Maritime Security: Federal Efforts Needed to Address Challenges  
in Preventing and Responding to Terrorist Attacks on Energy	 
Commodity Tankers (10-DEC-07, GAO-08-141).			 
                                                                 
U. S. energy needs rest heavily on ship-based imports. Tankers	 
bring 55 percent of the nation's crude oil supply, as well as	 
liquefied gases and refined products like jet fuel. This supply  
chain is potentially vulnerable in many places here and abroad,  
as borne out by several successful overseas attacks on ships and 
facilities. GAO's review addressed (1) the types of threats to	 
tankers and the potential consequences of a successful attack,	 
(2) measures taken to protect tankers and challenges federal	 
agencies face in making these actions effective, and (3) plans in
place for responding to a successful attack and potential	 
challenges stakeholders face in responding. GAO's review spanned 
several foreign and domestic ports, and multiple steps to analyze
data and gather opinions from agencies and stakeholders.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-141 					        
    ACCNO:   A78768						        
  TITLE:     Maritime Security: Federal Efforts Needed to Address     
Challenges in Preventing and Responding to Terrorist Attacks on  
Energy Commodity Tankers					 
     DATE:   12/10/2007 
  SUBJECT:   Crude oil						 
	     Disaster planning					 
	     Disaster recovery plans				 
	     Emergency management				 
	     Emergency preparedness				 
	     Emergency response 				 
	     Emergency response plans				 
	     Energy security					 
	     Energy supplies					 
	     Homeland security					 
	     Liquefied natural gas				 
	     Maritime security					 
	     Natural gas					 
	     Oil importing					 
	     Port security					 
	     Risk management					 
	     Tankers (Vessels)					 
	     Terrorism						 
	     Transportation security				 

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GAO-08-141

   

     * [1]Results in Brief
     * [2]Background

          * [3]Many Stakeholders Are Involved in Securing the Maritime Ener
          * [4]Tankers Transport Energy Commodities around the World
          * [5]Energy Commodities Originate in a Variety of Locations
          * [6]Key Domestic Ports Handle Vast Majority of Energy Imports
          * [7]Characteristics of Maritime Supply Chain Make It Vulnerable
          * [8]Addressing Tanker Security Vulnerabilities Involves Setting

     * [9]Energy Commodity Shipments Face Varied Threats, and a Succes

          * [10]No Credible Specific Threat of Attack at U.S. Ports to Date,

               * [11]Officials Are Concerned about Three Primary Types of
                 Threats
               * [12]Suicide Attacks
               * [13]Standoff Attacks
               * [14]Armed Assaults
               * [15]Other Types of Threats Are Considered Less Likely
               * [16]Intelligence Reviews Indicate Threats Are Likely to
                 Persist

          * [17]Possible Consequences of an Attack Include Public Safety, En

               * [18]Public Safety and Environmental Consequences Vary by
                 Commodi
               * [19]Blockage of Key Transit Routes, Key Facilities, or Ports
                 Cou
               * [20]Economic Consequences from the Psychological Market
                 Reaction

     * [21]Although Stakeholders Are Taking Protective Measures, Implem

          * [22]In Spite of the Widespread Adoption of the ISPS Code, the Pr

               * [23]U.S. Military Presence Overseas Aimed at Helping Deter
                 Marit
               * [24]State Department Officials Review Crew Member Visa
                 Applicati

          * [25]While Vessels Are in Transit, the Primary Challenge Involves
          * [26]In U.S. Waterways and Ports, the Primary Challenge Involves

               * [27]Security Requirements Vary by Commodity
               * [28]State and Local Law Enforcement Agencies Play a Major
                 Role i
               * [29]The Coast Guard Faces Challenges Meeting Internal
                 Security G
               * [30]The Coast Guard's Near-Term Efforts to Align
                 Requirements wi
               * [31]Additional LNG Facilities Set to Come On Line Will
                 Likely Po

     * [32]Stakeholders Have Developed Spill and Terrorism Response Pla

          * [33]Planning for Spill Response Is Largely Separate from Plannin
          * [34]Federal Agencies and Local Ports Could Face Challenges in In

               * [35]Federal Agencies and Ports Could Face Challenges in
                 Integrat
               * [36]Port Plans to Mitigate Economic Consequences Could Be
                 Useful
               * [37]Ports Could Face Challenges in Securing Resources to
                 Carry O
               * [38]Marine Firefighting Equipment and Training
               * [39]Other Training
               * [40]Interoperable Communications

          * [41]DHS Grants May Become More Accessible for Response and Recov

     * [42]Conclusions
     * [43]Recommendations for Executive Action
     * [44]Agency Comments

          * [45]Crude Oil
          * [46]Gasoline
          * [47]Jet Fuel
          * [48]LNG
          * [49]LPG

     * [50]GAO Contacts
     * [51]Staff Acknowledgments
     * [52]GAO's Mission
     * [53]Obtaining Copies of GAO Reports and Testimony

          * [54]Order by Mail or Phone

     * [55]To Report Fraud, Waste, and Abuse in Federal Programs
     * [56]Congressional Relations
     * [57]Public Affairs
     * [58]PDF6-Ordering Information.pdf

          * [59]GAO's Mission
          * [60]Obtaining Copies of GAO Reports and Testimony

               * [61]Order by Mail or Phone

          * [62]To Report Fraud, Waste, and Abuse in Federal Programs
          * [63]Congressional Relations
          * [64]Public Affairs

Report to Congressional Requesters

United States Government Accountability Office

GAO

December 2007

MARITIME SECURITY

Federal Efforts Needed to Address Challenges in Preventing and Responding
to Terrorist Attacks on Energy Commodity Tankers

