special events and times of
heightened security but would have to be designed very carefully to ensure
that passengers' civil liberties were not violated. After the July 2005
London bombings, four passenger rail operators-PATH, New York Metropolitan
Transportation Authority,

New Jersey Transit, and Utah Transit Authority in Salt Lake City-
implemented limited forms of random bag screening in their system.47 In
addition, APTA, FTA, and the National Academy of Science's Transportation
Research Board are currently conducting a study on the benefits and
challenges that passenger rail operators would face in implementing a
randomized passenger screening system.48 The study is examining such
issues as the legal basis for conducting passenger screening or search,
the precedence for such measures in the transportation environment, the
human resources required, and the financial implications and cost
considerations involved. As of July 2005, an initial draft of the study
was under review.

National government maintains clearinghouse on technologies and best
practices: According to passenger rail operators in five countries we
visited, their national governments have centralized the process for
performing research and developing passenger rail security technologies
and maintaining a clearinghouse on these technologies and security best
practices. According to these officials, this allows rail operators to
have one central source for information on the merits of a particular
passenger rail security technology, such as chemical sensors, CCTVs, and
intrusion detection devices. Some U.S. rail operators we interviewed
expressed interest in there being a more active centralized federal
research and development authority in the United States to evaluate and
certify passenger rail security technologies and make that information
available to rail operators. Although TSA is the primary federal agency
responsible for conducting transportation security research and
development, and has conducted the TRIP as previously mentioned, most of
the agency's research and development efforts to date have focused on
aviation security technologies. As a result, domestic rail operators told
us that they rely on consultations with industry trade associations, such
as APTA, to learn about best practices for passenger rail security
technologies and related investments. Several rail operators stated that
they were often unsure of where to turn when seeking information on
security-related products, such as CCTV cameras or intrusion detection
systems.

47According to APTA, MBTA has maintained the right to conduct random
searches of passengers. In addition, after the London bombings, the
Metropolitan Area Rapid Transit Authority in Atlanta posted notices on
buses and trains stating that it maintains the right to conduct random
searches.

48This research is being conducted through the Transit Cooperative
Research Program, a partnership among these three entities that undertakes
research and other technical activities in response to the needs of
transit service providers.

Currently, many operators said they informally ask other rail operators
about their experiences with a certain technology, perform their own
research via the Internet or trade publications, or perform their own
testing.

No federal agency has yet compiled or disseminated best practices to rail
operators to aid in this process. We have previously reported that
stakeholders have stated that the federal government should play a greater
role in testing transportation security technology and making this
information available to industry stakeholders.49 TSA and DOT agree that
making the results of research testing available to industry stakeholders
could be a valuable use of federal resources by reducing the need for
multiple rail operators to perform the same research and development
efforts, but they have not taken action to address this.50

Implementing these three practices-covert testing, random screening, and a
government-sponsored clearinghouse for technologies and best practices-in
the United States could pose political, legal, fiscal, and cultural
challenges because of the differences between the United States and these
foreign nations. For instance, many foreign nations have dealt with
terrorist attacks on their public transportation systems for decades,
compared with the United States, where rail transportation has not been
specifically targeted during terrorist attacks. According to foreign rail
operators, these experiences have resulted in greater acceptance of
certain security practices, such as random searches, which the U.S. public
may view as a violation of their civil liberties or which may discourage
them from using public transportation. The impact of security measures on
passengers is an important consideration for domestic rail transit
operators, since most passengers could choose another means of
transportation, such as a personal automobile. As such, security measures
that limit accessibility, cause delays, increase fares, or otherwise cause
inconvenience could push people away from transit and into their cars. In
contrast, the citizens of the European and Asian countries we visited are
more dependent on public transportation than most U.S. residents and
therefore, according to the rail operators we spoke with, may be more
willing to accept more intrusive security measures, simply because they
have no other choice for getting from place to place. Nevertheless, in
order to identify innovative security measures that could help further

49GAO-03-843. 50See GAO-03-843.

mitigate terrorism-related risk to rail assets-especially as part of a
broader risk management approach discussed earlier-it is important to at
least consider assessing the feasibility and costs and benefits of
implementing the three rail security practices we identified in foreign
countries in the United States. Officials from DHS, DOT, passenger rail
industry associations, and rail systems we interviewed told us that
operators would benefit from such an evaluation. Furthermore, the
passenger rail association officials told us that such an evaluation
should include practices used by foreign rail operators that integrate
security into infrastructure design.

