Aviation Security: Significant Management Challenges May	 
Adversely Affect Implementation of the Transportation Security	 
Administration's Secure Flight Program (09-FEB-06, GAO-06-374T). 
                                                                 
After the events of September 11, 2001, Congress created the	 
Transportation Security Administration (TSA) and directed it to  
assume the function of passenger prescreening--or the matching of
passenger information against terrorist watch lists to identify  
persons who should undergo additional security scrutiny--for	 
domestic flights, which is currently performed by the air	 
carriers. To do so, TSA is developing Secure Flight. This	 
testimony covers TSA's progress and challenges in (1) developing,
managing, and overseeing Secure Flight; (2) coordinating with key
stakeholders critical to program operations; (3) addressing key  
factors that will impact system effectiveness; and (4) minimizing
impacts on passenger privacy and protecting passenger rights.	 
This testimony includes information on areas of congressional	 
interest that GAO has previously reported on.			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-374T					        
    ACCNO:   A46640						        
  TITLE:     Aviation Security: Significant Management Challenges May 
Adversely Affect Implementation of the Transportation Security	 
Administration's Secure Flight Program				 
     DATE:   02/09/2006 
  SUBJECT:   Airport security					 
	     Aviation security					 
	     Computer-assisted passenger prescreening		 
	     system						 
                                                                 
	     Counterterrorism					 
	     Homeland security					 
	     Operational testing				 
	     Passengers 					 
	     Performance measures				 
	     Privacy policies					 
	     Program evaluation 				 
	     Program management 				 
	     Right of privacy					 
	     Secure flight					 
	     Systems design					 
	     Systems development life cycle			 
	     Transportation security				 
	     Stakeholder consultations				 
	     TSA Secure Flight Program				 

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GAO-06-374T

     

     * Summary
     * Background
          * Development of Legacy Passenger Prescreening Systems
          * Overview of Secure Flight Operations
     * TSA Has Not Followed a Disciplined Life Cycle Approach or Fu
          * TSA Has Not Followed a Disciplined Life Cycle Process or Ful
          * Comprehensive System Security Management Program Has Not Yet
          * Program Management Plan and Supporting Schedules and Cost Es
          * Oversight Reviews of Secure Flight Have Been Conducted and R
     * TSA Has Made Progress in Coordinating with Critical Stakehol
          * TSA Has Begun Collaborating with Key Stakeholders, but Their
          * Ongoing Coordination of Prescreening and
          * Name-Matching Initiatives Can Impact How Secure Flight Is Im
     * Key Factors That Will Influence the Effectiveness of Secure
          * Tests of Name-Matching Capability Are Under Way, but Full Sy
          * Key Policy Decisions That Will Impact System Effectiveness H
          * Efforts to Improve Data Quality and Accuracy Are Under Way,
          * False Identifying Information and Identity Theft Could Impac
     * Secure Flight Privacy Notices and Passenger Redress Process
          * Privacy Cannot Be Fully Assessed Because System Development
          * TSA Has Not Determined Secure Flight's Redress Process
     * Concluding Observations
     * GAO Contacts and Staff Acknowledgments
     * GAO's Mission
     * Obtaining Copies of GAO Reports and Testimony
          * Order by Mail or Phone
     * To Report Fraud, Waste, and Abuse in Federal Programs
     * Congressional Relations
     * Public Affairs

Testimony before the Committee on Commerce, Science, and Transportation,
U.S. Senate

United States Government Accountability Office

GAO

For Release on Delivery Expected at 10:00 a.m. EST

Thursday, February 9, 2006

AVIATION SECURITY

Significant Management Challenges May Adversely Affect Implementation of
the Transportation Security Administration's Secure Flight Program

Statement of Cathleen A. Berrick, Director, Homeland Security and Justice
Issues

GAO-06-374T

Mr. Chairman and Members of the Committee:

Thank you for inviting me to participate in today's hearing on the
Transportation Security Administration's (TSA) Secure Flight program. The
purpose of Secure Flight is to enable our government to protect the public
and strengthen aviation security by identifying and scrutinizing
individuals suspected of having ties to terrorism, or who may otherwise
pose a threat to aviation, in order to prevent them from boarding
commercial aircraft in the United States, if warranted, or by subjecting
them to additional security scrutiny prior to boarding an aircraft. The
program also aims to reduce the number of individuals unnecessarily
selected for secondary screening while protecting passengers' privacy and
civil liberties. My testimony today presents information on the progress
TSA has made and the challenges it faces in (1) developing, managing, and
overseeing the Secure Flight program; (2) coordinating with federal and
private sector stakeholders who will play critical roles in Secure Flight
operations; (3) addressing key factors that will impact system
effectiveness; and (4) minimizing program impacts on passenger privacy and
protecting passenger rights.

My testimony is based on our past reviews of the Secure Flight program,
and on preliminary results from our ongoing review of 10 issues related to
the development and implementation of Secure Flight, as mandated by Public
Law 109-90, and as requested by eight congressional committees.1 (See app.
1 for a description of the 10 issues.) My testimony today updates
information presented in our March 2005 report on the status of Secure
Flight's development and implementation,2 including 9 of the 10 areas of
congressional interest.3 In March 2005, we reported that TSA had made
progress in developing and testing Secure Flight, but had not completed
key system testing, had not finalized system requirements or determined
how certain aspects of the program would operate (such as the basis on
which passengers would be selected for preflight scrutiny), and had not
clearly defined the privacy impacts of the program. At the time, we
recommended that TSA take several actions to manage the risks associated
with developing and implementing Secure Flight, including finalizing
system requirements and test plans, privacy and redress requirements, and
program cost estimates.

1Section 518 of the Department of Homeland Security Appropriations Act,
2006 (Pub. L. No. 109-90) requires GAO to report to the Committees on
Appropriations of the Senate and House of Representatives on the 10 issues
listed in S: 522(a) the Department of Homeland Security Appropriations
Act, 2005 (Pub. L. No. 108-334), not later than 90 days after the
Secretary of the Department of Homeland Security certifies to the
above-named committees that Secure Flight has satisfied the 10 issues.
These 10 issues relate to system development and implementation,
effectiveness, program management and oversight, and privacy and redress.
We are also conducting our ongoing review in response to requests from the
United States Senate: the Committee on Commerce, Science, and
Transportation, and its Subcommittee on Aviation; Committee on
Appropriations, Subcommittee on Homeland Security; Committee on Homeland
Security and Governmental Affairs; Committee on Judiciary; also the House
of Representatives: Committee on Transportation and Infrastructure,
Committee on Homeland Security; and the Chairman of the Committee on
Government Reform.

2GAO, Aviation Security: Secure Flight Development and Testing Under Way,
but Risks Should Be Managed as System Is Further Developed, GAO-05-356
(Washington, D.C.: March 2005).

Today, I present information that suggests that, 3 years after TSA began
developing a program to provide passenger prescreening, significant
challenges remain in developing and implementing the Secure Flight
program. The results I am presenting are based on our review of available
documentation on Secure Flight's systems development and oversight,
policies governing program operations, and our past reports on the
program, and interviews with Department of Homeland Security (DHS)
officials, TSA program officials and their contractors, and other federal
officials who are key stakeholders in the Secure Flight program. We
reviewed TSA's System Development Life Cycle Guidance for developing
information technology systems, and other federal reports describing best
practices in developing and acquiring these systems. We also reviewed
draft TSA documents containing information on the development and testing
of Secure Flight, including concept of operations, requirements, test
plans, and test results. My testimony is based on TSA documents received,
but does not necessarily reflect all documentation that was only recently
made available. In addition to the TSA documents we have reviewed, we also
reviewed reports from the U.S. Department of Justice Office of the
Inspector General (DOJ-OIG), which reviewed the Secure Flight program, and
reports from two oversight groups that provided advisory recommendations
for Secure Flight: DHS's Privacy and Data Integrity Advisory Committee and
TSA's Aviation Security Advisory Committee Secure Flight Working Group. We
interviewed senior-level TSA officials, including representatives from the
Office of Transportation Threat Analysis and Credentialing, which is
responsible for Secure Flight, and the Office of Transportation Security
Redress (OTSR), to obtain information on Secure Flight's planning,
development, testing, and policy decisions. We also interviewed
representatives from the U.S. Customs and Border Protection (CBP) and
Terrorist Screening Center (TSC)4 to obtain information about stakeholder
coordination. We also interviewed officials from an air carrier and
representatives from aviation trade organizations regarding issues related
to Secure Flight's development and implementation. In addition, we
attended conferences on name-matching technologies sponsored by MITRE (a
federally funded research and development corporation) and the Office of
the Director of National Intelligence. Our work was conducted from April
2005 to February 2006 in accordance with generally accepted government
auditing standards.

3This statement does not provide information on the area of congressional
interest related to modifications with respect to intrastate travel to
accommodate states with unique air transportation needs because data were
not yet available to us on the effect of these modifications on air
carriers.

                                    Summary

In developing and managing the Secure Flight program, TSA has not
conducted critical activities in accordance with best practices for
large-scale information technology programs. Specifically, TSA has not
followed a disciplined life cycle approach in developing Secure Flight, in
which all phases of the project are defined by a series of orderly phases
and the development of related documentation. Program officials stated
that they have instead used a rapid development method that was intended
to enable them to develop the program more quickly. However, as a result
of this approach, the development process has been ad hoc, with project
activities conducted out of sequence. For example, program officials
declared the design phase complete before requirements for designing
Secure Flight had been detailed. Our evaluations of major federal
information technology programs, and research by others, has shown that
following a disciplined life cycle management process decreases the risks
associated with acquiring systems. As part of the life cycle process, TSA
must define and document Secure Flight's requirements-including how Secure
Flight is to function and perform, the data needed for the system to
function, how various systems interconnect, and how system security is
achieved. We found that Secure Flight's requirements documentation
contained contradictory and missing information. TSA officials have
acknowledged that they have not followed a disciplined life cycle approach
in developing Secure Flight, and stated that they are currently
rebaselining the program to follow their standard Systems Development Life
cycle process, including defining system requirements. We also found that
while TSA has taken steps to implement an information security management
program for protecting Secure Flight information and assets, its efforts
are incomplete, based on federal standards and industry best practices.
Without a completed system security program, Secure Flight may not be
adequately protected against unauthorized access and use or disruption,
once the program becomes operational. Finally, TSA is proceeding with
Secure Flight development without an effective program management plan
that contains current program schedules and cost estimates. TSA officials
stated they have not maintained an updated schedule in part because the
agency has not yet promulgated a necessary regulation requiring commercial
air carriers to submit certain passenger data needed to operate Secure
Flight, and air carrier responses to this regulation can impact when
Secure Flight will be operational and at what cost. While we recognize
that program unknowns introduce uncertainty into the program-planning
process, uncertainty is a practical reality in planning all programs and
is not a reason for not developing plans, including cost and schedule
estimates that reflect known and unknown aspects of the program. Further,
several oversight reviews of the program have been conducted and raise
questions about program management, including the lack of fully defined
requirements. TSA has recently taken actions that recognize the need to
instill more rigor and discipline into the development and management of
Secure Flight, including hiring a program manager with information systems
program management credentials, and more completely defining system
requirements and a program management plan, including the development of
schedules and cost estimates.