GAO-08-141

Contents

Letter 1

Results in Brief 7
Background 11
Energy Commodity Shipments Face Varied Threats, and a Successful Attack
Could Have Substantial Consequences 23
Although Stakeholders Are Taking Protective Measures, Implementation
Challenges Pose Difficulty Both Abroad and at Home 36
Stakeholders Have Developed Spill and Terrorism Response Plans but Face
Several Challenges in Integrating Them 53
Conclusions 77
Recommendations for Executive Action 79
Agency Comments 80
Appendix I Objective, Scope, and Methodology 84
Appendix II Selected Energy Commodities Transported by Tanker into United
States 87
Appendix III Recent High-Profile Terrorism Incidents against Tankers and
Energy Infrastructure 89
Appendix IV Assessing and Managing Risks Using a Risk Management Approach
90
Appendix V Comments from the Department of Homeland Security 93
Appendix VI Comments from the Federal Bureau of Investigation 97
Appendix VII Comments from the Department of Defense 100
Appendix VIII GAO Contacts and Staff Acknowledgments 101
Related GAO Products 102

Tables

Table 1: Selected International Stakeholders with Maritime Security
Activities 12
Table 2: Selected Domestic Stakeholders with Maritime Security Activities
13
Table 3: Federal and Port-level Plans and Agreements Governing Response to
Spills on Water and Terrorist Attacks 56
Table 4: High-Profile Terrorism Incidents against Tankers and Energy
Infrastructure by Target and Attack Method since 2002 89

Figures

Figure 1: Oil Tanker at Al-Basrah Offshore Oil Terminal, Persian Gulf 15
Figure 2: Tanker with Insert of Double Hull 16
Figure 3: Top Exporters of Petroleum to the United States in 2005
(Millions of barrels per day) 17
Figure 4: Top Exporters of Natural Gas to United States in 2005 (Millions
of cubic feet per day) 18
Figure 5: Regional Significance of Petroleum Commodities 19
Figure 6: Oil Flows and Strategic Shipping Chokepoints 20
Figure 7: Tanker Limburg after Terrorist Attack near Yemen 26
Figure 8: Tanker Approaching an Iraqi Oil Loading Terminal as U.S. Warship
Patrols Nearby 39
Figure 9: U.S. Warship Engaging Suspected Pirate Vessel near Somalia 41
Figure 10: Safety and Security Escort for LNG Tanker 44
Figure 11: Coast Guard Enforcing Security Zone around Moored LNG Tanker 45
Figure 12: Location of Operating, Planned, and Proposed LNG Marine
Terminals by U.S. Coast Guard District 50
Figure 13: Relationship of Spill and Terrorism Response Plans and
Agreements 54
Figure 14: Incident Response Sequence When an Attack Occurs Resulting in a
Spill 59
Figure 15: Potential Actions Taken to Respond to an Attack on an Energy
Commodity Tanker 61
Figure 16: Firefighters Preparing for a Maritime Terrorism Training
Exercise 68
Figure 17: Examples of Marine Firefighting Response 71
Figure 18: Firefighters Training to Combat an Aviation Fuel Fire 74
Figure 19: Risk Management Framework 90

Abbreviations

ACP Area Contingency Plan
AMSC Area Maritime Security Committee
AMSP Area Maritime Security Plan
BLEVE boiling liquid expanding vapor explosion
CBP Customs and Border Protection
CDC certain dangerous cargo
COTP Captain of the Port
CSF Critical Skill Factor
DHS Department of Homeland Security
DOD Department of Defense
DOJ Department of Justice
EPA Environmental Protection Agency
FBI Federal Bureau of Investigation
ICS incident command system
IMO International Maritime Organization
ISPS International Ship and Port Facility Code
LNG liquefied natural gas
LOOP Louisiana Offshore Oil Port
LPG liquefied petroleum gas
MARSEC Maritime Security Condition System
MIRP Maritime Incident Recovery Plan
MLA Maritime Liaison Agent
MOTR Marine Operational Threat Response Plan
MTR Maritime Transportation Response
MTSA Maritime Transportation Security Act of 2002
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NIMS National Incident Management System
NRP National Response Plan
NSFCC National Strike Force Coordination Center
ONS Operation Neptune Shield
OPA 90 Oil Pollution Act of 1990
SAFE Port Act Security and Accountability for Every Port Act of 2006
SONS Spill of National Signficance
USCG United States Coast Guard

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United States Government Accountability Office

Washington, DC 20548
December 10, 2007

The Honorable John D. Dingell: 
Chairman: 
The Honorable Joe Barton: 
Ranking Member: 
Committee on Energy and Commerce House of Representatives: 

The Honorable Bennie G. Thompson: 
Chairman: 
The Honorable Peter King: 
Ranking Member: 
Committee on Homeland Security: 
House of Representatives: 

The Honorable Edward J. Markey: 
House of Representatives:

This is a public version of a report we issued in March 2007 that
contained Sensitive Security Information related to the transportation of
energy commodities by tanker. Specific details regarding the nature of
security conditions and operations at specific ports, and specific
findings related to response plans and results of exercises that are
sensitive were removed. We worked with the cognizant agencies to ensure
that this version would not contain Sensitive Security Information. No
additional audit work was performed for the completion of this version.
The conclusions and recommendations of our March 2007 report remain
generally unchanged.