Differences in the business models and financial status of some foreign
rail operators could also affect the feasibility of adopting certain
security practices in the United States. Several foreign countries we
visited have privatized their passenger rail operations. Although most of
the foreign rail operators we visited-even the privatized systems-rely on
their governments for some type of financial assistance, two foreign rail
operators generated significant revenue and profits in other business
endeavors, which they said allowed them to invest heavily in security
measures for their rail systems. In particular, the Paris Metro system is
operated by the RATP Corporation (Regie Autonome des Transports
Parisiens), which also contracts with other cities in France and
throughout the world to provide consulting and project management
services. RATP's ability to make a profit, according to its officials,
through its consulting services allows the agency to supplement government
funding in order to support expensive security measures for the Paris mass
transit system. For example, RATP recently installed a computer-assisted
security control system that uses CCTV, radio, and global positioning
technology that it says has significantly reduced the amount of time it
takes for security or emergency personnel to respond to an incident or
emergency, such as a terrorist attack. Because of RATP's available funding
for security, the corporation also purchased an identical system for the
Metropolitan Paris Police, so the RATP and the police system would be
compatible. In addition, according to Hong Kong mass transit system
officials, their company was highly profitable because of its real estate
and development operations, allowing the company to invest in security
measures. In contrast, domestic rail operators do not generate a profit
and therefore are dependent on financial assistance from the federal,
state, and local levels of government to maintain and enhance services,
including funding security improvements.

Another important difference between domestic and foreign rail operators
is the structure of their police forces. In particular, England, France,

Conclusions

Belgium, and Spain all have national police forces patrolling rail systems
in these countries. The use of a national police force is a reflection
that these foreign countries often have one nationalized rail system,
rather than over 30 rail transit systems owned and operated by numerous
state and local governments, as is the case in the United States. For
example, in France, the French National Railway operates all intercity
passenger rail services in the country and utilizes the French Railway
police to provide security. According to foreign rail operators, the use
of one national rail police force allows for consistent policing and
security measures throughout the country. In the United States, in
contrast, there is not a national police force for the rail transit
systems.51 Rather, some transit agencies maintain individual polices
forces, while others rely on their city or county police forces for
security.

The recent London rail bombings made clear that even when a variety of
security precautions are put in place, passenger rail systems that move
high volumes of passengers on a daily basis remain vulnerable to attack.
It is important nonetheless to take the necessary steps to identify and
mitigate risks to passenger rail systems. In the United States, securing
the passenger rail system is a daunting task. As we have reported
previously, the sheer number of stakeholders involved in securing these
systems can lead to communication challenges, duplication of effort, and
confusion about roles and responsibilities. Accordingly, enhanced federal
leadership is needed to help ensure that actions and investments designed
to enhance security are properly focused and prioritized. We are
encouraged by the steps DHS components have taken to use elements of a
risk management approach to guide critical infrastructure protection
decisions for the passenger rail industry. This is a necessary step in a
broader effort by DHS to determine how to allocate finite resources not
only to help protect all modes of transportation, but also to secure other
national critical infrastructure sectors.

However, both DHS and TSA could take additional steps to help ensure that
the risk management efforts under way clearly and effectively identify
priority areas for security-related investments in rail and other sectors.
We recognize that TSA has had many aviation security-related
responsibilities and has implemented many security initiatives to meet
legislative

51Unlike domestic rail transit agencies, Amtrak maintains a 342-member
police force for its national network.

requirements. Notwithstanding, TSA has not yet completed its methodology
for determining how the results of threat, criticality, and vulnerability
assessments will be used to identify and prioritize risks to passenger
rail and other transportation sectors. In order to complete and apply its
methodology as part of the forthcoming transportation sectorspecific plan,
TSA needs to more consistently involve industry stakeholders in the
overall risk assessment process and collaborate with them on collecting
and analyzing information on critical infrastructure and key resources in
the passenger rail industry. Without consistent and substantive
stakeholder input, TSA may not be able to fully capture critical
information on rail assets-information that is needed to properly assess
risk. In addition, as part of the process to complete its risk assessment
methodology, TSA needs to consider whether other proven approaches, such
as ODP's risk assessment methodology, could be leveraged for rail and
other transportation modes, such as aviation. Until the overall risk to
the entire transportation sector is identified, TSA will not be able to
fully benefit from the outcome of risk management analysis-including
determining where and how to target the nation's limited resources to
achieve the greatest security gains.

Once risk assessments for the passenger rail industry have been completed,
it will be critical to be able to compare assessment results across all
transportation modes as well as other critical sectors and make informed,
risk-based investment trade-offs. The framework that DHS is developing to
help ensure that risks to all sectors can be analyzed and compared in a
consistent way needs to be completed and shared with TSA and other
sector-specific agencies. The delay in completing the element of the
framework that defines concepts, terminology, and metrics for assessing
risk limits DHS's ability to compare risk across sectors as sectorspecific
agencies are concurrently conducting risk assessment activities without
this guidance. Until this framework is complete, it will not be possible
for information from different sectors to be reconciled to allow for a
meaningful comparison of risk-a goal outlined in DHS's interim NIPP.

Apart from its efforts to formally identify risks, TSA has taken steps to
enhance the security of the overall passenger rail system. The issuance of
security directives in the wake of the Madrid bombings was a
wellintentioned effort to take swift action in response to a current
threat. However, because these directives were issued under emergency
circumstances, with limited input and review by rail industry and federal
stakeholders-and no public comment period-they may not provide the
industry with baseline security standards based on industry best
practices.