4TSC was established in accordance with Homeland Security Presidential
Directive-6 to consolidate the government's approach to terrorism
screening, including the use of terrorist information for screening
purposes. TSC is an interagency effort involving DHS, Department of
Justice, Department of State, and intelligence community representatives
and is administered by the Federal Bureau of Investigation.

TSA has taken steps to collaborate with Secure Flight stakeholders whose
participation is essential to ensuring that passenger and terrorist watch
list data are collected and transmitted for Secure Flight operations, but
additional information and testing are needed to enable stakeholders to
provide the necessary support for the program. TSA has, for example,
drafted policy and technical guidance to help inform air carriers of their
Secure Flight responsibilities, and has begun receiving feedback from the
air carriers on this information. TSA is also in the early stages of
coordinating with U.S. Customs and Border Protection and the federal
Terrorist Screening Center on broader issues of integration and
interoperability related to other people-screening programs used by the
government to combat terrorism. In addition, TSA has conducted preliminary
network connectivity testing between TSA and federal stakeholders to
determine, for example, how information will be transmitted from CBP to
TSA and back. However, these tests used only dummy data, and were
conducted in a controlled environment, rather than in a real-world
operational environment. According to CBP, without real data, it is not
possible to conduct stress testing to determine if the system can handle
the volume of data traffic that will be required by Secure Flight. TSA
acknowledged it has not determined what the real data volume requirements
will be, and cannot do so until the regulation for air carriers has been
issued and their data management role has been finalized. All key program
stakeholders also stated that additional information is needed before they
can finalize their plans to support Secure Flight operations. A TSC
official stated, for example, that until TSA provides estimates of the
volume of potential name matches that TSC will be required to screen, TSC
cannot make decisions about required resources. Also, ongoing coordination
of prescreening and name-matching initiatives with CBP and TSC can impact
how Secure Flight is implemented.

In addition to collaborating with stakeholders, TSA has, over the past 11
months, made some progress in evaluating factors that could influence
system effectiveness. However, several activities are under way, or are to
be decided, that will also affect Secure Flight's effectiveness, including
operational testing to provide information about Secure Flight's ability
to function. TSA has been testing name-matching technologies to determine
what type of passenger data will be needed to match against terrorist
watch list data. These tests have been conducted thus far in a controlled,
rather than real-world environment, using historical data, but additional
testing is needed to learn more about how these technologies will perform
in an operational environment. In addition, due to program delays, TSA has
not yet conducted comprehensive end-to-end testing to verify that the
entire system functions as intended, although it had planned to do so last
summer. TSA also has not yet conducted stress testing to determine how the
system will handle peak data volumes. In addition, TSA has not made key
policy decisions for determining the passenger information that air
carriers will be required to collect, the name-matching technologies that
will be used to vet passenger names against terrorist watch list data; and
thresholds that will be set to determine the relative volume of passengers
who are to be identified as potential matches against the database. TSA
plans to finalize decisions on these factors as system development
progresses. However, until these decisions are made, data requirements
will remain unsettled and key stakeholders-in particular, air
carriers-will not have the information they need to assess and plan for
needed changes to their systems to interface with Secure Flight. On the
issue of data quality and accuracy, while the completeness and accuracy of
data contained in the government's terrorist screening database can never
be certain-given the varying quality of intelligence information gathered,
and changes in this information over time-TSC has established some
processes to help ensure the quality of these data. However, in a review
of the TSC's role in Secure Flight, the Department of Justice Office of
Inspector General found that TSC could not ensure that the information
contained in its databases was complete or accurate. According to a TSC
official, TSA and TSC plan to enter into a letter of agreement that will
describe the data elements from the terrorist-screening database, among
other things, to be used for Secure Flight. To address accuracy, TSA and
TSC plan to work together to identify false positives-passengers
inappropriately matched against data contained in the terrorist-screening
database-by using intelligence analysts to monitor the accuracy of data
matches. An additional factor that could impact the effectiveness of
Secure Flight in identifying known or suspected terrorists is the system's
inability to identify passengers who assume the identity of another
individual by committing identity theft, or who use false identifying
information. Secure Flight is neither intended to nor designed to address
these vulnerabilities.

Because Secure Flight's system development documentation does not fully
address how passenger privacy protections are to be met, it is not
possible to assess potential system impacts on individual privacy
protections. The Privacy Act and the Fair Information Practices-a set of
internationally recognized privacy principles that underlie the Privacy
Act-limit the collection, use, and disclosure of personal information by
federal agencies. TSA officials have stated that they are committed to
meeting the requirements of the Privacy Act and the Fair Information
Practices However, it is not yet evident how this will be accomplished
because TSA has not decided what passenger data elements it plans to
collect, or how such data will be provided by stakeholders. Further, TSA
is in the process of developing but has not issued the systems of records
notice, which is required by the Privacy Act, or the privacy impact
assessment, which is required by the E-Government Act, that would describe
how TSA will protect passenger data once Secure Flight becomes
operational. Moreover, privacy requirements were not incorporated into the
Secure Flight system development process in a manner that would explain
whether personal information will be collected and maintained in the
system in a manner that complies with privacy and security requirements.
In our review of Secure Flight's system requirements, we found that
privacy concerns were broadly defined in functional requirements
documentation, which states that the Privacy Act must be considered in
developing the system. However, these broad functional requirements have
not been translated into specific system requirements. TSA officials
stated that they are completing work on integrating privacy and
requirements into the Secure Flight system as the program is being
developed, and that new privacy notices will be issued in conjunction with
a forthcoming regulation prior to proceeding with the system's initial
operating capability. Until TSA finalizes these requirements and notices,
however, privacy protections and impacts cannot be assessed. TSA is also
determining how it will meet a congressional mandate that the Secure
Flight program include a process whereby aviation passengers determined to
pose a threat to aviation security may appeal that determination and
correct erroneous information contained within the prescreening system.
According to TSA officials, no final decisions have been made regarding
how TSA will address the redress requirements, but information on the
process will be contained within the privacy notices released in
conjunction with the forthcoming regulation.

                                   Background

TSA is responsible for securing all modes of transportation while
facilitating commerce and the freedom of movement for the traveling
public. Passenger prescreening is one program among many that TSA uses to
secure the domestic aviation sector. The process of prescreening
passengers-that is, determining whether airline passengers might pose a
security risk before they reach the passenger-screening checkpoint-is used
to focus security efforts on those passengers that represent the greatest
potential threat. Currently, U.S. air carriers conduct passenger
prescreening by comparing passenger names against government-supplied
terrorist watch lists and applying the Computer-Assisted Passenger
Prescreening System rules, known as CAPPS rules.5

Development of Legacy Passenger Prescreening Systems

Following the events of September 11, and in accordance with the
requirement set forth in the Aviation and Transportation Security Act that
a computer-assisted passenger prescreening system be used to evaluate all
passengers before they board an aircraft,6 TSA established the Office of
National Risk Assessment to develop and maintain a capability to prescreen
passengers in an effort to protect U.S. transportation systems and the
public against potential terrorists. In March 2003, this office began
developing the second-generation computer-assisted passenger prescreening
system, known as CAPPS II, to provide improvements over the current
prescreening process, and to screen all passengers flying into, out of,
and within the United States.

5CAPPS rules are characteristics that are used to select passengers who
require additional security scrutiny. CAPPS rules are Sensitive Security
Information.

6Aviation and Transportation Security Act, Pub. L. No. 107-71, S: 136, 115
Stat. 597, 637 (2001).

Based in part on concerns about privacy and other issues expressed by us
and others, DHS canceled the development of CAPPS II in August 2004 and
shortly thereafter announced that it planned to develop a new passenger
prescreening program called Secure Flight. In contrast to CAPPS II, Secure
Flight, among other changes, will only prescreen passengers flying
domestically within the United States, rather than passengers flying into
and out of the United States. Also, the CAPPS rules will not be
implemented as part of Secure Flight, but rather the rules will continue
to be applied by commercial air carriers. Secure Flight will operate on
the Transportation Vetting Platform (TVP)7-the underlying infrastructure
(hardware and software) to support the Secure Flight application,
including security, communications, and data management; and, the Secure
Flight application is to perform the functions associated with receiving,
vetting, and returning requests related to the determination of whether
passengers are on government watch lists. This application is also to be
configurable-meaning that it can be quickly adjusted to reflect changes to
workflow parameters. Aspects of Secure Flight are currently undergoing
development and testing, and policy decisions regarding the operations of
the program have not been finalized.8

Overview of Secure Flight Operations

As currently envisioned, under Secure Flight, when a passenger makes
flight arrangements, the organization accepting the reservation, such as
the air carrier's reservation office or a travel agent, will enter
passenger name record (PNR) information obtained from the passenger, which
will then be stored in the air carrier's reservation system. 9 While the
government will be asking for only portions of the PNR, the PNR data can
include the passenger's name, phone number, number of bags, seat number,
and form of payment, among other information. Approximately 72 hours prior
to the flight, portions of the passenger data contained in the PNR will be
sent to Secure Flight through a network connection provided by DHS's CBP.
Reservations or changes to reservations that are made less than 72 hours
prior to flight time will be sent immediately to TSA through CBP.

7TSA plans to use this centralized vetting capability to identify
terrorist threats in support of various DHS and TSA programs. In addition
to Secure Flight, TSA plans to use the platform to ensure that persons
working at sensitive locations; serving in trusted positions with respect
to the transportation infrastructure; or traveling as cockpit and cabin
crew into, within, and out of the United States are properly screened
depending on their activity within the transportation system. In addition
to supporting the Secure Flight and Crew Vetting programs, TSA expects to
leverage the platform with other applications such as TSA screeners and
screener applicants, commercial truck drivers with hazardous materials
endorsements, aviation workers with access to secure areas of the
airports, alien flight school candidates, and applicants for TSA's
domestic Registered Traveler program.

8The Intelligence Reform and Terrorism Prevention Act of 2004 requires
that TSA begin to assume responsibility for the passenger prescreening
function within 180 days after the completion of testing. Pub. L. No.
108-458 S: 4012, 118 Stat. 3638, 3714-19 (codified as amended at 49 U.S.C.
S: 44903(j)(2)).

Upon receipt of passenger data, TSA plans to process the passenger data
through the Secure Flight application running on the TVP. During this
process, Secure Flight is to determine if the passenger data match the
data extracted daily from TSC's Terrorist Screening Database (TSDB)-the
information consolidated by TSC from terrorist watch lists to provide
government screeners with a unified set of terrorist-related information.
In addition, TSA will screen against its own watch list composed of
individuals who do not have a nexus to terrorism but who may pose a threat
to aviation security.10

In order to match passenger data to information contained in the TSDB, TSC
plans to provide TSA with an extract of the TSDB for use in Secure Flight,
and provide updates as they occur. This TSDB subset will include all
individuals classified as either selectees (individuals who are selected
for additional security measures prior to boarding an aircraft) or no-flys
(individuals who will be denied boarding unless they are cleared by law
enforcement personnel).11 To perform the match, Secure Flight is to
compare the passenger, TSDB, and other watch list data using automated
name-matching technologies. When a possible match is generated, TSA and
potentially TSC analysts will conduct a manual review comparing additional
law enforcement and other government information with passenger data to
determine if the person can be ruled out as a possible match. TSA is to
return the matching results to the air carriers through CBP. Figure 1
illustrates how Secure Flight is intended to operate.