The United States economy is dependent on oil, gas, and other energy
commodities that are transported from overseas by ship.1 For example, in
2005, approximately 55 percent of the nation's crude oil supply--one of
the main sources of gasoline, diesel and jet fuel, heating oil, and many
other petroleum products--and approximately 3 percent of the natural gas
supply, was imported by tanker. Daily ship-based imports of crude oil
averaged about 8.5 million barrels, or the equivalent of about four
supertankers arriving at U.S. terminals each day.2 In addition to crude
oil, the United States also imports highly combustible liquid energy
products, such as gasoline, jet fuel, and liquefied gases, such as
liquefied petroleum gas (LPG) and liquefied natural gas (LNG).3 Natural
gas is converted to LNG by cooling it to minus 260 degrees Fahrenheit, at
which point it becomes a liquid. In its liquid form, natural gas reduces
to more than 1/600th of its volume as a gas, making it feasible to
transport over long distances. Daily ship-based imports of LNG now average
about 1.7 billion cubic feet, or the equivalent of two LNG tankers
arriving at a U.S. port every 3 days. This already extensive reliance on
imported energy commodities is expected to increase--and for LNG, to grow
substantially. The Energy Information Administration forecasts that by
2015, the amount of crude oil imported into the United States will
increase by nearly 4 percent, while the amount of imported LNG will grow
more than 400 percent.

1In this report, the term "energy commodities" refers to crude oil,
refined petroleum products, and natural gas.

Transporting these often hazardous commodities by sea involves a global
supply chain with many players. For energy commodities imported by the
United States, this supply chain has three main activities: loading it
aboard a ship at a foreign facility, shipping it across oceans and
waterways, and unloading it at a facility in this country. Waterborne
shipments originate at facilities in a variety of countries--for crude
oil, primarily in Mexico, Saudi Arabia, Venezuela, and Nigeria, and for
LNG, primarily in Algeria and Trinidad and Tobago.4 Overseas facilities
where tankers are loaded are owned by the private sector, governments, or
combinations of the two. Foreign governments play a substantial role in
overseeing the security of energy export operations. Shipment of these
commodities likewise involves vessels owned by many different companies,
as well as transportation routes across international waters that no
government controls. In 2006, there were approximately 3,550 registered
crude oil tankers of 300 gross tons or more, along with 200 registered LNG
tankers. Most of these vessels are registered in countries other than the
United States, which means the United States has limited oversight
authority over these vessels' crews or condition until they enter U.S.
waters. Once the crude oil or LNG tanker arrives in the United States, it
is unloaded at terminals that may be on the Atlantic, Gulf, or Pacific
coasts. LNG is currently unloaded at one of five locations.5 As demand for
natural gas grows, the number of domestic LNG unloading locations is
expected to increase. The Federal Energy Regulatory Commission, which must
approve each onshore LNG terminal siting and construction application, has
already approved 11 additional terminals, and dozens more have been
proposed.6

2While most petroleum is imported as crude oil and refined in U.S.
terminals, tankers also import products already refined from crude oil.
Crude oil is refined into petroleum products using several processes that
start with simple distillation. The products are referred to as "light"
petroleum products (the group of petroleum products with lower boiling
temperatures, including gasoline, jet fuel, and diesel fuel) and "heavy"
petroleum products (those that remain after the lighter products are
distilled away, such as asphalt). See appendix II for a description of
assorted energy commodities imported into the United States by tanker.

3LNG is primarily methane, while LPG is propane or butane that has been
cooled or pressurized to reduce its volume. LPG imports are relatively
small in volume compared to LNG imports.

4Canada is the other primary supplier of crude oil and natural gas to the
United States, but its exports arrive by pipeline.

This supply chain, while critical, is also vulnerable to disruption by
terrorists. Port facilities are inherently vulnerable, because they must
provide access by land and sea and because they are sprawling
installations, often close to population centers. Likewise, the ships that
transport these products are vulnerable because they travel on direct
routes that are known in advance and, for part of their journey, they may
have to travel through waters that do not allow them to maneuver away from
possible attacks. Since so many different players are involved, terrorists
have room to probe the supply chain for the weakest link. Despite an often
heavy security presence, terrorists have attempted--and in some cases
carried out--several attacks on this supply chain since September 11,
2001. To date, these attacks have included attempts to damage tankers or
disrupt loading operations in or near overseas ports. For example, in 2004
terrorists coordinated an attack against two offshore oil terminals in
Iraq where tankers were loading, and in 2002 terrorists conducted a
suicide boat attack against the French supertanker Limburg off the coast
of Yemen.

5The five are located at Everett, Massachusetts (near Boston); Cove Point,
Maryland (on Chesapeake Bay); Elba Island, Georgia (near Savannah); Lake
Charles, Louisiana (in western Louisiana); and offshore in the Gulf of
Mexico, 116 miles south of the Louisiana coast.

6In addition to the 11 onshore LNG terminals, 2 offshore terminals have
been approved by the Maritime Administration, which is responsible for
approving new offshore LNG facilities. A total of 32 new onshore and
offshore LNG facilities have been proposed or approved by either the
Federal Energy Regulatory Commission or the Maritime Administration.

Much of the international framework for protecting this supply chain and
preventing pollution from vessels is laid out in international
conventions. The International Ship and Port Facility Security (ISPS) Code
was adopted under the auspices of the International Maritime Organization
(IMO) by the Conference of Contracting Governments to the International
Convention for the Safety of Life at Sea (SOLAS).7 In accordance with the
SOLAS Convention as amended in 2002, the code establishes requirements for
contracting governments of countries where ports are located, contracting
governments of countries where ships are registered, operators of port
facilities, and operators of vessels traveling on the high seas.8
Individual nations can set higher standards for facilities on their soil
and for vessels registered in that country. The United States has chosen
to set higher standards, largely through the Maritime Transportation
Security Act of 2002 (MTSA).9 Enacted after the September 11, 2001,
attacks, MTSA places much of the responsibility for coordinating and
overseeing security efforts with the federal government--and more
specifically with the Department of Homeland Security (DHS) and its
agencies, such as the U.S. Coast Guard. Another international agreement
developed under IMO auspices is the International Convention for the
Prevention of Pollution from Ships, which entered into force in 1983 and
was intended to prevent pollution of the marine environment by ships from
operational or accidental causes. Included in its provisions was pollution
by oil, chemicals, and harmful substances. In the United States, Congress
passed the Oil Pollution Act of 1990 (OPA 90) following the 1989 Exxon
Valdez oil spill.10 OPA 90 addressed prevention, response, and
compensation for oil pollution from vessels and facilities in U.S. waters
and the shoreline. OPA 90 greatly increased federal oversight of maritime
oil transportation by setting new requirements for vessel construction and
crew licensing and manning, mandating contingency planning, enhancing
federal response capability, broadening enforcement authority, and
increasing penalties.11

7IMO is an agency of the United Nations that facilitates international
regulation of safety and security of commercial shipping.