Nor is it clear how these directives are to be measured and enforced.
Consequently, neither the federal government nor rail operators can be
sure they are requiring and implementing security practices proven to help
prevent or mitigate disasters. Collaborating with rail industry
stakeholders to develop security standards is an important starting point
for strengthening the security of passenger rail systems. DHS and DOT have
taken steps in this direction through the interdepartmental MOU in place
and related agreements now being developed to define roles and
responsibilities and resources for mass transit, rail, and other matters.
These agreements, once completed and communicated to the rail industry,
will help ensure that federal activities to secure rail systems, including
the development of standards, are coordinated, and that stakeholders are
involved in their development and implementation to the extent possible.
Otherwise, security efforts could be duplicative, thus dispersing finite
resources, rather than focusing them based on risk, or fail to achieve the
intended ends. Given the importance of clearly defining DHS's and DOT's
roles and responsibilities for rail security matters, time frames could be
established to hold DHS and DOT accountable for completing the MOU
agreements.

While foreign passenger rail operators face similar challenges to securing
their systems and have generally implemented similar security practices as
U.S. rail operators, there are some practices that are utilized abroad
that U.S. rail operators or the federal government have not studied in
terms of the feasibility, costs, and benefits. For example, an information
clearinghouse for new passenger rail technologies that are available and
have been tested might allow rail operators to efficiently implement
technologies that had already received approval. In addition, while FTA
plans to require rail operators to consider its security infrastructure
design guidelines when renovating or constructing rail systems or
facilities, opportunities may still exist to further research and evaluate
ways of integrating security into design, as some foreign rail operators
have done. Another rail security practice-covert testing of rail security
procedures- is being used in two foreign rail systems we visited and is
considered by them as an effective means of keeping rail employees alert
to their surroundings and potential security threats. And finally, random
searches of passengers and baggage are being used by two foreign rail
operators and this practice has recently been adopted by four domestic
rail operators in the wake of the London attacks.

Introducing these security practices into the United States may involve
cultural, financial, and political challenges, owing to differences
between the United States and foreign nations. Nonetheless, as part of the
overall

  Recommendations for Executive Action

risk management approach, there may be compelling reasons for exploring
the feasibility, costs, and benefits of implementing any of these
practices in the United States. Doing so could enable the United States to
leverage the experiences and knowledge of foreign passenger rail operators
and help identify additional innovative measures to secure rail systems
against terrorist attack in this country.

In order for the Department of Homeland Security to have the information
needed to fully evaluate, compare, and prioritize risk mitigation
activities across sectors, we recommend that the Secretary of the
Department of Homeland Security take the following action:

o  	Establish a timeline for completing the department's framework for
analyzing sector risks and ensure that the risk assessment methodologies
used by sector-specific agencies are consistent with this framework.

In order for the Transportation Security Administration to have the
information needed to more fully evaluate, select, and implement risk
mitigation activities, and complete its transportation sector-specific
plan and other strategic risk based plans, we recommend that the Secretary
of the Department of Homeland Security direct the Assistant Secretary of
the Transportation Security Administration to take the following two
actions:

o  	Establish a plan for completing its methodology for conducting risk
assessments that includes timelines and addresses how it will work with
passenger rail stakeholders and leverage existing federal expertise in
Department of Homeland Security components, including the Office for
Domestic Preparedness, as well as the Department of Transportation modal
administrations, including the Federal Railroad Administration and the
Federal Transit Administration.

o  	Evaluate whether the risk assessment methodology used by the Office
for Domestic Preparedness should be leveraged to facilitate the completion
of risk assessments for rail and other transportation modes.

To ensure that future rail security directives are enforceable,
transparent, and feasible, we recommend that the Secretary of the
Department of Homeland Security direct the Assistant Secretary of the
Transportation Security Administration, in collaboration with the
Department of Transportation and the passenger rail industry, to take the
following two actions:

o  	Develop security standards that reflect industry best practices and
can be measured, monitored, and enforced by Transportation Security
Administration rail inspectors and, if appropriate, by rail asset owners.
This could be accomplished by using the rule-making process, with notice
in the Federal Register and an opportunity for interested stakeholders to
comment, to promulgate long-term regulations that incorporate these
standards.

o  	Set timelines for completing the memorandum of understanding modal
agreements for rail, mass transit, and research and development, which
both the Department of Homeland Security and the Department of
Transportation have agreed to pursue.

To help strengthen the security of passenger rail systems in the United
States and potentially leverage the knowledge and practices employed by
foreign rail operators, we recommend that the Secretary of the Department
of Homeland Security, in collaboration with the Department of
Transportation and the passenger rail industry, take the following two
actions:

o  	Evaluate the feasibility of establishing and maintaining an
information clearinghouse on existing and emergency security technologies
and security best practices used in the passenger rail industry both in
the United States and abroad.

o  	Evaluate the potential benefits and applicability-as risk analyses
warrant and as opportunities permit-of implementing covert testing
processes to evaluate the effectiveness of rail system security personnel;
implementing practices used by foreign rail operators that integrate
security into infrastructure design; and implementing random searches or
screening of passengers and their baggage, pending the results of an
ongoing joint federal and industry review of the impact of random
screening on passenger rail operators.