9This description of the Secure Flight system, as well as the graphic
illustrating the system in figure1, is based on TSA's draft June 9, 2005,
concept of operations, a document that gives a high-level overview of the
Secure Flight system.

10TSA also plans to utilize a cleared list as part of the watch list
matching process; the cleared list is composed of individuals who are
frequently misidentified as being on the TSDB and who have applied, and
been approved, to be on the list.

11These measures may include additional screening or other law enforcement
actions.

Figure 1: Planned Operation of Secure Flight

aInformation about confirmed no-flies and certain selectees are shared
with appropriate federal agencies which coordinate the appropriate law
enforcement response.

As shown in figure 1, when the passenger checks in for the flight at the
airport, the passenger is to receive a level of screening based on his or
her designated category. A cleared passenger is to be provided a boarding
pass and allowed to proceed to the screening checkpoint in the normal
manner. A selectee passenger is to receive additional security scrutiny at
the screening checkpoint.12 A no-fly passenger will not be issued a
boarding pass. Instead, appropriate law enforcement agencies will be
notified. Law enforcement officials will determine whether the individual
will be allowed to proceed through the screening checkpoint or if other
actions are warranted, such as additional questioning of the passenger or
taking the passenger into custody.

 TSA Has Not Followed a Disciplined Life Cycle Approach or Fully Defined System
                       Requirements, Schedule, and Costs

TSA has not followed a disciplined life cycle approach in developing
Secure Flight, in accordance with best practices for large-scale
information technology programs. Following a disciplined life cycle,
activities and related documentation are to be developed in a logical
sequence. TSA also has not finalized and documented functional and system
requirements that fully link to each other and to source documents.
Without adequately defined requirements, TSA cannot finalize a system
security plan or develop a reliable program schedule or life cycle cost
estimates. In addition to these concerns, other reviews that have been
conducted of Secure Flight have raised questions about the management of
the program.

TSA Has Not Followed a Disciplined Life Cycle Process or Fully Defined System
Requirements but Plans to Address These Issues

Based on evaluations of major federal information technology programs like
Secure Flight, and research by others, following a disciplined life cycle
management process in which key activities and phases of the project are
conducted in a logical and orderly process and are fully documented, helps
ensure that programs achieve intended goals within acceptable levels of
cost and risk. Such a life cycle process begins with initial concept
definition and continues through requirements determination to final
testing, implementation, and maintenance. TSA has established a System
Development Life Cycle (SDLC) that defines a series of orderly phases and
associated steps and documentation. The SDLC serves as the mechanism to
ensure that systems are effectively managed and overseen. Figure 2
provides a description of TSA's SDLC phases and related documentation.

12Some selectees will receive a boarding pass from air carriers, but be
required to undergo secondary screening prior to boarding the aircraft,
while other selectees will first be met by law enforcement personnel, who
will determine if the individual should receive a boarding pass. In
addition, air carriers, through their application of the CAPPS rules, may
also designate a passenger as a selectee.

Figure 2: Summary of TSA's System Development Life Cycle Process

TSA has not followed its SDLC in developing and managing Secure Flight.
Rather, program officials stated that they have used a rapid development
method that was intended to enable them to develop the program more
quickly. However, these officials could not provide us with details on how
this approach was implemented. As a result, our analysis of steps
performed and documentation developed indicates that Secure Flight has not
been pursued within the context of a logical, disciplined, system
development methodology. Rather the process has been ad hoc, with project
activities conducted out of sequence. For example, program officials
declared that the program's design phase was completed before system
requirements had been adequately detailed, and key activities have yet to
be adequately performed, such as program planning and defining system
requirements. TSA officials acknowledged that problems arose with Secure
Flight as a result of using this approach. As a result, it is currently
unclear what Secure Flight capabilities are to be developed, by when, at
what cost, and what benefits are to accrue from the program. Without
clarification on these decision points, the program is at risk of failure.

Defining and documenting system requirements is integral to life cycle
development. Based on best practices and our prior work in this area, the
expected capabilities of a system such as Secure Flight should be defined
in terms of requirements for functionality (what the system is to do),
performance (how well the system is to execute functions), data (what data
are needed by what functions, when, and in what form), interface (what
interactions with related and dependent systems are needed), and security.
Further, system requirements should be unambiguous, consistent with one
another, linked (that is, traceable from one source level to another),13
verifiable, understood by stakeholders, and fully documented.

TSA has prepared certain Secure Flight requirements documents, and
officials stated that they are now reviewing those requirements
documents.14 We support these review efforts because we found, in the
requirements documents we reviewed, inconsistencies and ambiguities in
requirements documentation for system functions, performance, data, and
security-and that these documents were not always complete. For example,
according to TSA's SDLC guidance and best practices for developing
information technology systems, systems like Secure Flight should have a
comprehensive concept of operations covering all aspects of the program
during the planning phase (see fig. 2). We reported in our March 2005
report that TSA had not yet finalized a concept of operations, which would
describe conceptually the full range of Secure Flight operations and
interfaces with other systems, and we recommended that it develop one.
Since March 2005, TSA documents refer to numerous concept of operations,
such as a long concept of operations, a short concept of operations, and
an initial operational capability concept of operations. TSA provided a
June 2005 concept of operations for our review, but this document does not
contain key system requirements, such as the high-level requirements for
security and privacy.

13Examples of higher-order sources include legislation, which may dictate
certain requirements, and other system documentation, such as the
operational concept. When requirements are managed well, traceability can
be established from the source requirements to lower-level requirements
and from the lower level back to their source. Such bidirectional
traceability helps determine that all source requirements have been
addressed completely and that all lower-level requirements can be verified
as derived from a valid source.

In addition, we found that Secure Flight requirements were unclear or
missing. For example, while the requirements that we reviewed state that
the system be available 99 percent of the time, this only covers the TVP
and Secure Flight application. It does not include requirements for the
interfacing systems critical for Secure Flight operations. Thus, the
availability requirements for all of the components of the Secure Flight
system are not yet known. Some data requirements are also vague or
incomplete; for example, one data requirement is that the data is current,
but the meaning of current is not defined. In addition, only some system
security requirements are identified in the security document provided to
us for the TVP, and sections in TSA's Systems Requirements Specification
contain only placeholder notes-"to be finalized"-for security and privacy
requirements.

TSA officials acknowledged that it is important that requirements be
traceable to ensure that they are consistently, completely, and correctly
defined, implemented, and tested. To help accomplish this, TSA officials
stated that they use a requirements tracking tool for Secure Flight that
can align related requirements to different documents, and thus establish
traceability (e.g., it can map the Systems Requirements Specification to a
functional requirements document). According to program officials, this
tool can also be used for aligning and tracing requirements to test cases
(i.e., scenarios used to determine that the system is working as
intended). We found, however, that requirements for Secure Flight have not
been fully traced. For example, we were not able to trace system
capabilities in contractual documents to the concept of operations and
then to the various requirement documents, to design phase use cases, and
to test cases. In addition, contractor staff we interviewed stated that
they were unable to use this tool to align or trace necessary requirements
without the aid of supplemental information. Without internal alignment
among system documentation relating to requirements, there is not adequate
assurance that the system produced will perform as intended.

14Key requirements documentation we reviewed included the Transportation
Vetting Platform/Secure Flight System Requirements Specification (May 13,
2005), the Secure Flight System Security Plan (July 15, 2005), the
Transportation Vetting Platform System Security Plan (July 15, 2005),
Transportation Vetting Platform and Secure Flight Security Risk Assessment
(July 15, 2005), and documentation called for under Federal Information
Processing Standard (FIPS) 199 (August 23, 2005).

In addition, we found that available Secure Flight requirements documents
did not define the system's boundaries, including interfaces, for each of
the stakeholders-that is, the scope of the system from end to end, from an
air carrier to CBP, to TSA, to TSC, and back to TSA, then again to CBP and
air carriers (refer to fig. 1 for an overview of this process). Defining a
system's boundaries is important in ensuring that system requirements
reflect all of the processes that must be executed to achieve a system's
intended purpose. According to TSA's SDLC guidance, a System Boundary
Document is to be developed early in the system life cycle. However, in
its third year of developing a passenger prescreening system, TSA has not
yet prepared such a document. Although the System Boundary Document was
not available, the program's Systems Security Document does refer to an
"accreditation boundary," which defines the Secure Flight system from the
standpoint of system security accreditation and certification. According
to this definition of what Secure Flight includes, those systems that are
needed to accomplish Secure Flight program goals (e.g., those of
commercial air carriers, CBP, and TSC) are not part of Secure Flight. If
the boundary documents, and thus the requirements, do not reflect all
system processes and connections that need to be performed, the risk is
increased that the system will not achieve Secure Flight's intended
purpose. Moreover, until all system requirements have been defined, TSA
will not be able to stress-test Secure Flight in an operational,
end-to-end mode. In our March 2005 report, we recommended that TSA
finalize its system requirements documents and ensure that these documents
address all system functionality. Although TSA agreed with our
recommendations, the requirements documentation that we reviewed showed
that the agency has not yet completed these activities.

Our evaluations of major federal information technology programs, and
research by others, has shown that following a disciplined life cycle
management process decreases the risks associated with acquiring systems.
The steps and products in the life cycle process each have important
purposes, and they have inherent dependencies among themselves. Thus, if
earlier steps and products are omitted or deficient, later steps and
products will be affected, resulting in costly and time-consuming rework.
For example, a system can be effectively tested to determine whether it
meets requirements only if these requirements have already been fully
defined. Concurrent, incomplete, and omitted activities in life cycle
management exacerbate the program risks. Life cycle management weaknesses
become even more critical as the program continues, because the size and
complexity of the program will likely only increase, and the later
problems are found, the harder and more costly they will likely be to fix.

In October 2005, Secure Flight's director of development stated in a
memorandum to the assistant TSA administrator responsible for Secure
Flight that by not following a disciplined life cycle approach, in order
to expedite the delivery of Secure Flight, the government had taken a
calculated risk during the requirements definition, design, and
development phases of the program's life cycle development. The director
stated that by prioritizing delivery of the system by a specified date in
lieu of delivering complete documentation, TSA had to lower its standards
of what constituted acceptable engineering processes and documentation.
Since then, TSA officials stated that the required system documentation
associated with each phase of the TSA life cycle is now being developed to
catch up with development efforts. In addition, TSA recognized that it
faces challenges preparing required systems documentation, and to help in
this regard it has recently hired a certified systems program manager to
manage systems development. In January 2006, this program manager stated
that as Secure Flight moves forward, TSA's SDLC would be followed in order
to instill greater rigor and discipline into the system's development. In
addition, TSA plans to hire a dedicated program director for Secure Flight
to manage program activities, schedules, milestones, costs, and program
contractors, among other things.