8Countries where ports are located are referred to as "port states."
Countries where ships are registered are referred to as "flag states." As
of November 30, 2006, there were 156 contracting governments to the SOLAS
Convention, representing 99 percent of the world shipping fleet by
tonnage.

9Pub. L. No. 107-295, 116 Stat. 2064.

10Pub. L. No. 101-380, 104 Stat. 484.

In setting U.S. policy with regard to homeland security, both Congress and
the Administration have endorsed making decisions on the basis of
risk--that is, on identifying critical infrastructure, determining what is
most at risk, and applying sound measures designed to make cost-effective
use of resources and funding. As groups such as the 9/11 Commission have
pointed out, no amount of money can totally insulate seaports from attack
by a well-funded and determined enemy. Managing on the basis of risk
acknowledges the trade-offs inherent in deciding how finite resources
should be spent.

Federal actions to prevent attacks against the energy supply chain involve
coordination with the many players involved, including foreign
governments; foreign and domestic corporations that own and operate the
ships that carry energy commodities; companies that import, refine, and
market petroleum and liquefied gases; and a host of state and local
governmental agencies. At the state and local levels, fire and police
departments would be the first responders, with support from emergency
management, environmental, and transportation departments. Private sector
agencies, such as oil or gas facility terminal operators, vessel
management companies, and oil spill response organizations, would also be
involved. Finally, multiple federal agencies would also respond. In
particular, the U.S. Coast Guard (USCG) and the Federal Bureau of
Investigation (FBI) would have primary responsibility for leading the
response effort.

To help evaluate how secure the maritime energy supply chain is and how
the United States would respond in the event of a terrorist attack, you
asked us to review security and safety efforts taken to date.12 This
report addresses three questions:

11See: GAO, Maritime Transportation: Major Oil Spills Occur Infrequently,
but Risks to the Federal Oil Spill Fund Remain, [65]GAO-07-1085
(Washington, D.C.: Sept. 7, 2007).

           o What are the types of terrorist threats to tankers carrying
           energy commodities and the potential consequences of a successful
           attack?

           o What measures are being taken to protect these tankers, and what
           challenges do federal agencies face in making these actions
           effective?

           o If a terrorist attack succeeds despite these protective
           measures, what plans are in place to respond and what are the
           potential challenges in responding to an attack?

To address these objectives, we conducted a wide range of activities
overseas and in the United States. Overseas, we met with officials from
the IMO, foreign government security agencies, vessel and facility
operators, international industry associations, vessel and cargo insurers,
and risk management companies. We conducted our overseas work primarily in
five countries, which we selected for specific reasons related to their
role in the supply chain, the sophistication of their security procedures,
or the presence of key stakeholders. In the United States, we met with
officials in many federal departments and agencies, including the
Departments of Homeland Security, Defense, State, Energy, Transportation,
and Justice; the Federal Energy Regulatory Commission; and the
Environmental Protection Agency. We met with a variety of state and local
government officials dealing with homeland security, emergency response,
and law enforcement, as well as with operators of oil cleanup
organizations, petroleum tankers, liquefied gas carriers, and their
attendant unloading facilities. We also visited field units of the U.S.
Coast Guard, Customs and Border Protection, the FBI, and a nonprobability
sample of petroleum and liquefied gas import and export facilities.13 In
these visits we observed security practices firsthand, and conducted
interviews with officials. We obtained and reviewed studies on the
consequences of an attack, obtained additional views from experts, and
specifically convened a panel of academic and industry experts to
determine the potential consequences of an incident involving LNG.14 We
analyzed databases, progress reports, regulations, and guidance documents
we obtained from the Coast Guard and Federal Energy Regulatory
Administration. We obtained necessary information from the Coast Guard to
review the reliability of the information contained in the databases used
in this report. Appendix I contains a more detailed discussion of our
methodology. We conducted our work in accordance with generally accepted
government auditing standards from April 2005 through February 2007.

12In general, the scope of our review is limited to terrorist attacks. We
did not evaluate the security of the maritime energy supply chain from
other attacks, such as the militaries of other countries, or from natural
disasters, such as hurricanes or earthquakes. For information on ports and
natural disasters see GAO, Port Risk Management: Additional Federal
Guidance Would Aid Ports in Disaster Planning and Recovery, [66]GAO-07-412
(Washington, D.C.: Mar. 28, 2007), and GAO, Coast Guard: Observations on
the Preparation, Response, and Recovery Missions Related to Hurricane
Katrina, [67]GAO-06-903 (Washington, D.C.: July 31, 2006).