We provided DHS, DOT, and Amtrak a draft of this report for review and
comment. DOT and Amtrak generally agreed with our findings and
recommendations and provided technical comments, which we incorporated
where appropriate.

DHS generally concurred with the report's recommendations and provided
detailed comments on various sections of the report. Its comments are
contained in appendix IV. We summarize their comments and provide our
response below.

  Agency Comments
  and Our Evaluation

In commenting on the report, DHS stated that it is working through the
Office of State and Local Government Coordination Preparedness (referred
to in this report as the Office for Domestic Preparedness, ODP), TSA, and
FTA to maximize and leverage collective resources to better serve the mass
transit and commuter rail industry. In addition, DHS indicated that it
will share ODP's risk management architecture with public and private
sector entities and use risk management principles to better prioritize
its funding decisions. DHS reported taking or is planning to take other
actions to enhance the security of the U.S. passenger rail system, such as
initiating a canine explosives detection program, gathering and
centralizing information on mass transit security to aid in decision
making, and partnering with FRA inspectors to review rail security
measures in operation since the July 2005 London rail bombings. We are
encouraged by DHS's efforts to work towards a common risk-based
architecture for securing the passenger rail system and its related
security initiatives.

In more specific comments, DHS stated that our assertion that TSA missed
the December 2004 deadline for completing the TSSP was misleading because
the agency completed a draft by November 2004. DHS also stated that it
plans to include industry associations, such as APTA and AAR, in its
development of the TSSP and noted that it partnered with these
associations and their members after the London bombings in July 2005. We
modified the report to reflect the fact that a draft TSSP was completed by
this date. However, the plan was not produced by December 2004, as
required by HSPD-7, and therefore was not available for use by the rail
operators and stakeholders.

DHS also noted that while TSA's methodology for conducting criticality
assessments relies on open source information and therefore does not
require direct contact with industry stakeholders, the agency nevertheless
involved federal stakeholders and rail operators in conducting the
assessments. We recognize that TSA's process for conducting criticality
assessments relies on open source information, and TSA reported to us that
it had some contact with stakeholders. However, DHS's interim NIPP states
that the department and sector-specific agencies would work with the
industry to determine the most effective means of collecting and analyzing
information on critical assets. TSA was not able to provide us with
evidence showing that it had solicited and evaluated input from industry
stakeholders on its criticality assessment methodology. In addition, the
criticality assessment case files we reviewed contained no evidence of
coordination with stakeholders during the assessment process. Furthermore,
industry associations we interviewed told us that

TSA did not solicit their input on the agency's criticality assessment
methodology or ask them to identify specific critical assets. Moreover, of
the 32 rail operators we contacted about TSA's criticality assessment
process, 22 operators responded; of those who responded, all stated that
TSA did not involve them in conducting critical assessments of their
systems.

DHS also stated that while stakeholders were not given an opportunity to
comment on the final draft of the measures contained in the security
directives, various stakeholders, including Amtrak, did comment on each of
the measures required by the directive. Our report acknowledges that
associations and Amtrak were given an opportunity to comment on the draft
directives. However, the draft directives initially provided to industry
stakeholders did not include all of the measures required by the final
directives. For example, the draft directives provided to APTA and AAR did
not include the requirement that engineer cab or compartments be kept
locked. Moreover, although TSA stated that it would continue to
collaborate with industry stakeholders on the development of the
directives, DHS and TSA determined that the prevailing threat environment
necessitated issuing the directives without additional consultation.
According to TSA, the emergency circumstances under which the directives
were issued allowed for only limited input and review by federal and rail
industry stakeholders. However, we believe that using the federal
rule-making process as a means of establishing permanent standards would
make the process more transparent and could help TSA in developing
standards that are most appropriate for the industry and which can be
measured, monitored, and enforced. Since stakeholders will play a critical
role in administering, implementing, and/or enforcing TSA standards, their
involvement in the development of standards is important to the success of
these initiatives.

DHS stated that our report criticized TSA's efforts to develop the
directives based upon consultation with industry and a review of best
security practices. Specifically, DHS said that TSA went beyond FTA's and
APTA's written documents (i.e., FTA's list of the top 20 actions FTA rail
operators can take to strengthen security, FTA-recommended protective
measures and activities for transit agencies that may be followed based on
current threat levels, and an APTA member survey) and considered other
effective security measures, such as locking engineer cab and compartment
doors (a measure suggested by WMATA, according to DHS), which the agency
said were being implemented by various operators. While we agree that
collaborating with other federal agencies and industry stakeholders to
develop security standards based upon best practices is a