Comprehensive System Security Management Program Has Not Yet Been Established in
Accordance with Federal Guidance

TSA has taken steps to implement an information system security management
program for protecting Secure Flight information and assets. Secure
Flight's security plans and the related security review, which TSA
developed and conducted to establish authority to operate, are important
steps in the system's development. However, the steps related to system
security TSA has taken to date are individually incomplete, and
collectively fall short of a comprehensive system security management
program. Federal guidance and industry best practices describe critical
elements of a comprehensive information system security management
program. Without effective system security management, it is unlikely that
Secure Flight will, for example, be adequately protected against
unauthorized access and use, disruption, modification, and destruction.

According to National Institute of Standards and Technology (NIST)15 and
Office of Management and Budget (OMB) guidance under the Federal
Information Security Management Act, as well as industry best practices, a
comprehensive system security management program includes (1) conducting a
system wide risk assessment that is based on system threats and
vulnerabilities, (2) developing system security requirements and related
policies and procedures that govern the operation and use of the system
and address identified risks, (3) certifying that the system is secure
based on sufficient review and testing to demonstrate that the system
meets security requirements, and (4) accrediting the system as secure in
an operational setting.

TSA has developed two system security plans-one for the TVP and one for
the Secure Flight application. However, neither of these plans nor the
security activities that TSA has conducted to date are complete. For
example, while security threats and vulnerabilities were assessed in the
documentation and risks were identified in risk assessments, requirements
to address these risks were only partially defined in the security plan
for the TVP, and they were not included at all in the plan for the Secure
Flight application. In addition, the sections on security requirements and
privacy requirements in the System Requirements Specification document
read "to be finalized" with no further description.

15The NIST requirements provide guidelines for selecting and specifying
security controls for information systems supporting the executive
agencies of the federal governments. The guidelines apply to all
components of an information system that processes, stores, or transmits
federal information.

Moreover, we also found that the security systems plans did not reflect
the current level of risk designated for the program. For example,
although the July 15, 2005, System Security Plan for the TVP arrived at an
overall assessment of its exposure to risks as being "medium," an August
23, 2005, requirements document found that the security risk level for the
TVP was "high." As a system moves from a medium to a high level of risk,
the security requirements become more stringent. TSA has not provided us
with an updated System Security Plan for the TVP that addressed this
greater level of risk by including additional NIST requirements for a
high-risk system. In addition, this TVP System Security Plan included only
about 40 percent of the NIST requirements associated with a medium-risk
system. Without addressing all NIST requirements, in addition to those
required for a high-risk system, TSA may not have proper controls in place
to protect sensitive information.

According to federal guidance and requirements, the determination and
approval of the readiness of a system to securely operate is accomplished
via a certification and accreditation process. On September 30, 2005, the
TSA assistant administrator responsible for Secure Flight formally granted
authority, based on certification and accreditation results, for the TVP
and the Secure Flight application to operate.16 However, the team
performing the certification found that TSA was unsure whether they tested
all components of the security system for the TVP and the Secure Flight
application, because TSA lacked an effective and comprehensive inventory
system. Therefore the certification team could not determine whether its
risk assessments were complete or accurate. This team also documented 62
security vulnerabilities for the Secure Flight application and 82 security
vulnerabilities for the TVP. The certification team recommended authority
to operate on the condition that corrective action or obtaining an
exemption for the identified vulnerabilities would be taken within 90 days
or the authority to operate would expire. TSA officials stated that these
vulnerabilities had been addressed except for three that are being
reviewed in a current security audit.

16An authorization to operate is issued for the information system, if,
after assessing the results of the security certification, the authorizing
official deems that the risk to agency operations, agency assets, or
individuals is acceptable.

Program Management Plan and Supporting Schedules and Cost Estimates for Secure
Flight Have Not Been Maintained

TSA has proceeded with Secure Flight development over the past year
without a complete and up-to-date program management plan, and without
associated cost and schedule estimates showing what work will be done by
whom, at what cost, and when. A program management plan can be viewed as a
central instrument for guiding program development. Among other things,
the plan should include a breakout of the work activities and products
that are to be conducted in order to deliver a mission capability to
satisfy stated requirements and produce promised mission results. This
information, in turn, provides the basis for determining the time frames
and resources needed for accomplishing this work, including the basis for
milestones, schedules, and cost estimates. TSA has not provided us with
either the complete and up-to-date program management plan, or an
estimated schedule and costs for Secure Flight. According to a TSA
official, an updated program management plan is currently being developed
and is about 90 percent complete.

In lieu of a program management plan with a schedule and milestones, TSA
has periodically disclosed program milestones. However, the basis for and
meaning of these milestones have not been made clear, and TSA's progress
in meeting these milestones has not been measured and disclosed. TSA's
SDLC and OMB17 guidance require that programs like Secure Flight provide
risk-adjusted schedule goals, including key milestones, and that programs
demonstrate satisfactory progress toward achieving their stated
performance goals. In March 2005, we reported that the milestone that TSA
set for achieving initial operating capability for Secure Flight had
slipped from April 2005 to August 2005. TSA officials stated that TSA
revised this milestone to state that instead of achieving initial
operating capability, it would begin operational testing. This new
milestone subsequently slipped first to September 2005, then to November
2005. Since that time, the program has not yet begun operational testing
or initial operations, and TSA has not yet produced an updated schedule
identifying when program operations will begin or when other key
milestones are to be achieved to guide program development and
implementation. Further, while agency officials stated that they are now
planning for operational testing of an unspecified capability, no
milestone date has been set for doing so.

17OMB, Circular No. A-11, Part 7, Sec. 300. Planning, Budgeting,
Acquisition, and Management of Capital Assets.

TSA officials stated that they have not maintained an updated program
schedule for Secure Flight in part because the agency has not yet
determined the rulemaking approach it will pursue for requiring commercial
air carriers to submit certain passenger data needed to operate Secure
Flight, among other things. Specifically, TSA officials stated that a
schedule with key milestones, such as operational testing, cannot be set
until after air carriers have responded to the rulemaking and provided
their plans and schedules for participating in Secure Flight. The
rulemaking has been pending since the spring of 2005, and the rule remains
in draft form and is under review, according to TSA officials. Once the
rule has been issued, TSA officials stated that air carriers will be given
time to respond with their plans and schedules. TSA officials further
stated that until this occurs, and a decision is made as to how many air
carriers will participate in a yet-to-be-defined initial phase of the
program (they are expected to begin incrementally), a program schedule
cannot be set.

Further, TSA has not yet established cost estimates for developing and
deploying either an initial or a full operating capability for Secure
Flight, and it has not developed a life-cycle cost estimate (estimated
costs over the expected life of a program, including direct and indirect
costs and costs of operation and maintenance). TSA also has not updated
its expenditure plan-plans that generally identify near-term program
expenditures-to reflect the cost impact of program delays, estimated costs
associated with obtaining system connectivity with CBP, or estimated costs
expected to be borne by air carriers. Program and life cycle cost
estimates are critical components of sound program management for the
development of any major investment. Developing cost estimates is also
required by OMB guidance and can be important in making realistic
decisions about developing a system. Expenditure plans are designed to
provide lawmakers and other officials overseeing a program's development
with a sufficient understanding of the system acquisition to permit
effective oversight, and to allow for informed decision making about the
use of appropriated funds.

In our March 2005 report, we recommended that TSA develop reliable life
cycle cost estimates and expenditure plans for the Secure Flight program,
in accordance with guidance issued by OMB, in order to provide program
managers and oversight officials with the information needed to make
informed decisions about program development and resource allocations.
Although TSA agreed with our recommendation, it has not yet provided this
information. TSA officials stated that developing program and life cycle
cost estimates for Secure Flight is challenging because no similar
programs exist from which to base cost estimates and because of the
uncertainties surrounding Secure Flight requirements. Further, they stated
that cost estimates cannot be accurately developed until after system
testing is completed and policy decisions have been made regarding Secure
Flight requirements and operations. Notwithstanding these statements, TSA
officials stated that they are currently assessing program and life cycle
costs as part of their rebaselining and that this new baseline will
reflect updated cost, funding, scheduling, and other aspects of the
program's development.

While we recognize that program unknowns introduce uncertainty into the
program-planning process, including estimating tasks, time frames, and
costs, uncertainty is a practical reality in planning all programs and is
not a reason for not developing plans, including cost and schedule
estimates, that reflect known and unknown aspects of the program. In
program planning, assumptions need to be made and disclosed in the plans,
along with the impact of the associated uncertainty on the plans and
estimates. As more information becomes known over the life of the program,
these plans should be updated to recognize and reflect the greater
confidence in activities that can be expressed with estimates.

Program management plans and related schedules and cost estimates-based on
well-defined requirements-are important in making realistic decisions
about a system's development, and can alert an agency to growing schedule
or cost problems and the need for mitigating actions. Moreover, best
practices and related federal guidance emphasize the need to ensure that
programs and projects are implemented at acceptable costs and within
reasonable and expected time frames. Investments such as Secure Flight are
approved on the expectation that programs and projects will meet certain
commitments to produce certain capabilities and benefits (mission value)
within the defined schedule and cost. Until an updated program management
plan and related schedules and cost estimates and expenditure plans, are
prepared for Secure Flight-which should be developed despite program
uncertainties, and updated as more information is gained-TSA and Congress
will not be able to provide complete oversight over the program's progress
in meeting established commitments.

Oversight Reviews of Secure Flight Have Been Conducted and Raised Questions
about Program Management

DHS and TSA have executive and advisory oversight mechanisms in place to
oversee Secure Flight. As we reported in March 2005, the DHS Investment
Review Board (IRB)-designed to review certain programs at key phases of
development to help ensure they meet mission needs at expected levels of
costs and risks-reviewed the TVP from which Secure Flight will operate, in
January 2005.18 As a result of this review, the board withheld approval
for the TVP to proceed from development and testing into production and
deployment until a formal acquisition plan, a plan for integrating and
coordinating Secure Flight with other DHS people-screening programs, and a
revised acquisition program baseline (cost, schedule, and performance
parameters) had been completed. Since that time, TSA has not yet addressed
these conditions and has not obtained approval from the IRB to proceed
into production. DHS officials stated that an IRB review is scheduled to
be held in March 2006-14 months after the IRB last met to examine Secure
Flight-to review Secure Flight and other people-screening programs,
including international prescreening conducted by CBP. Specifically, the
board will review the acquisition strategy and progress for each program,
focusing, in part, on areas of potential duplication. According to TSA
officials, the agency intends to establish a new program cost, schedule,
and capability baseline for Secure Flight, which will be provided to the
IRB for review.

DHS's Data Privacy and Integrity Advisory Committee also reviewed Secure
Flight during the last year.19 Committee members have diverse expertise in
privacy, security, and emerging technology, and come from large and small
companies, the academic community, and the nonprofit sector. In December
2005, the committee issued five recommendations on key aspects of the
program, including recommendations designed to minimize data collection
and provide an effective redress mechanism to passengers who believe they
have been incorrectly identified for additional security scrutiny. TSA
officials stated that they are considering the advisory committees'
findings and recommendations as part of their rebaselining efforts.

18The DHS Investment Review Board also reviewed the CAPPS II program in
October 2003 and authorized the program to proceed with the system's
development.

19The committee was established under the authority of the Homeland
Security Act, P.L. 107-296, in accordance with the provisions of the
Federal Advisory Committee Act (5 U.S.C. App.2). At the first meeting of
the committee, in April 2005, Secure Flight was recommended as a program
for examination for numerous reasons, including the number of citizens
affected by the program, weaknesses in the program's redress system
identified by us in our March 2005 report, and the program's potential use
as a model for other related DHS efforts.