Results in Brief

Attacks overseas show that tankers face several major types of threats
that, if carried out domestically, could have serious consequences.
Overseas, terrorists have demonstrated the ability to carry out at least
three main types of threats. First--and overall of greatest concern to
officials we spoke with--is a suicide attack, such as the 2002 suicide
boat attack on the tanker Limburg off the coast of Yemen. This attack
killed 1 person, injured 17, and spilled 90,000 barrels of oil. A second
major type of threat, known as a "standoff attack," uses a rocket or other
weapon launched at a sufficient distance to allow the attackers to evade
defensive fire. A third type of threat is an armed assault. For example,
well-armed bands have used small boats to attack tankers, loading
facilities, and oil workers. Many other types of potential attacks exist,
such as internal crew conspiracies and collisions with other vessels
piloted by terrorists. To date, no such attacks have occurred on tankers
in U.S. waters or on loading facilities in U.S. ports, and intelligence
officials report there is currently no specific credible threat to tankers
or terminals on the domestic front. Nonetheless, these successful attacks
abroad, the expressed desire by terrorists to target U.S. economic
interests, and the potential outcome of a terrorist attack on a tanker
have led Congress and the Administration to conclude that protective
efforts are warranted. A successful attack on an energy commodity tanker
could have substantial public safety, environmental, and economic
consequences. Public safety and environmental consequences of an attack
vary by commodity. For instance, highly combustible commodities like LNG
and LPG have the potential to catch fire, or in a more unlikely
scenario--if they are trapped in a confined space such as under a
dock--explode, posing a threat to public safety. Crude oil and heavy
petroleum products remain in the environment after they are spilled and
must be removed, potentially causing significant environmental damage.
Finally, the economic consequences of a major attack could include a
temporary price spike reflecting fears of further attacks, and supply
disruptions associated with delays of shipments if major transit routes,
key facilities, or key ports are closed. The loss of one cargo of an
energy commodity might not have a significant, sustained price impact.
However, if an attack results in port closures for multiple days or weeks,
price responses and higher costs could mean losses in economic welfare to
consumers, businesses, and government amounting to billions of dollars.

13Nonprobability sampling is a method of sampling where observations are
selected in a manner that is not completely random, usually using specific
characteristics of the population as criteria. Results from nonprobability
samples cannot be used to make inferences about a population because in a
nonprobability sample, some elements of the population being studied have
no chance or an unknown chance of being selected as part of the sample.

14We have also reported the views of our findings related specifically to
LNG in a separate report. See GAO, Maritime Security: Public Safety
Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural
Gas Need Clarification, [68]GAO-07-316 (Washington, D.C.: Feb. 22, 2007).

Much is being done, both internationally and domestically, to protect
energy commodity tankers and their attendant facilities from attack, but
notwithstanding these actions, significant challenges may still leave
tankers and facilities at risk. Internationally, many foreign governments
and facility operators are taking such actions as improving physical
security at facilities and conducting offshore patrols. For example, port
facilities report compliance with ISPS Code requirements, tanker operators
report strengthening their security posture while loading and at sea, and
the Coast Guard visits foreign exporting ports to assess the effectiveness
of the anti-terrorism measures in place. Navies of various countries,
including the United States, are also patrolling threatened waters, such
as the Persian Gulf and the Gulf of Aden, due to attacks on ships,
including tankers, and port facilities. International stakeholders face
challenges, however, in implementing this security framework. Our visits
to overseas facilities showed that some port facilities had put extensive
security measures in place, while at other facilities, we found such
problems as unattended gates and downed fences. Although facilities may
report they are complying with the ISPS Code, there is no mechanism
currently in place to verify compliance, and Coast Guard activities abroad
are limited by and dependent on conditions set by host nations, including
the locations the Coast Guard can visit. For tankers in transit in
international waters, the primary challenge involves patrolling the
lengthy travel routes and frequent danger spots with a limited number of
naval vessels. Because of the challenges and limitations faced
internationally, security efforts taken domestically carry increased
importance. Here, federal agencies such as the Coast Guard and Customs and
Border Protection (CBP) have taken a variety of steps to protect the
energy supply chain. Both agencies monitor arriving ships and crews, and
the Coast Guard also conducts security activities, such as pre-entry
security boardings, escorts, and patrols. The prioritization of the Coast
Guard's security activities is based upon its established risk-based
decision-making processes. These activities are often reinforced by local
law enforcement units that, in some cases, receive financial support from
facility operators. Despite these domestic efforts, challenges persist.
Coast Guard records document that at some ports, a lack of resources has
hindered some Coast Guard units from meeting their self-imposed
requirements for security activities, such as escorts and boardings. To
better align security requirements with its resources, the Coast Guard
recently revised some of its security standards, such as those for
protecting vessels carrying a number of hazardous liquids and liquefied
gases. Although the Coast Guard reported that it based this action on the
consequences of an attack, it could not provide us any analyses that
covered all commodities involved. As a result, it is unclear if security
requirements were reduced for the commodities with the lowest associated
risk. The Coast Guard is currently performing such an analysis. In the
future, the Coast Guard faces additional challenges at some domestic
ports, where workload demands are likely to rise substantially as new LNG
facilities come on line and LNG shipments increase. These increased
demands could cause the Coast Guard to continue to be unable to meet the
standards it has set for keeping U.S. ports secure.