critical step in enhancing the security of U.S. passenger rail systems and
are making a recommendation to this effect, we continue to question the
extent to which TSA followed this approach in developing the directives
and the criteria TSA used to determine what constituted industry best
practices. For example, regarding the requirement to lock train operator
cabs or compartments, it is unclear whether this requirement is an
industry best practice. The source material TSA provided to us, which the
agency said it consulted in developing the directives, does not indicate
that locking engineer or train operator cab or compartment doors is a best
practice, or an effective one, in use by WMATA or other operators.
Furthermore, TSA did not seek input from other stakeholders to determine
whether they viewed this as a best practice. For example, the draft
directives provided to AAR and APTA for comment did not include this
measure. In addition, documentation shows that TSA called one commuter
rail operator prior to issuing the directives to discuss this proposed
measure, and the operator raised a concern about the safety of the locked
door requirement. All of the rail operators and association
representatives we interviewed raised concerns either about the extent of
TSA's coordination with the industry in developing the directives or the
feasibility of specific directives.

Regarding our assertion that the locked door measure may conflict with an
FRA safety requirement, DHS responded that, according to FRA, the measure
applied only to two types of passenger rail cars. However, FRA's director
of the office of safety assurance and compliance and its director of
security disagreed with this assertion and said that this safety concern
would apply to all commuter or intercity rail equipment that is equipped
with locking mechanisms. While the locked door requirement may be well
intentioned, it may have the unintended consequence of increasing safety
risks to railroad employees and passengers. According to FRA, a locked
door pursuant to the directive would not allow the locomotive engineer to
quickly exit the cab when faced with an impending highway rail grade
crossing collision or other accident. In some cases, the door providing
access to the locomotive's cab also serves as one of only two primary
paths for emergency exit by passengers and is marked as an emergency exit.
According to FRA, if these doors are locked pursuant to the directives,
they may not be usable in an emergency, and passenger evacuation time
could be substantially increased.

In the report, we stated that APTA, AAR, and other stakeholders did not
believe they had been sufficiently consulted throughout the development of
the security directives, including the measure advocating installation of
bomb-resistant trash cans. As a result, stakeholders did not believe the

directives reflected a complete understanding of the passenger rail
environment or incorporate industry best practices. On this issue, DHS
noted in its comments that the directives did not require the installation
of bomb-resistant trash cans, but rather encouraged the removal of
traditional trash cans. While we agree that the directive emphasizes the
desirability, under certain circumstances and to the extent that resources
allow, of removing traditional trash cans, we believe the directive also
directly advocates the use of bomb-resistant trash cans since it directs
operators to "install bomb resistant receptacles to the extent resources
allow." While industry stakeholders had an opportunity to comment on the
trash can removal issue, they were not given an opportunity to consider
the feasibility or efficacy of installing bomb-resistant trash cans
because this measure was not included in the draft directives provided to
industry stakeholders for comment.

With regard to the directive requiring Amtrak and the Alaska Railroad
Corporation to perform ID checks on all passengers, DHS stated that our
report raised an issue regarding the efficacy of performing ID checks
without vetting passenger names against a watch list or other database.
DHS stated that ID checks were a baseline measure that could be enhanced
in response to heightened or specific threats by vetting names against a
watch list. DHS also explained that Amtrak was already performing some ID
checks, and that the measure was designed to incorporate the ID check into
current business practice of operators such as Amtrak, which could request
passengers to have their IDs available when tickets are checked. We do not
disagree with DHS's assertion that additional measures could be added in
heightened threat environments. Our discussion of this measure focuses on
Amtrak's concern about the feasibility of the requirement in light of the
potential impacts on Amtrak's operations and revenue. DHS's explanation of
the intent of this measure suggests that it was to encourage the use of ID
checks and that operators "could request passengers to have their ID
available." However, as written, the directive requires rather than
encourages IDs to be checked at the initial point where tickets are
checked.

In commenting on our report's assertion that it is unclear which entities
are responsible for implementing the security directives, DHS acknowledged
that individual stations and terminals may be owned and/or operated by
multiple federal, state, and private entities but emphasized that the
prevailing threat environment at the time the security directives were
issued necessitated looking to the passenger rail operator to coordinate
the implementation of the required measures. We agree that rail operators
must play an important role in the implementation of

measures in stations that they may not own. However, the directives, as
written, do not make it clear which entities (rail operators and station
and terminal owners) are responsible for implementing the requirements
and, in the 15 months since the directives were issued, TSA has not yet
clarified these responsibilities. The industry associations and rail
operators still believe that implementation responsibilities remain
unclear. Given that TSA considers these directives to be mandatory and has
hired inspectors to ensure compliance with directives, we believe that it
is important to clearly articulate which entities are to be held
accountable for implementing the measures required by the directives.

Finally, DHS commented that it has approved and distributed standard
operating procedures to its rail inspectors since we completed our field
work, and that DOT had been actively engaged in reviewing and commenting
on these procedures. We are encouraged that TSA is moving forward with
efforts to develop processes for ensuring compliance with security
standards. However, as stated above, we are concerned that TSA may not be
effectively able to ensure or enforce compliance until the standards have
been more fully developed in consultation with stakeholders. TSA was not
able to provide us with evidence to show it had collaborated with DOT in
developing and approving these procedures. In addition, DOT officials
raised questions regarding the approved status of these procedures. For
example, FTA's director of safety and security told us he had not seen
either a draft or a final version of these procedures. Furthermore, FRA's
director of the office of safety assurance and compliance did not believe
the procedures had been approved. According this official, TSA provided a
draft of the standard operating procedures on August 10, 2005, and
comments are due back on September 14, 2005.