In September 2004, TSA appointed an independent working group within the
Aviation Security Advisory Committee,20 composed of government privacy and
security experts, to review Secure Flight. The working group issued a
report in September 2005 that concluded, among other things, that TSA had
not produced a comprehensive policy document for Secure Flight that could
define oversight or governance responsibilities, nor had it provided an
accountability structure for the program. The group attributed this
omission to the lack of a program-level policy document issued by a senior
executive, which would clearly state program goals. The working group also
questioned Secure Flight's oversight structure and stated that it should
focus on the effectiveness of privacy aspects of the program and, in doing
so, consider oversight regimes for federal law enforcement and U.S.
intelligence activities.

In addition to oversight reviews initiated by DHS and TSA, the DOJ-OIG
issued a report in August 2005 reviewing TSC's role in supporting Secure
Flight. 21 In its report, the DOJ-OIG reported that TSC faced several key
factors that were unknown with respect to supporting Secure Flight,
including when the program will begin, the volume of inquiries it will
receive, the number of TSC resources required to respond to these
inquiries, and the quality of the data it will have to analyze. In light
of these findings, the DOJ-OIG report recommended that, among other
things, TSC better prepare itself for future needs related to Secure
Flight by strengthening its budgeting and staffing processes and by
improving coordination with TSA on data exchange standards. In June 2005,
a DOJ-OIG report recommended that TSC conduct a record-by-record review of
the TSDB to improve overall data quality and integrity. TSC agreed with
all recommendations made.22

20The Aviation Security Advisory Committee, now within DHS, was formed in
1989 to provide advice on a variety of aviation security issues.

21Department of Justice Office of the Inspector General, Review of the
Terrorist Screening Center's Efforts to Support the Secure Flight Program,
August 2005. Congress requested that the DOJ-OIG evaluate TSC's plans to
support Secure Flight to report these findings to the House and Senate
Appropriations Committees.

22Department of Justice Office of the Inspector General, Review of the
Terrorist Screening Center, June 2005.

 TSA Has Made Progress in Coordinating with Critical Stakeholders but More Work
                                    Remains

TSA has drafted policy and technical guidance to help inform air carriers
of their Secure Flight responsibilities, and has begun coordinating with
CBP and TSC on Secure Flight requirements and broader issues of
integration and interoperability between Secure Flight and other
people-screening programs. However, TSA has not yet provided information
and technical requirements that all stakeholders need to finalize their
plans to support the program's operations, and to adequately plan for the
resources needed to do so.

TSA Has Begun Collaborating with Key Stakeholders, but Their Participation Will
Be Limited Until System Requirements Have Been Finalized

As we reported in March 2005, key federal and commercial stakeholders-CBP,
TSC, and commercial air carriers-will play a critical role in the
collection and transmission of data needed for Secure Flight to operate
successfully. Accordingly, TSA will need to ensure that requirements for
each stakeholder are determined. For instance, TSA will need to define how
air carriers are to connect to CBP and what passenger data formats and
structures will be used. Although more remains to be done, TSA has worked
to communicate and coordinate requirements with stakeholders. For example,
TSA has maintained weekly communications with CBP and TSC regarding their
roles and responsibilities related to Secure Flight operations.

TSA has also begun to address air carriers' questions about forthcoming
Secure Flight requirements. For example, TSA Officials have produced draft
air carrier guidance, known as the Secure Flight Data Transmission Plan
Guidance (DTPG).23 The final DTPG is to include guidance to air carriers
addressing the following areas: Secure Flight's mission overview and
objectives, project planning phases, aircraft operator operations and
airport procedures, technical data requirements, aircraft operator
application development, Secure Flight operations, and system maintenance
and support. According to TSA officials, air carriers have received copies
of a partial draft DTPG, and some air carriers have submitted feedback to
Secure Flight's Airline Implementation and Operations Team that TSA says
it is working to address.

23The current draft of the DTPG also includes several appendices that
provide additional, detailed program information to airlines, including an
Interface Control Document containing detailed technical information such
as message content and screen layout, a high-level technical plan for
implementing various components of Secure Flight, detailed programming
specifications for message timing and instructions for various passenger
vetting scenarios, a recommendation that the airline industry develop an
industry standard method for communicating Full Name (FN) and Date of
Birth (DOB), and the system operational test plans.

In addition to drafting guidance, TSA has conducted preliminary network
connectivity testing between TSA and federal stakeholders. For example,
messages have been transmitted from CBP to TSA and back. However, such
tests included only dummy data. According to CBP officials, no real-time
passenger data have been used in this testing, and system stress testing
has not yet been conducted.24 Without real-time passenger data, the
official said, CBP cannot estimate total capacity or conduct stress
testing to ensure the system operates effectively. Further, according to a
TSC official, testing has been conducted to show that a data exchange
between the TSC and TSA is functioning, but the system has not been
stress-tested to determine if it can handle the volume of data traffic
that will be required to operate Secure Flight. According to this
official, TSA has not specified what these data volume requirements will
be. TSA officials acknowledged that they have not yet made this
determination and stated that they will not be able to do so until they
(1) issue the rule, and (2) have received the air carrier plans for
participating in Secure Flight based on requirements identified in the
rule.

Although CBP, TSC, and air carrier officials we interviewed acknowledged
TSA's outreach efforts, they cited several areas where additional
information was needed from TSA before they could fully support Secure
Flight. Several CBP officials stated, for example, that they cannot
proceed with establishing connectivity with all air carriers until DHS
publishes the rule-the regulation that will specify what type of
information is to be provided for Secure Flight-and the air carriers
provide their plans for providing this information. Similarly, a TSC
official stated that TSC cannot make key decisions on how to support
Secure Flight until TSA provides estimates of the volume of potential name
matches that TSC will be required to screen, as identified above. The TSC
official stated that without this information, TSC cannot make decisions
about required resources, such as personnel needed to operate its call
center.25 As we reported in March 2005, air carriers also expressed
concerns regarding the uncertainty of the Secure Flight system and data
requirements, and the impact these requirements may have on the airline
industry and traveling public. Air carriers will not be able to begin to
modify their passenger data systems to record the data attributes-such as
full name and date of birth, which Secure Flight will use to conduct name
matching-until TSA determines and communicates which specific data
attributes are to be used.

24Stress testing refers to measuring a system's performance and
availability in times of particularly heavy (i.e., peak) load.

25According to the DOJ-OIG, when Secure Flight becomes operational, TSC
anticipates a significantly greater operational workload as a result of
the program and an increased need for staff, space, and funding.

Oversight groups that have reviewed Secure Flight agreed that additional
work was needed to improve the flow of information to, and coordination
with, program stakeholders. In its December 2005 report on Secure Flight,
the DHS Data Privacy and Integrity Advisory Committee stated that TSA
needs to be clear with air carriers about what information it needs now
and what information it may consider requesting in the future, to enable
air carriers to avoid sequential revisions of data-handling systems. Also,
in September 2005, the Aviation Security Advisory Committee working group
expressed concerns about the lack of clarity regarding how Secure Flight
will interact with other screening programs.

Further, in its August 2005 audit of TSC's support of Secure Flight, the
DOJ-OIG reported that TSC officials believed that their ability to prepare
for the implementation of Secure Flight has been hampered by TSA's failure
to make, communicate, and comply with key program and policy decisions in
a timely manner, such as the launch date and volume of screening to be
conducted during initial implementation. In addition, the report noted
that because TSA is unsure about how many air carriers will participate in
the initial phase of the program, neither TSA nor TSC can know how many
passenger records will be screened, and cannot project the number of watch
list hits that will be forwarded to the TSC for action. Finally, the
DOJ-OIG report concluded that the shifting of critical
milestones-including TSA's schedule slippages over the past year-has
affected TSC's ability to adequately plan for its role in Secure Flight.

Despite TSA's outreach efforts, stakeholder participation in Secure Flight
is dependent on TSA's effort to complete its definition of requirements
and describe these in the rule. Because TSA has not fully defined system
requirements, key stakeholders have not been able to fully plan for or
make needed adjustments to their systems. In our March 2005 report, we
recommended that TSA develop a plan for establishing connectivity among
the air carriers, CBP, and TSC to help ensure the secure, effective, and
timely transmission of data for use in Secure Flight operations. Although
TSA has continued to coordinate with these key stakeholders, at present
the agency has still not completed the plans and agreements necessary to
ensure the effective support of Secure Flight.

Ongoing Coordination of Prescreening and

Name-Matching Initiatives Can Impact How Secure Flight Is Implemented

In January 2006, TSA officials stated that they are in the early stages of
coordinating with CBP on broader issues of integration and
interoperability related to other people-screening programs. These broader
coordination efforts, which are focused on minimizing duplicative efforts
that may exist between the agencies that screen individuals using watch
list data and achieving synergies and efficiencies, are important because
they may affect how Secure Flight will operate initially and in the
future. Specifically, TSA Officials stated that they are coordinating more
closely with CBP's international prescreening initiatives for passengers
on flights bound for the United States. The Air Transport Association and
the Association of European Airlines-organizations representing air
carriers-had requested, among other things, that both domestic and
international prescreening function through coordinated information
connections and avoid unnecessary duplication of communications,
programming, and information requirements.26

In response to air carrier concerns, and the initiatives of DHS to
minimize duplicative efforts, officials from both CBP and TSA explained
that they are beginning to work together to ensure that air carriers have
a single interface with the government for prescreening both domestic and
international passengers. TSA and CBP officials further stated that they
will try to use CBP's network to transmit domestic and international
passenger data to and from the air carriers, thus providing the air
carriers with a single interface for sending and receiving information.27
TSA and CBP officials also stated that air carriers should receive a
common notification about whether a passenger-domestic or
international-requires normal processing, additional screening, or is not
permitted to board a plane. However, according to these officials, TSA and
CBP have not yet resolved other system differences-such as the fact that
their prescreening systems use different passenger data elements,
documentation,28 and name matching technologies-that could lead to
conflicting notifications that would instruct air carriers to handle a
passenger differently for an international than for a domestic flight.
Both TSA and CBP officials agreed that additional coordination efforts are
needed to resolve these differences, and stated that they plan to work
closely together in developing a prescreening capability for both domestic
and international passengers.29 Decisions made as a result of further
coordination could result in changes to the way that Secure Flight is
implemented.

26Correspondence to the Honorable Michael Chertoff, Secretary, Department
of Homeland Security, October 27, 2005.

27CBP and TSA officials stated they will use this same network to transmit
data for their respective international and domestic prescreening efforts.
Different addresses on the passenger information will ensure that TSA and
CBP data are routed to the appropriate handling agencies for screening.

28For international prescreening, name-matching is conducted using data
elements from a passport, whereas passports are not required for domestic
flights.