Should a terrorist attack succeed despite the protective measures in
place, the United States and designated ports have developed plans for
responding but could face several challenges in implementing these plans
effectively. Specifically, ports face challenges in integrating both
national- and port-level spill and terrorism response plans, mitigating
economic consequences, and obtaining necessary resources to respond.
Regarding the plans, at the national level, the National Response Plan
lays out the broad parameters of the federal role, both in spill response
(that is, taking steps to contain a spill and mitigate its environmental
damage, regardless of how it occurred) and in terrorism response (that is,
for the attack, taking security-related actions and conducting an
investigation). The plan designates the Coast Guard as the primary agency
for spill response on water and the FBI as the primary agency for
terrorism response, and it calls on the two agencies to coordinate their
responses if the incident involves an attack on energy commodity tankers.
Other federal plans and agreements also come into play, each with
information about coordinating responses among the various agencies
involved or taking specific action. At the port level, under the Oil
Pollution Act of 1990 and the Maritime Transportation Security Act of
2002, Coast Guard's Captain of the Port is to establish separate plans for
spill and terrorism responses, working with local agencies, which are
subsequently approved by Coast Guard districts. For both types of response
plans, the agencies may include port authorities, fire departments, and
facilities in the port. Some stakeholders, such as private oil spill
response organizations, participate only in spill response planning, while
other stakeholders, such as police departments, participate mainly in
terrorism response planning. While national- and port-level plans exist,
federal agencies and ports could face challenges in using them
effectively.15 First, the separate spill and terrorism response plans
should be integrated for responding to an attack on an energy commodities
tanker. At the federal level, the Coast Guard and the FBI should ensure
that they have a detailed operational plan to integrate the spill and
terrorism response sections of the National Response Plan. Port
stakeholders should integrate spill and terrorism response plans to
address response coordination. The Coast Guard has recommended joint
exercises when feasible to test stakeholders' spill and terrorism response
plans. Second, the President's strategy for maritime security recommends
that ports develop plans to mitigate the economic consequences of an
attack, such as determining priorities for allowing vessels to enter or
leave the port after it reopens. While such plans could be developed under
the leadership of the Coast Guard's Captain of the Port at the port level,
there was no national-level guidance about what economic mitigation plans
should contain at the time of our review. Finally, some ports we visited
may not have the resources needed to promptly respond to an attack. For
instance, some local firefighters said that they may not be able to
effectively respond to marine fires because they do not have enough fire
boats or are not sufficiently trained for shipboard firefighting. Port
officials also said they lacked resources for improving emergency response
capabilities. According to DHS officials, federal grant funding for
response activities may become more available as DHS moves toward a more
comprehensive risk-based process for allocating grant funds. However, DHS
may not be able to effectively allocate grants on the basis of reducing
risk because it does not have performance measures showing how much of a
given resource is needed to conduct a response. Without such performance
measures, the federal government cannot effectively set priorities for
acquiring needed response resources.

15Specific details regarding the operationalization and integration of
spill and terrorism response plans were provided in the Sensitive Security
Information version of this report.

We are making recommendations to the Secretary of Homeland Security and
the Attorney General designed to build on efforts already under way and
make these efforts more effective. For protecting against threats, we
recommend developing a national resource allocation plan for meeting
security requirements posed by proposed expansion in the number of LNG
facilities and shipments. For responding to actual attacks, these
recommendations include ensuring that a detailed operational plan has been
developed that integrates the different spill and terrorism response
sections of the National Response Plan, as well as ensuring the
integration of local spill and terrorism planning and exercises at ports
that receive energy commodities; developing national-level guidance that
ports can use for mitigating economic consequences, particularly in the
case of port closures; and developing specific performance measures for
determining the resources needed to effectively respond to attacks on
tankers carrying energy commodities. The responsible agencies generally
agreed with our recommendations. DHS, however, stated it was taking the
final recommendation (on performance measures) under advisement.

Background

Many Stakeholders Are Involved in Securing the Maritime Energy Supply Chain

Numerous international and domestic organizations play a role in the
security of maritime energy commodities. The list of stakeholders outside
the United States is quite diverse. They include international
organizations, governments of nations where tankers load or where tankers
are registered, and owners and operators of tankers or facilities (see
table 1).

Table 1: Selected International Stakeholders with Maritime Security
Activities

Agency                            Selected mission-related activities      
International organizations                                                
      o International Maritime          o Develops and maintains a            
      Organization (IMO)                comprehensive regulatory framework    
                                        for shipping.                         
      IMO is an organization            o Develops international standards    
      responsible for regulating        for port and vessel security.         
      international shipping with                                             
      167 governments as members.                                             
      o International Maritime          o The International Maritime Bureau's 
      Bureau                            Piracy Reporting Center broadcasts a  
      o The International Maritime      daily bulletin of piracy attacks      
      Bureau is a division of the       directly to ships at sea.             
      International Chamber of          o Provides piracy updates and         
      Commerce that works to            comprehensive reports on a regular    
      suppress piracy around the        basis.                                
      world.                            o Reports piracy incidents to law     
                                        enforcement authorities.              
      o Intertanko                      o Intertanko maintains a database     
                                        that includes reports of security     
      Intertanko is an association      conditions at ports of call           
      of independent tanker owners      throughout the world.                 
      and operators.                                                          
      o BIMCO                           o BIMCO coordinates with              
                                        international organizations,          
      The Baltic and International      governments, and members to improve   
      Maritime Council (BIMCO)          port and ship security, address       
      represents over 65 percent of     piracy and stowaway problems, and     
      world's tanker fleet.             secure an adequate supply of          
                                        well-trained seafarers.               
Overseas governmental agencies                                             
      o ISPS designated authorities     o Set security levels at a country's  
                                        ports.                                
      Government agencies               o Review vessel and facility security 
      responsible for implementing      plans and oversees compliance with    
      ISPS requirements. In the         these plans.                          
      United States the authority is                                          
      the United States Coast Guard.                                          
International private sector                                               
      o Overseas port facility          o Implement facility security plans   
      operators                         that meet local port security         
                                        standards.                            
      o Vessel owners and operators     o Implement vessel security plans     
                                        that meet ISPS Code and flag state    
                                        security standards.                   
      o Lloyd's Market Association      o Lists area endangered by war,       
                                        strikes, terrorism, and related       
      Support and research              perils--areas for which underwriters  
      organization for Lloyd's          can charge higher premiums for        
      insurance underwriters.           vessels.                              

Source: GAO.

On the domestic side, the U.S. Coast Guard is the lead federal agency and
is responsible for a wide array of maritime safety and security
activities. Other U.S. government agencies support the Coast Guard's
maritime security mission by addressing a wide range of issues that affect
the flow of cargo and people into the United States. State and local
governments and the private sector also have responsibilities to secure
domestic ports. Table 2 lists key federal agencies and other stakeholders
on the domestic side, together with examples of the kinds of maritime
security activities performed.