As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it until 30 days
from the date of this letter. We will then send copies of this report to
the Secretary of Homeland Security, the Secretary of Transportation, the
Assistant Secretary of the Transportation Security Administration, the
Administrator of the Federal Railroad Administration, the Administrator of
the Federal Transit Administration, the President and Chief Executive
Officer of Amtrak, the Director of the Office of State and Local
Government Coordination and Preparedness, and interested congressional
committees. We will make copies available to others upon request. In
addition, this report will be available at no charge on our Web site at
http://www.gao.gov.

If you or your staff have any questions about this report, please contact
Ms. Cathleen Berrick on (202) 512-8777 or Ms. JayEtta Hecker on (202)
512-2834. Contact points for our offices of Congressional Relations and
Public Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix V.

Cathleen A. Berrick, Director Homeland Security and Justice Issues

JayEtta Hecker, Director Physical Infrastructure Issues

Appendix I: Objectives, Scope, and Methodology

To address our first objective, to identify the actions taken by the
Department of Homeland Security (DHS) agencies to assess risks posed by
terrorism in the context of prevailing risk management principles, we
interviewed officials from DHS, the Department of Transportation (DOT),
and Amtrak. Specifically, within DHS, we interviewed officials from the
Transportation Security Administration's (TSA) Office of Intermodal
Security Programs (formerly the Office of Maritime and Land Security),
Office of Transportation Security Policy, Transportation Security
Intelligence Service, and the Chief Operating Officer. We also interviewed
officials from the Office of State and Local Government Coordination and
Preparedness (SLGCP), the Information Analysis and Infrastructure
Protection Directorate, the Border and Transportation Security
Directorate, and the Office of Inspector General. Within DOT, we
interviewed officials from the Office of Intelligence, Inspector General,
Deputy Secretary of Transportation, the Federal Transit Administrations
(FTA) Office of Safety and Security, and the Federal Railroad
Administration (FRA) Office of Security and Office of Safety Assurance and
Compliance. We also interviewed Amtrak's Chief of Police and Security,
Vice President of Corporate Security, Inspector General, and Amtrak
security officials in locations throughout the United States. In addition,
we reviewed federal agency plans such as the DHS Interim National
Infrastructure Protection Plan, and obtained and reviewed various
risk-related assessments conducted by federal agencies, including the
vulnerability assessments of rail transit systems conducted by FTA, TSA
threat assessments of mass transit and rail and criticality assessments of
passenger rail assets, and a passenger rail risk assessment tool kit
developed by SLGCP. Further, we conducted a site visit to and interview
with officials from the Port Authority of New York and New Jersey to
discuss the results of an SLGCP risk assessment conducted at that
location.

To address our second objective to determine the actions that federal
agencies have taken to enhance the security of the U.S. passenger rail
system, we interviewed officials from FTA's Office of Safety and Security,
DOT's Office of the Secretary, FRA's Office of Security, Office of
Research and Development, and Office of Safety Assurance and Compliance,
and TSA's Office of Intermodal Security Programs, Office of Research and
Development, and the Chief Operating Officer. We did not evaluate the
effectiveness of any of these federal passenger rail security efforts. We
also reviewed federal guidance, such as Homeland Security Presidential
Directive-7, FTA's Top 20 Security Program Action Items for Transit
Agencies, and TSA's security directives for passenger rail operators;

Appendix I: Objectives, Scope, and Methodology

inspected all phases of TSA's TRIP program; and reviewed the memorandum of
understanding between DHS and DOT.

To determine the security practices that domestic and selected foreign
passenger rail operators have implemented to mitigate risks and enhance
security, and any differences in these practices, we interviewed officials
from TSA's Office of Intermodal Security Programs, FRA's Office of
International Policy, and FTA's Office of Safety and Security to discuss
domestic and foreign passenger rail security measures. We also conducted
site visits to or teleconferences with 32 heavy and commuter rail
operators in the United States-representing over 95 percent of the
nation's passenger rail ridership in 2003-and Amtrak. Table 4 lists the
domestic passenger rail operators that we visited or interviewed during
our review.