In addition to coordinating with CBP on international prescreening, TSA
faces additional coordination challenges working with TSC. Specifically,
according to TSC officials, TSC has an initiative under way to, among
other things, better safeguard watch list data. Currently, TSC exports
watch list data to other federal agencies, such as TSA and the State
Department, for use in these agencies' screening efforts or processes for
examining documents and records related to terrorism. However, TSC is
currently developing a new system whereby watch list data would not be
exported, but rather would be maintained by TSC. This system, called
Query, is to serve as a common shared service that will allow agencies to
directly search the TSDB using TSC's name matching technology for their
own purposes. TSC has conducted limited testing of the system. If TSC
chooses to use Query, TSA will be required to modify the system
architecture for Secure Flight in order to accommodate the new system.
According to a TSC official, this effort could be costly. While TSA
acknowledged in its draft concept of operations plan in June 2005 that
Secure Flight would need to be modified to accommodate TSC's Query "as
necessary," the agency has not made adjustments to its system requirements
or conducted a cost analysis of expected impacts on the Secure Flight
program. Rather, TSA has decided that it will continue developing the
Secure Flight application, which includes TSA's name-matching
technologies. Thus, TSC will need to export watch list data to TSA to
support Secure Flight, once it becomes operational.

29We currently have an on-going review of CBP's international prescreening
process, including assessing the current process for conducting
international passenger prescreening and reviewing the benefits and
challenges of implementing additional or enhanced international
prescreening strategies.

Key Factors That Will Influence the Effectiveness of Secure Flight Have Not Been
                             Finalized or Resolved

Several activities are under way, or are to be decided, that will affect
Secure Flight's effectiveness, including how operational testing is
conducted, and how data requirements and data accuracy are determined. TSA
has been testing and evaluating name-matching technologies for determining
what type of passenger data will be needed to match against the TSDB.
These tests have been conducted thus far in a controlled, rather than
real-world environment, using historical data, and additional testing is
needed. In addition, TSA has not made key decisions regarding how the
name-matching technologies to be used by Secure Flight will operate or
which data will be used to conduct name matching. While TSA is not
responsible for ensuring the accuracy of passenger data, the agency must
nonetheless advise stakeholders on data accuracy and quality requirements.
Another factor that could impact the effectiveness of Secure Flight in
identifying known or suspected terrorists is the system's inability to
identify passengers who assume the identity of another individual by
committing identity theft, or passengers who use false identifying
information. Secure Flight is neither intended to nor designed to address
these vulnerabilities.

Tests of Name-Matching Capability Are Under Way, but Full System Testing Has Not
Yet Been Conducted

TSA has tested-and continues to test-the effectiveness of one aspect of
the Secure Flight system, namely name-matching technologies. These
name-matching tests will help TSA determine what passenger data will be
needed for the system to match most effectively passenger records with
information contained in the TSDB. These tests are critical to defining
data requirements and making decisions about how to configure the
name-matching technologies. Additional tests will need to be conducted in
an operational, real-world environment to fully understand how to
configure the system effectively. This is because the name-matching tests
conducted to date were conducted in a controlled, rather than real-world,
environment-that is, under controlled, or simulated, conditions. For
example, TSA used historic air carrier passenger data from June 2004 and
historic and simulated watch list data to test the functionality and
effectiveness of Secure Flight's name-matching technologies that match air
carrier passenger records with potential terrorists in the TSDB.

Additional testing beyond name-matching also needs to be conducted, after
TSA rebaselines its program, defines system requirements, and begins
adhering to its SDLC. For example, stress and operational testing30 would
help determine whether Secure Flight can process the volume of data
expected and operate as intended in an operational environment. As we
reported in March 2005, TSA had planned to conduct a series of operational
tests consisting of increasingly larger increments of the system's
functionality until the complete system was tested. These tests were to
begin in June 2005. However, due to program delays, TSA has not yet
conducted this end-to-end testing needed to verify that the entire system,
including any interfaces with external systems, functions as intended in
an operational environment. TSA also has not yet conducted the stress
testing needed to measure the system's performance and availability in
times of particularly heavy (i.e., peak) loads. Recently, TSA documented
its overall strategy for conducting these tests and developed draft test
plans. TSA officials stated that information about its plans for future
testing will be included in its rebaselined program plan. Until this
testing is complete, it will not be possible to determine whether Secure
Flight will function as intended in an operational environment.

Key Policy Decisions That Will Impact System Effectiveness Have Not Been Made

Key policy decisions that will influence the effectiveness of Secure
Flight in identifying passengers who should undergo additional security
scrutiny have not yet been made. These policy decisions include (1)
determining the passenger information that air carriers will be required
to collect and provide for vetting, (2) the name-matching technologies
that will be used to vet passenger data against data contained in the
TSDB, and (3) the thresholds that will be set to determine when a
passenger will be identified as a potential match against the TSDB. These
three decisions, discussed below, are all critical to ensuring that Secure
Flight identifies potential terrorist threats as effectively as possible
while minimizing the number of potential matches that will require further
review by TSA and TSC analysts.

(1) Determining the passenger information that air carriers will be
required to collect and provide for vetting: TSA needs to decide which
data attributes air carriers will be required to provide in passenger data
to be used to match against data contained in the TSDB, such as full
first, middle, and last name plus other discrete identifiers, such as date
of birth. Using too many data attributes can increase the difficulty of
matching, since the risk of errors or mismatches increases. Using too few
attributes can create an unnecessarily high number of incorrect matches
due to, among other things, the difficulty of differentiating among
similar common names without using further information. Initial TSA test
results have shown that the use of name and date of birth alone might not
be sufficient for decreasing the number of false positives-that is,
passengers inappropriately matched against data contained in the TSDB.

30Whereas stress testing is used to determine the maximum capacity of the
system, operational testing is used to ensure that the system operates as
intended, including the people and the information technology systems
operating together in their expected environments.

(2) Selecting name-matching technologies used to vet passenger names
against the TSDB: TSA must determine what type or combination of
name-matching technologies to acquire and implement for Secure Flight, as
these different technologies have different capabilities. For example,
TSA's PNR testing showed that some name-matching technologies are more
capable than others at detecting significant name modifications, which
allows for the matching of two names that contain some variation.
Detecting variation is important because passengers may intentionally make
alterations to their names in an attempt to conceal their identity. Also,
unintentional variations can result from different translations of
nonnative names or data entry errors. For example, some name-matching
technologies might correctly discriminate between "John Smith" and "John
Smythe," others may not. However, name matching technologies that are best
at detecting name variations may also increase the number of potential
matches that will have to be further reviewed, which could be offset using
a combination of name matching technologies. TSA officials stated in
November 2005 that it planned to continuously evaluate the best
name-matching technologies or combination of technologies to enhance the
system in future iterations. TSA officials recently stated that they had
made, but not yet documented, an initial determination regarding the
name-matching technologies that will be used for Secure Flight and that
they plan to conduct continuous reviews of the name-matching technologies
to address circumstances as they arise.

(3) Selecting thresholds for determining when a possible name match has
occurred: TSA has discretion to determine what constitutes a possible
match between a passenger's data and a TSDB record.31 For each name that
is matched, the name-matching tool will assign a numeric score that
indicates the strength of the potential match.32 For example, a score of
95 out of 100 would indicate a more likely match than a score of 85. If
TSA were to set the threshold too high, many names may be cleared and
relatively few flagged as possible matches-that is, there is a possibility
that terrorists' names may not be matched. Conversely, if the threshold
were set too low, passengers may be flagged unnecessarily, and relatively
few cleared through the automated process. As an example of the importance
of setting thresholds, during one of the PNR tests conducted, TSA set the
name-matching threshold at 80, which resulted in over 60 percent of
passengers requiring manual review. Alternatively, when TSA set the
threshold at 95, less than 5 percent of the same group of passenger
records were identified as requiring further review. With about 1.8
million passengers traveling domestically per day, having a threshold that
is too low could produce an unmanageable number of matches-possibly
leading to passenger delays-while setting the threshold too high could
result in the system missing potential terrorists. Although TSA will not
decide how the thresholds should be set until it conducts additional
evaluations, it has indicated that the threshold might be adjusted to
reflect changes in the terrorist threat level. This would result in Secure
Flight flagging more names for potential manual review in order to ensure
greater scrutiny in response to changing conditions.

31The name matching process depends on the level of false positive and
false negative matches deemed acceptable. False negatives are passengers
incorrectly not matched to a watch list.

TSA plans to finalize decisions on these factors as system development
progresses. However, until these decisions are made, requirements will
remain unsettled and key stakeholders-in particular air carriers-will not
have the information they need to assess and plan for changes to their
systems necessary for interfacing with Secure Flight. Air carriers and
reservation companies will also not know which additional data attributes
they may be required to collect from passengers, to support Secure Flight
operations, as reservations are made. These decisions will also directly
influence the number of analysts that TSA and TSC will need to manually
review potential matches to the TSDB. Accordingly, stakeholders have
expressed concern that they have not been provided information about what
these decisions are. They stated that they are awaiting additional
information from TSA in order to move forward with their plans to
interface with and support Secure Flight.

32The score is based, in part, on how much weight is given to, say, name
or date of birth relative to each other.

Efforts to Improve Data Quality and Accuracy Are Under Way, but Additional Work
Remains

Two additional factors that will impact the effectiveness of Secure Flight
are (1) the accuracy and completeness of data contained in TSC's TSDB and
in passenger data submitted by air carriers, and (2) the ability of TSA
and TSC to identify false positives and resolve possible mistakes during
the data matching process, in order to minimize inconveniencing
passengers. According to TSA and TSC officials, the data attributes that
Secure Flight will require for name matching need to be included in both
the passenger data and the TSDB in order for the automated system to
effectively match names between the two lists. As we reported in March
2005, while the completeness and accuracy of data contained in the TSDB
can never be certain-given the varying quality of intelligence information
gathered, and changes in this information over time-TSC has established
some processes to help ensure the quality of these data. However, the
DOJ-OIG, in its June 2005 review of TSC,33 found that that the TSC could
not ensure that the information contained in its databases was complete or
accurate.34 According to a TSC official, since the time of the DOJ-OIG
review, TSC has taken several steps to improve the quality of TSDB
records, including conducting a record-by-record review, updating
procedures for a daily review of each new or modified record, and using
automated rules to check the completeness of records received from other
agencies.35 According to this official, TSA and TSC plan to enter into a
letter of agreement that will describe the TSDB data elements that TSC
will produce for TSA, among other things, to be used for Secure Flight.
However, these data requirements have not yet been determined.

In order to obtain accurate and complete passenger data from air carriers,
TSA plans to describe the required data attributes that must be contained
in passenger data provided to TSA in the forthcoming rule. TSA also plans
to issue a final and complete DTPG to specify the data formats and other
transmission requirements. However, the accuracy and completeness of the
information contained in the passenger data record will still be dependent
on the air carriers' reservations systems and passengers, and the air
carriers' modifications of their systems for transmitting the data in the
proper format. These steps are not trivial, as indicated by the June 2004
historical passenger data provided by the air carriers for TSA's
name-matching tests. For these tests, many passenger data records
submitted by air carriers were found to be inaccurate or incomplete,
creating problems during the automated name-matching process. For example,
some passenger data included invalid characters or prefixes, such as "Mr."
and "Mrs.," in the name fields. Other inaccuracies included invalid
characters or prefixes, spelling errors, and inverted birth date
information. Additionally, some of the records had omitted or incomplete
data elements necessary for performing the automated match or were in an
unusable format.