Table 2: Selected Domestic Stakeholders with Maritime Security Activities

Stakeholders                  Selected mission-related activities          
Federal government:                                                        
Department of Homeland                                                     
Security                                                                   
      o U.S. Coast Guard            o Conducts vessel escorts, boardings of   
                                    selected vessels, and security patrols of 
                                    key port areas.                           
                                    o Ensures vessels in U.S. waters comply   
                                    with domestic (MTSA) and international    
                                    (ISPS Code) maritime security standards.  
                                    o Reviews U.S. vessel and facility        
                                    security plans and oversees compliance    
                                    with these plans.                         
                                    o Meets with foreign governments and      
                                    visits foreign port facilities to observe 
                                    security conditions.                      
      o Customs and Border          o Screens vessel, crew, passenger, and    
      Protection (CBP)              cargo information prior to vessel arrival 
                                    in the United States.                     
                                    o Boards all vessels that arrive from     
                                    foreign ports to review personnel and     
                                    cargo documentation. Ensures that all     
                                    have appropriate documents to gain access 
                                    to the United States.                     
                                    o If concerns about crew or cargo exist,  
                                    takes action to deny entrance to the      
                                    United States.                            
Federal government:           
Department of Justice         
      o Federal Bureau of           o FBI Maritime Liaison Agents, stationed  
      Investigation (FBI)           at key ports in the United States, help   
                                    disseminate maritime intelligence to port 
                                    stakeholders.                             
                                    o Leads Joint Terrorism Task Forces.      
                                    o Has lead role in investigating maritime 
                                    terrorism incidents.                      
Federal government:           
Department of Defense         
      o U.S. Navy                   o Provides support to Department of       
                                    Homeland Security as requested for        
                                    maritime homeland security operations.    
                                    o Maintains a credible maritime           
                                    interdiction capability to deal with      
                                    identified hostile ships at any location  
                                    when authorized to do so.                 
                                    o Builds relationships with partner       
                                    nations' navies to enhance cooperation    
                                    and information sharing.                  
Federal government:           
Department of State           
      o Bureau of Consular          o Reviews visa applications and issues    
      Affairs - Visa Services       nonimmigrant visas for crew members,      
                                    including recognizing falsified documents 
                                    on visa applications.                     
State and local governments                                                
      o Law enforcement agencies    o Conduct land-based patrols of port      
                                    facilities.                               
                                    o If agency operates a marine unit,       
                                    support Coast Guard role through water    
                                    patrols and possibly escorts.             
Private sector                
      o Facility operators          o Develop and implement facility security 
                                    plans that meet MTSA standards.           

Source: GAO.

All of these international and domestic stakeholders help to ensure the
safety and security of a global supply chain that brings energy
commodities to the United States. This supply chain spans the globe and
reaches many regions of the world. Each day, the United States imports
many different energy commodities from overseas suppliers in Africa,
Europe, the Middle East, and North and South America. Excluding Canada,
which supplies petroleum and natural gas to the United States via
pipeline, the vast majority of these varied imports arrive by tanker.

Tankers Transport Energy Commodities around the World

The various types of energy commodities require different handling
methods, and as a result, various kinds of tankers have been built to
accommodate them. An LNG carrier is designed for transporting LNG at minus
260 degrees Fahrenheit, when gas liquefies and shrinks drastically in
volume. The cargo is transported in special tanks insulated to minimize
evaporation. LNG carriers are up to 1,000 feet long and have a draft
(depth below the water line) of 40 feet when fully loaded. The global LNG
fleet is expected to double from 200 in 2006 to over 400 by 2010.
According to industry reports, the existing fleet has completed more than
33,000 voyages without a substantial spill. Oil tankers are more numerous
and vary greatly in size. Tankers transporting crude oil from the Middle
East generally consist of Very Large Crude Carriers, which typically carry
more than 2 million barrels of oil per voyage.16 These ships are over
1,000 feet long, nearly 200 feet wide, and have a draft of over 65 feet.17
Figure 1 shows a typical Very Large Crude Carrier. These ships are too big
for most U.S. ports and must transfer their loads to smaller tankers (a
process called lightering) or unload at an offshore terminal. At present,
the United States has only one such offshore terminal--the Louisiana
Offshore Oil Port (LOOP).18 Most tankers transporting cargos from the
Caribbean and South America, by contrast, are smaller than Very Large
Crude Carriers and can enter U.S. ports directly.

16A barrel is equivalent to 42 gallons of oil.

17The Ultra Large Crude Carrier type of tanker is even larger than the
Very Large Crude Carrier, but because of changing route economics, Ultra
Large Crude Carriers make up a small portion of the overall tanker market.

18LOOP, the only U.S. deepwater oil port that can handle fully loaded Very
Large Crude Carriers, is located 18 miles off the Louisiana coast and
currently handles about 10 percent of U.S. crude oil imports.