Table 4: Domestic Passenger Rail Agencies We Visited or Interviewed for
the Purposes of this Review

Passenger rail agency Urban area served

Altamont Commuter Express (ACE) Stockton and San Jose, California

Alaska Railroad Corporation Anchorage and Fairbanks, Alaska

Bay Area Rapid Transit (BART) San Francisco-Oakland, California

CALTRAIN	San Francisco and San Jose, California

San Diego Transit Corp. (Coaster) San Diego, California

Dallas Area Rapid Transit / Trinity Railway Dallas, Texas Express (DART)

Greater Cleveland Regional Transportation Cleveland, Ohio Authority
(GCRTA)

Los Angeles County Metropolitan Transportation Los Angeles, California
Authority (LACMTA)

Metropolitan Atlanta Rapid Transit Authority Atlanta, Georgia (MARTA)

Maryland Transit Administration (MTA) 	Greater Washington, D.C., and
Maryland

Massachusetts Bay Transportation Authority Boston, Massachusetts (MBTA)

METRA Commuter Rail Chicago, Illinois

Southern California Regional Rail Authority Greater Los Angeles,
California (Metrolink)

Long Island Railroad (LIRR) New York, New York

Metro North Railroad (MNR) New York, New York

New York City Transit (NYCT) New York, New York

Appendix I: Objectives, Scope, and Methodology

Passenger rail agency Urban area served

Staten Island Railway (SIR) New York, New York

San Francisco Municipal Railway (MUNI) San Francisco, California

     Northern Indiana Commuter District Chicago, Illinois--Northern Indiana

Delaware River Port Authority (PATCO) 	New Jersey and Philadelphia,
Pennsylvania

       Port Authority Trans Hudson (PATH) New York, New York--New Jersey

San Diego Trolley San Diego, California

Southeastern Pennsylvania Transportation Philadelphia, Pennsylvania
Authority (SEPTA)

South Florida Regional Transportation Authority Miami, Florida (SFRTA)

Connecticut Department of Transportation (Shore New Haven, Connecticut
Line East)

Sound Transit (Sounder) Seattle, Washington

TRIMET Portland, Oregon

Virginia Railway Express (VRE) 	Northern Virginia, Greater Washington,
D.C.

Washington Metropolitan Area Transit Authority Washington, D.C. (WMATA)

New Jersey Transit (NJT) 	Newark, New Jersey- New York, New York

Miami Dade Transit Miami, Florida

Chicago Transit Authority (CTA) Chicago, Illinois

Source: National Transit Database.

We also conducted site visits to 13 passenger rail operators in seven
European and Asian countries, including France, the United Kingdom,
Belgium, Spain, Japan, Singapore, and Hong Kong. In all of these
countries, we met with passenger rail security officials and toured
facilities to identify security practices being used on their systems as
well as differences from U.S. passenger rail systems. We also met with
government officials in select countries. See table 5 for a list of
foreign passenger rail operators and government agencies we met with
abroad.

Appendix I: Objectives, Scope, and Methodology

Table 5: Foreign Passenger Rail and Government Agencies We Visited or
Interviewed for the Purposes of This Review

Passenger rail agency or government agency Area served

Paris Metro Paris, France

French National Railway France

National Department for Transport-Security Directorate United Kingdom

                   London Underground London, United Kingdom

Network Rail United Kingdom

British Transport Police United Kingdom

                 Channel Tunnel Rail Link United Kingdom/France

                  Transport for London London, United Kingdom

Belgian National Railway Belgium

Madrid Metro Madrid, Spain

RENFE (Spanish National Railway) Spain

European Commission-Directorate for Energy and European Union Transport

JR Central Japan

Tokyo Metro Tokyo, Japan

Ministry of Land, Infrastructure, and Transport Japan

SBS Transit Corporation Singapore

Singapore Mass Rapid Transit Singapore

Land Transport Authority Singapore

Hong Kong Mass Transit Railway Hong Kong

Special Administrative Regional Government Hong Kong

Source: GAO.

We also attended an international rail security conference sponsored by
the International Union of Railways in partnership with the International
Union on Public Transport. While attending this conference, we interviewed
officials from the German National Railway. Because we selected a
nonprobability sample of both foreign and domestic passenger rail
operators, the information we obtained from these interviews and visits
cannot be generalized to all foreign or domestic rail operators. Finally,
we discussed those foreign security practices identified with several
domestic passenger rail operators and a collection of surface
transportation security experts from the Mineta Transportation Institute
and RAND Corporation to determine the potential to use some of these
practices in the United States.

Appendix I: Objectives, Scope, and Methodology

We performed our work from May 2004 through July 2005 in accordance with
generally accepted government auditing standards.

Appendix II: Elements of a Typical Homeland Security Risk Assessment

A threat assessment: Threat is defined as a potential intent to cause harm
or damage to an asset (e.g., natural environment, people, man-made
infrastructures, and activities and operations). Threat assessments
consist of the identification of adverse events that can potentially
affect an entity. Threats might be present at the global, national, or
local level, and their sources include terrorists and criminal
enterprises. Specific threat information may indicate vulnerabilities that
are subject to attack, or following the completion of a risk management
process may, for instance, indicate that resources should be temporarily
deployed to protect cargo in a particular region of the country or a
specific airport. Even if updated often, a threat assessment might not
adequately capture some emerging threats.