33Department of Justice Office of the Inspector General, Review of the
Terrorist Screening Center, June 2005. According to the DOJ Office of the
Inspector General's report, some errors in the TSDB might be corrected by
a manual review conducted by intelligence analysts and a redress process.

34We have an ongoing review of the reasons misidentifications occur using
TSDB data, and the efforts by the TSC and other agencies to reduce these
errors.

35Department of Justice Office of the Inspector General, Review of the
Terrorist Screening Center's Efforts to Support the Secure Flight Program,
August 2005.

In a related effort to address accuracy, TSA and TSC plan to work together
to identify false positives as passenger data are matched against data in
the TSDB and to resolve mistakes to the extent possible before
inconveniencing passengers. The agencies will use intelligence analysts
during the actual matching of passenger data to data contained in the TSDB
to increase the accuracy of data matches. As indicated in figure 1, when
TSA's name-matching technologies indicate a possible match, TSA analysts
are to manually review all of the passenger data and other information to
determine if the passenger can be ruled out as a match to the TSDB. If a
TSA analyst cannot rule out a possible match, the record will be forwarded
to a TSC analyst to conduct a further review using additional information.
According to a TSC official, TSA and TSC analysts participated in a
tabletop exercises to test the consistency of their respective manual
reviews, and found that the matching logic used by both groups of analysts
was consistent. This official stated that TSA and TSC also tested their
operational procedures, and found gaps in their procedures that are now
being addressed. According to this official, TSA and TSC plan to conduct
additional joint exercises. Completing these exercises will be important
to further understanding the effectiveness of using intelligence analysts
to clear misidentified passengers during Secure Flight operations.

False Identifying Information and Identity Theft Could Impact the Security
Benefits of Secure Flight

Another factor that could affect Secure Flight's effectiveness in
identifying known or suspected terrorists is the system's inability to
identify passengers who falsify their identifying information or who
commit identity theft.36 TSA Officials stated that the program is not
intended to or designed to protect against the use of falsified identities
or to detect identity theft. However, TSA officials stated that the use of
commercial data during the name-matching process may help identify
situations in which a passenger submits fictitious information such as a
false address. In the spring of 2005, a TSA contractor tested the use of
commercial data composed of personally identifiable information (such as
name and address) to determine, among other things, if such data could be
used to increase Secure Flight's effectiveness in identifying false or
stolen identities. However, according to the DHS Data Privacy and
Integrity Advisory Committee report, testing performed to date does not
provide a reasonable case for utilizing commercial data as part of Secure
Flight. TSA officials are not currently pursuing the use of commercial
data to support Secure Flight because the fiscal year 2006 DHS
appropriations act prohibits TSA from using data or databases obtained
from or that remain under the control of a non-federal entity,37
effectively terminating this type of testing for the duration of fiscal
year 2006.38 Further, TSA officials stated that incorporating
biometrics-technologies that can automate the identification of people by
one or more of their distinct physical or behavioral characteristics-is
not currently envisioned for Secure Flight. As noted in our previous work,
biometric technologies, such as fingerprint recognition, are being used in
other TSA screening programs.39 Moreover, the current prescreening process
of matching passenger names against no-fly and selectee lists implemented
by air carriers also does not protect against identity theft or the use of
fictitious identities.

36Falsifying identifying information involves passenger attempted to hide
their true identities by submitting fictitious identifying information,
such as false addresses, when purchasing tickets. Identity theft would
involve a passenger "stealing" another person's identifying information,
such as name and date of birth, and then using that identifying
information to create fraudulent documents associated with the identity
(such as a driver's license containing the stolen identifiers with the
thief's picture). This is sometimes referred to as identity fraud.

37The Department of Homeland Security Appropriations Act, 2006, Pub. L.
No. 109-90, S: 518 (e), 119 Stat. 2064, 2085 (2005).

38This prohibition on the use of appropriated funds does not apply to
passenger name record data obtained from air carriers.

39GAO, Aviation Security: Challenges in Using Biometric Technologies,
GAO-04-785T (Washington, D.C.: May 19, 2004).

Secure Flight Privacy Notices and Passenger Redress Process Cannot Be Finalized
               Until Program Requirements Are More Fully Defined

TSA is aware of, and plans to address, the potential for Secure Flight to
adversely affect travelers' privacy and impact their rights. However, TSA,
as part of its requirements development process, has not yet clearly
identified the privacy impacts of the planned system or the full actions
it plans to take to mitigate them. Nor has the agency completed its
assessment of the potential impact on passenger privacy of the system in
an operational environment or defined its redress process for Secure
Flight because, in part, the operational plans and system requirements for
Secure Flight have not been finalized. TSA officials stated that they are
in the process of reviewing new privacy notices that will be issued in
conjunction with a forthcoming rule making prior to proceeding with its
initial operating capability, and that these notices will also address
certain aspects of Secure Flight's redress process. Until TSA finalizes
system requirements and notices, however, privacy protections and impacts
cannot be assessed.

Privacy Cannot Be Fully Assessed Because System Development Documentation Does
Not Fully Address Privacy Requirements

The Privacy Act and the Fair Information Practices-a set of
internationally recognized privacy principles that underlie the Privacy
Act-limit the collection, use, and disclosure of personal information by
federal agencies.40 While TSA has reiterated its commitment to meet the
requirements of the Privacy Act and the Fair Information Practices, it is
not yet evident how this will be accomplished. 41 To begin with, TSA has
not decided what data attributes from the PNR it plans to collect, or how
such data will be provided by airlines, through CBP, to TSA. Further,
according to TSA officials, the agency is in the process of developing but
has not issued the system of records notice, which is required by the
Privacy Act,42 or the privacy impact assessment, which is required by the
E-Government Act,43 that would describe how TSA considered privacy in the
development of the system and how it will protect passenger data once the
system becomes operational.

40Privacy Act of 1974, Pub. L. No. 93-579, 88 Stat. 1896 (codified as
amended at 5 U.S.C. S: 552a).

41Also, in its mandate regarding Secure Flight, Congress asked that GAO
review whether there are any specific privacy concerns with the
technological architecture of the Secure Flight system.

42The Privacy Act requires that an agency publish a system of records
notice in the Federal Register upon establishment or revision of the
existence and character of any system of records. See S: 552a(e)(4).

43The E-Government Act of 2002 requires agencies to conduct a privacy
impact assessment before developing systems that collect, maintain, or
disseminate information in an identifiable form. Pub. L. No. 107-347, 116
Stat. 2899.

Moreover, privacy requirements were not incorporated into the Secure
Flight system development process in such a way that would explain whether
personal information will be collected and maintained in the system in a
manner that complies with statutory requirements and TSA's SDLC guidance.
One requirement of the privacy impact assessment is that privacy be
addressed in the systems development documentation. In addition, TSA's
SDLC guidance acknowledges that privacy protections should be planned for
and carried out as part of the system development process. In our review
of Secure Flight's system requirements, we found that privacy concerns
were broadly addressed in Secure Flight's functional requirements, but had
not been translated into specific system requirements. For example, the
functional requirements stated that the Privacy Act must be considered in
the development of the system, but the system requirements documents do
not reflect how privacy protections will be supported by the system.
Rather, system requirements documents state that privacy requirements are
"yet to be finalized." TSA's Privacy Officer stated that she has been
collaborating with the system development team, but this is not evident in
the documents we reviewed.

Without taking steps to ensure that privacy protections are built into the
system requirements, TSA cannot be assured that it will be in compliance
with the Privacy Act once operational, and it runs the risk of repeating
problems it experienced last spring. We reported in July 2005 that TSA's
initially issued privacy notices for the Secure Flight data-processing
tests did not meet Privacy Act requirements because personal information
was used in testing in ways that the agency had not disclosed to the
public.44 We explained that in its fall 2004 notices, TSA had informed the
public of its plans to use personal information during Secure Flight
testing, including the use of commercial data in a limited manner.
However, these initial notices did not fully describe how personal
information would be collected, used, and stored for commercial data
testing as it was carried out. As a result, individuals were not fully
informed that their personal information was being collected and used, nor
did they have the opportunity to comment on this or become informed on how
they might exercise their rights of access to their information. Although
TSA did not fully disclose its use of personal information prior to
beginning Secure Flight commercial data testing, the agency issued revised
privacy notices in June 2005 to more fully disclose the nature of the
commercial tests and address the issues disclosed by us.

44GAO, Aviation Security: Transportation Security Administration Did Not
Fully Disclose Uses of Personal Information during Secure Flight Program
Testing in Initial Privacy Notices, but Has Recently Taken Steps to More
Fully Inform the Public, GAO-05-864R (Washington, D.C.: July 22, 2005).

As we reported in March 2005, until TSA fully defines its operational
plans for Secure Flight and addresses international privacy concerns, it
will remain difficult to determine whether the planned system will offer
reasonable privacy protections to passengers who are subject to
prescreening or mitigate potential impacts on passengers' privacy. At that
time, we recommended that TSA finalize privacy policies and issue
associated documentation prior to Secure Flight achieving initial
operating capability. TSA acknowledged that it needs to publish new
privacy notices to cover the collection, use, and storage of personal data
for Secure Flight's initial and full operating capability, before
beginning operational testing. TSA officials stated that these privacy
notices are currently being reviewed by TSA and DHS and will be released
in conjunction with the forthcoming rulemaking.

TSA Has Not Determined Secure Flight's Redress Process

Congress mandates that Secure Flight include a process whereby aviation
passengers determined to pose a threat to aviation security may appeal
that determination and correct erroneous information contained within the
prescreening system.45 TSA currently has a process in place that allows
passengers who experience delays, under the current process run by air
carriers, to submit a passenger identity verification form to TSA and
request that the agency place their names on a cleared list. If, upon
review, TSA determines that the passenger's identity is distinct from the
person on a watch list, TSA will add the passenger's name to its cleared
list, and will forward the updated list to the air carriers. TSA will also
notify the passenger of his or her cleared status and explain that in the
future the passenger may still experience delays.46 Recently, TSA has
automated the cleared list process, enabling the agency to further
mitigate inconvenience to travelers on the cleared list.

45See  Pub. L. Nos. 108-334, S: 522(a)(1); and 109-90, S: 518(a).

46TSA's Office of Transportation Security Redress manages redress for the
current watch list matching process conducted by the air carriers.
Currently OTSR is developing an agency-wide policy for redress and has
interviewed TSA Officials as part of this effort, but found that Secure
Flight requirements were not sufficiently defined for use in drafting the
new policy. TSA officials stated that they are continuing to discuss the
Secure Flight redress process with OSTR.

The Intelligence Reform and Terrorism Prevention Act, enacted in December
2004, directs TSA to include certain elements in its Secure Flight redress
policy.47 Specifically, it requires the establishment of a timely and fair
process for individuals identified as a threat to appeal the determination
to TSA and correct any erroneous information.48 It further requires that
TSA establish a method for maintaining a record of air passengers who have
been misidentified and have corrected erroneous information. To prevent
repeated delays of misidentified passengers, this record must contain
information determined by TSA to authenticate the identity of such a
passenger. In January 2006, TSA officials stated that no final decisions
have been made regarding how TSA will address the relevant requirements
for redress found in the Intelligence Reform and Terrorism Prevention Act
requirements. However, OTSR officials stated that a cleared list will be
part of the process. The June 2005 concept of operations describes a
process where individuals that are frequently misidentified as being on
the TSDB and TSA selectee list can request to be placed on a list of
individuals who have been cleared.