A vulnerability assessment: Vulnerability is defined as the inherent state
(either physical, technical, or operational) of an asset that can be
exploited by an adversary to cause harm or damage. Vulnerability
assessments identify these inherent states and the extent of their
susceptibility to exploitation, relative to the existence of any
countermeasures. A vulnerability assessment is generally conducted by a
team of experts skilled in such areas as engineering, intelligence,
security, information systems, finance, and other disciplines.

A criticality assessment: Criticality is defined as an asset's relative
importance, given that an event occurs. Criticality or similar consequence
assessments identify and evaluate an entity's assets based on a variety of
factors, including the importance of its mission or function, the extent
to which people are at risk, or the significance of a structure or system
in terms of, for example, national security, economic activity, or public
safety. Criticality or consequence assessments are important because they
provide, in combination with threat and vulnerability assessments,
information for later stages of the risk management process.

Risk assessment: A complete risk assessment is a qualitative and/or
quantitative determination of the likelihood (probability) of occurrence
of an adverse event and the severity, or impact, of its consequences. Risk
assessment can involve designating risk as, for example, low, medium, or
high (other scales, such as numeric, can also be used), and often
integrates threat, criticality, and vulnerability assessments. Such
analyses can help inform which actions are best suited to mitigate
assessed risk, in conjunction with the risk-based evaluation of
alternatives while considering cost and other factors.

                                  Source: GAO.

Appendix III: FTA and ODP Passenger Rail Risk Assessments Conducted or In
Progress

  FTA Risk 1. Assessments 2. Conducted 3.

4.

5.

6.

7.

8.

9.

Bi-State Development Agency
Chicago Metra Commuter Rail
Chicago Transit Authority
Dallas Areas Rapid Transit--Trinity Railway Express
Denver Regional Transportation District
Detroit Department of Transportation
Greater Cleveland Regional Transit Authority
King County Department of Transportation Metro District
Los Angeles County Metropolitan Transportation Authority

10. Maryland Transit Administration

11. Massachusetts Bay Transportation Authority

12. Metropolitan Transit Authority of Harris County

13. Metropolitan Atlanta Rapid Transit Authority

14. Metropolitan Transportation Authority--Long Island Railroad

15. Metropolitan Transportation Authority--Metro North Railroad

16. Metropolitan Transportation Authority--New York City Transit

17. Miami Dade Transit

18. Minneapolis Metro Transit

19. New Jersey Transit

20. New Orleans Regional Transit Authority

21. Niagara Frontier Transportation Authority

22. North County Transit District--Coaster

23. Port Authority Trans-Hudson--PATH

Appendix III: FTA and ODP Passenger Rail Risk Assessments Conducted or In
                                    Progress

24. Port Authority of Allegheny County Pennsylvania

25. Puerto Rico Highway and Transportation Authority

26. Sacramento Regional Transit District

27. San Diego Trolley

28. Santa Clara Valley Transit Authority

29. San Francisco Municipal Railway-MUNI

30. San Francisco Bay Area Rapid Transit

31. Southeastern Pennsylvania Transportation Authority

32. Tri-County Commuter Rail Authority

33. Tri-County Metropolitan Transportation District of Oregon--TriMet

34. Utah Transit Authority

35. Virginia Railway Express

36. Washington Metropolitan Area Transit Authority

                               ODP Risk Completed

  Assessments 1.

2.

3.

4.

5.

6.

7.

Port Authority of New York and New Jersey
New Jersey Transit
Massachusetts Bay Transportation Authority
Washington Metropolitan Area Transit Authority
Southeastern Pennsylvania Transportation Authority
Tri-County Metropolitan Transportation District of Oregon--TriMet
Delaware River Port Authority--PATCO

Appendix III: FTA and ODP Passenger Rail Risk Assessments Conducted or In
                                    Progress

In Progress

1. Bay Area Rapid Transit

2. San Mateo County Transit District

3. San Francisco Municipal Railway

4. Metropolitan Transit Authority of Harris County, Texas

5. Chicago Transit Authority

6. Miami-Dade Transit

7. Metropolitan Atlanta Rapid Transit Authority

8. AMTRAK Northeast Corridor

9. Dallas Area Rapid Transit / Trinity Railway Express

10. South Florida Regional Transportation Authority

11. Maryland Transit Administration

12. Detroit Transportation Corporation

                         Appendix IV: Comments from the
                        Department of Homeland Security

Appendix IV: Comments from the Department of Homeland Security

Appendix IV: Comments from the Department of Homeland Security

Appendix IV: Comments from the Department of Homeland Security

Appendix IV: Comments from the Department of Homeland Security

Appendix IV: Comments from the Department of Homeland Security

Appendix V: GAO Contacts and Staff Acknowledgments

  GAO Contacts Acknowledgments

(440319)

Cathleen A. Berrick, (202) 512-8777 JayEtta Z. Hecker, (202) 512-2834

In addition to those named above, Seto Bagdoyan, Amy Bernstein, Leo
Barbour, Christopher Currie, Nikki Clowers, Scott Farrow, David Hooper,
Andrew Huddleston, Kirk Kiester, Octavia Parks, Jack Schulze, and Ray
Sendejas made key contributions to this report.

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