In our March 2005 report, we recommended that TSA finalize its Secure
Flight redress policies and procedures prior to achieving its initial
operating capability. Information concerning aspects of the redress
process will be published before operational tests or full implementation
of the Secure Flight process, and will be contained within the privacy
notices that TSA officials stated will be released in conjunction with the
forthcoming rulemaking. Moving forward, TSA has assigned a manager to
serve as liaison with DHS on privacy and redress issues.

47See  Pub. L. No. 108-458, S: 4012(a) (codified at 49 U.S.C. S:
44903(j)(2)(C), (G)).

48This requirement generally addresses principles from both the Privacy
Act-that individuals be able to access and correct their personal
information-and the Fair Information Practice of individual
participation-that individuals be able to know about the collection of
personal information, to access that information, to request correction,
and to challenge the denial of such requests. However, Secure Flight's
redress system will be challenging for two significant reasons. First,
much of the information underlying decisions to add individuals to the
TSDB is likely to be classified, and as such will not be accessible to
passengers. Second, TSA does not control the content of the TSDB that it
intends to use as the primary input in making screening decisions.

                            Concluding Observations

TSA has continued its development and testing of Secure Flight, but has
made limited progress in addressing longstanding issues related to system
development and testing, program management, and privacy and redress
protections. To make and demonstrate progress on any large-scale
information technology program, such as Secure Flight, an agency must
first adequately define what program capabilities, such as requirements
related to performance, security, privacy, and data content and accuracy,
are to be provided. These requirements can then in turn be used to produce
reliable estimates of what these capabilities will cost, when they will be
delivered, and what mission value or benefits will accrue as a result. For
Secure Flight, well-defined requirements would provide a guide for
developing the system and a baseline to test the developed system to
ensure that it delivers necessary capabilities, and would help to ensure
that key program areas-such as security, system connectivity, and privacy
and redress protections-are appropriately managed.

When we reported on Secure Flight in March 2005, TSA had committed to take
action on our recommendations to manage the risks associated with
developing and implementing Secure Flight, including finalizing the
concept of operations, system requirements and test plans; completing
formal agreements with CBP and air carriers to obtain passenger data;
developing life cycle cost estimates and a comprehensive set of critical
performance measures; issuing new privacy notices; and putting a redress
process in place. Over the past 11 months, TSA has made some progress on
all of these areas, including conducting further testing of factors that
could influence system effectiveness and corroborating with key
stakeholders. However, TSA has not completed any of the actions it had
scheduled to accomplish. In particular, TSA has not yet developed complete
system requirements or conducted important system testing (including
stress testing), fully established security measures, made key decisions
that will determine system effectiveness, developed a program management
plan and a schedule for accomplishing program goals, or published updated
privacy and redress notices. Taken as a whole, this lack of progress
indicates that the program has not been effectively managed and is at risk
of failure.

While we recognize that TSA faces program uncertainties that can directly
impact Secure Flight's development and progress, uncertainty is a
component of most programs, and should not be used as a reason for not
defining requirements and developing plans and cost estimates, to manage
risk. We believe that Secure Flight, like all programs, can utilize best
practices to develop such plans to manage program uncertainties.

To its credit, TSA has recently taken actions that recognize the need to
instill more rigor and discipline into the development and management of
Secure Flight, including hiring a program manager with information systems
program management credentials. We also support TSA's efforts to
rebaseline the program, including defining system requirements and
finalizing a program management plan, including the development of
schedules and cost estimates, before proceeding with program development.
In fact, proceeding with operational testing and completing other key
program activities should not be pursued until TSA puts in place a more
disciplined life cycle process and defines system requirements. In the
absence of this and other program information, such as requirements,
capabilities, and benefits, further investment in this program would be
difficult to justify.

We are also encouraged that DHS's IRB-the executive decision making
authorities-has scheduled a review of Secure Flight and other
people-screening programs. Given the potential duplication with CBP's new
initiatives for international prescreening, DHS, TSA, and CBP need to
assess alternative system solutions that should be factored into Secure
Flight's rebaselined program and be the basis for IRB decisions regarding
Secure Flight's future. Notwithstanding these efforts, however, much work
remains to be accomplished before Secure Flight is positioned to be
properly executed so that informed and prudent investment decisions can be
made.

Mr. Chairman, this concludes my prepared statement. I will be pleased to
respond to any questions that you or other members of the committee have
at the appropriate time.

                     GAO Contacts and Staff Acknowledgments

For further information about this testimony, please contact Cathleen
Berrick, at 202-512-3404 or at [email protected] , or Randolph C. Hite at
202-512-6256 or at [email protected].

Other key contributors to this statement were David Alexander, Amy
Bernstein, Mona Nichols Blake, John de Ferrari, Christine Fossett, Brent
Helt, Richard Hung, Thomas Lombardi, C. James Madar, Matthew Mohning,
David Plocher, Karl Seifert, and William Wadsworth.

Appendix I: Legislatively Mandated Secure Flight Issues to be Certified by
DHS and Reviewed by GAO

Legislative mandated issue                                                 
(number and short title)       Description of mandated issue
      1. Redress process          A system of due process exists whereby      
                                  aviation passengers determined to pose a    
                                  threat are either delayed or prohibited     
                                  from boarding their scheduled flights by    
                                  TSA may appeal such decisions and correct   
                                  erroneous information contained in CAPPS II 
                                  or Secure Flight or other                   
                                  follow-on/successor programs.               
      2. Accuracy of databases    The underlying error rate of the government 
      and effectiveness of Secure and private databases that will be used to  
      Flight                      both establish identity and assign a risk   
                                  level to a passenger will not produce a     
                                  large number of false positives that will   
                                  result in a significant number of           
                                  passengers being treated mistakenly or      
                                  security resources being diverted.          
      3. Stress testing           TSA has stress-tested and demonstrated the  
                                  efficacy and accuracy of all search         
                                  technologies in CAPPS II or Secure Flight   
                                  or other follow-on/successor programs and   
                                  has demonstrated that CAPPS II or Secure    
                                  Flight or other follow-on/successor         
                                  programs can make an accurate predictive    
                                  assessment of those passengers who may      
                                  constitute a threat to aviation.            
      4. Internal oversight       The Secretary of Homeland Security has      
                                  established an internal oversight board to  
                                  monitor the manner in which CAPPS II or     
                                  Secure Flight or other follow-on/successor  
                                  programs are being developed and prepared.  
      5. Operational safeguards   TSA has built in sufficient operational     
                                  safeguards to reduce the opportunities for  
                                  abuse.                                      
      6. Security measures        Substantial security measures are in place  
                                  to protect CAPPS II or Secure Flight or     
                                  other follow-on/successor programs from     
                                  unauthorized access by hackers or other     
                                  intruders.                                  
      7. Oversight of system use  TSA has adopted policies establishing       
      and operation               effective oversight of the use and          
                                  operation of the system.                    
      8. Privacy concerns         There are no specific privacy concerns with 
                                  the technological architecture of the       
                                  system.                                     
      9. Modifications with       TSA has, in accordance with the             
      respect to intrastate       requirements of section 44903 (j)(2)(B) of  
      travel to accommodate       title 49, United States Code, modified      
      states with unique air      CAPPS II or Secure Flight or other          
      transportation needs        follow-on/successor programs with respect   
                                  to intrastate transportation to accommodate 
                                  states with unique air transportation needs 
                                  and passengers who might otherwise          
                                  regularly trigger primary selectee status.  
      10. Life-cycle cost         Appropriate life-cycle cost estimates, and  
      estimates and expenditure   expenditure and program plans exist.        
      plans                       

Source: GAO.

(440422)

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Highlights of GAO-06-374T a report to the Committee on Commerce, Science,
and Transportation, U.S. Senate

February 9, 2006

AVIATION SECURITY

Significant Management Challenges May Adversely Affect Implementation of
the Transportation Security Administration's Secure Flight Program

After the events of September 11, 2001, Congress created the
Transportation Security Administration (TSA) and directed it to assume the
function of passenger prescreening-or the matching of passenger
information against terrorist watch lists to identify persons who should
undergo additional security scrutiny-for domestic flights, which is
currently performed by the air carriers. To do so, TSA is developing
Secure Flight. This testimony covers TSA's progress and challenges in (1)
developing, managing, and overseeing Secure Flight; (2) coordinating with
key stakeholders critical to program operations; (3) addressing key
factors that will impact system effectiveness; and (4) minimizing impacts
on passenger privacy and protecting passenger rights. This testimony
includes information on areas of congressional interest that GAO has
previously reported on.

What GAO Recommends

In a prior report, GAO recommended that the Department of Homeland
Security (DHS) direct TSA to take several actions to manage risks
associated with Secure Flight's development, including finalizing system
requirements and test plans, privacy and redress requirements, and program
cost estimates; and establishing plans to obtain data needed to operate
the system. DHS generally concurred with GAO's recommendations, but has
not yet completed the actions it plans to take.

TSA has made some progress in developing and testing the Secure Flight
program. However, TSA has not followed a disciplined life cycle approach
to manage systems development, or fully defined system requirements.
Rather, TSA has followed a rapid development method intended to develop
the program quickly. This process has been ad hoc, resulting in project
activities being conducted out of sequence, requirements not being fully
defined, and documentation containing contradictory information or
omissions. Further, while TSA has taken steps to implement an information
security management program for protecting information and assets, its
efforts are incomplete. Finally, TSA is proceeding to develop Secure
Flight without a program management plan containing program schedule and
cost estimates. Oversight reviews of the program have also raised
questions about program management. Without following a more rigorous and
disciplined life cycle process, including defining system requirements,
the Secure Flight program is at serious risk of not meeting program goals.

Over the past year, TSA has made some progress in managing risks
associated with developing Secure Flight, and has recently taken actions
that recognize the need to instill more rigor and discipline into the
development process. TSA has also taken steps to collaborate with Secure
Flight stakeholders whose participation is essential to ensuring that
passenger and terrorist watch list data are collected and transmitted to
support Secure Flight. However, key program stakeholders-including the
U.S. Customs and Border Protection, the Terrorist Screening Center, and
air carriers-stated that they need more definitive information about
system requirements from TSA to plan for their support of the program.

In addition, several activities that will affect Secure Flight's
effectiveness are under way, or have not yet been decided. For example,
TSA conducted name-matching tests, which compared passenger and terrorist
screening database data, to evaluate the ability of the system to
function. However, TSA has not yet made key policy decisions which could
significantly impact program operations, including what passenger data it
will require air carriers to provide and the name-matching technologies it
will use.

Further, Secure Flight's system development documentation does not fully
explain how passenger privacy protections are to be met, and TSA has not
issued the privacy notices that describe how it will protect passenger
data once Secure Flight becomes operational. As a result, it is not
possible to assess how TSA is addressing privacy concerns. TSA is also
determining how it will provide for redress, as mandated by Congress, to
provide aviation passengers with a process to appeal determinations made
by the program and correct erroneous information contained within the
prescreening process. However, TSA has not finalized its redress polices.
*** End of document. ***