Figure 1: Oil Tanker at Al-Basrah Offshore Oil Terminal, Persian Gulf

There are generally two enforcement systems aimed at ensuring that these
vessels are in compliance with applicable regulations, laws, and
conventions: flag state control and port state control. The flag state is
the country in which the vessel is registered. Flag state control can
extend anywhere in the world where the vessel operates. For example, a
flag state's requirements set the standards for the operation and
maintenance of all vessels flying that flag. If the flag state is a
contracting government to the SOLAS Convention, these standards are
required to be at least as stringent as those included in the ISPS Code.
The port state is the country where the port is located. Port state
control is the process by which a nation exercises its authority over
foreign-flagged vessels operating in waters subject to its jurisdiction.
It is intended to ensure that vessels comply with all domestic
requirements for ensuring safety of the port, environment, and personnel.
Thus, when a foreign-flagged oil tanker enters a U.S. port, the U.S. port
state control program, administered by the U.S. Coast Guard, becomes the
primary means of marine safety enforcement. For example, the Oil Pollution
Act of 1990 requires that all tankers built after 1994 coming to the
United States must have double hulls--that is, a two-layered hull to help
prevent spills resulting from a collision or grounding (see fig. 2).19

Figure 2: Tanker with Insert of Double Hull

Energy Commodities Originate in a Variety of Locations

According to the Energy Information Administration, the United States
consumes more than 20 million barrels of petroleum every day.20 Of that
amount, over 65 percent comes from foreign sources. The top suppliers of
crude oil and petroleum products to the United States in 2005 were Canada,
Mexico, Saudi Arabia, Venezuela, and Nigeria--each supplying over 1
million barrels of petroleum per day (see fig. 3). Iraq, Algeria, Angola,
Russia, and the United Kingdom are also major energy suppliers with daily
imports to the United States of up to 500,000 barrels per day. These top
10 energy suppliers accounted for approximately 75 percent of all U.S.
petroleum imports in 2005. All petroleum imports to the United States from
those countries arrive on tankers, except those from Canada.

19The U.S. Maritime Administration reports that in 2005, 79 percent of
tanker calls (U.S.-flag and foreign-flag) at U.S. ports were by
double-hull tankers.

20This includes both crude oil and petroleum products.

Figure 3: Top Exporters of Petroleum to the United States in 2005
(Millions of barrels per day)

Imports are a growing portion of the natural gas supply in the United
States. With consumption of natural gas growing faster than domestic
production, imports of natural gas will almost certainly continue to rise,
according to the Energy Information Administration. Today, Canada is the
primary supplier of natural gas to the United States and all of natural
gas imports from Canada are carried by pipeline.21 Approximately 3 percent
of all natural gas imports to the United States is LNG. Trinidad and
Tobago is the single largest supplier of LNG to the United States,
supplying 70 percent of all LNG imported into this country (see fig. 4).
Other LNG suppliers in 2005 included Algeria, Egypt, Malaysia, Nigeria,
Qatar, and Oman.

21Imports of natural gas from Mexico also arrive in the United States via
pipeline.

Figure 4: Top Exporters of Natural Gas to United States in 2005 (Millions
of cubic feet per day)

Key Domestic Ports Handle Vast Majority of Energy Imports

The United States imports about 65 percent of its crude oil and petroleum
products as well as about 3 percent of its natural gas needs.22 As shown
in figure 5, certain energy commodities are imported into particular
regions of the country. Appendix II provides detailed descriptions of U.S.
energy commodity imports transported by tanker. For example, in 2004:

           o Ports along the Gulf Coast imported 62 percent of the crude oil
           imported to the United States.
           o Ports along the East Coast imported 95 percent of the gasoline
           and 75 percent of the LNG.
           o Ports along the West Coast imported 60 percent of all jet fuel.

22This section presents petroleum and LNG import data for 2004. Although
2005 data are more recent, normal petroleum import patterns were disrupted
by the series of hurricanes that affected the Gulf Coast. Because of these
impacts, 2004 data are more representative.

Figure 5: Regional Significance of Petroleum Commodities

Characteristics of Maritime Supply Chain Make It Vulnerable to Terrorist Attack

The global maritime environment through which the energy supply chain
operates is constrained by physical geography and influenced by regional
political dynamics. The physical geography of the continents, for example,
forces shipping lanes to pass through certain narrow channels, or
chokepoints. There are approximately 200 such locations, but only a
handful are of strategic importance for the global energy supply (see fig.
6). A chokepoint by definition tends to be shallow and narrow, resulting
in impaired navigation and congestion from other tankers, cargo ships, and
other smaller vessels, which can impede the free and efficient flow of
goods. Moreover, several key chokepoints are surrounded by more than one
sovereign nation, resulting in a complex security environment within a
constrained physical space. Managing security in this environment requires
significant coordination among these countries to successfully manage the
security in these locations. According to the Energy Information
Administration, chokepoints are susceptible to pirate attacks and shipping
accidents in their narrow channels. In addition, chokepoints can be
blocked, mined, or rendered inaccessible by foreign naval forces, with
potentially devastating consequences for the flow of oil and goods around
the world and into the United States.

Figure 6: Oil Flows and Strategic Shipping Chokepoints

The Straits of Hormuz and Malacca are two critical maritime shipping
chokepoints that tankers pass through regularly. The Strait of Hormuz,
which connects the oil fields of the Persian Gulf with the Gulf of Oman
and the Indian Ocean, is the most important chokepoint in the world in
terms of the global energy supply, with about 20 percent of the world oil
supply, including 17 percent of U.S. petroleum imports passing through it.
Tankers with oil from the Persian Gulf must navigate through this
chokepoint in order to access the principal international shipping lanes
toward the United States. Another chokepoint, the Strait of Malacca, links
the Andaman Sea and the Indian Ocean (and oil coming from the Middle East)
with the South China Sea and the Pacific Ocean (and major consuming
markets in Asia). The Strait of Malacca is located among Malaysia,
Indonesia, and Singapore and about 600 vessels pass through it each day.
Piracy and political instability in the region, especially in Indonesia,
are issues of concern for shipping operations in the strait. The Energy
Information Administration identified other important maritime
chokepoints, including the Bab el-Mandab passage from the Arabian Sea, the
Panama Canal connecting the Pacific and Atlantic Oceans, the Suez Canal
connecting the Red Sea to the Mediterranean Sea, and the Bosporus Straits
linking the Black Sea to the Mediterranean Sea.

Besides facing vulnerabilities while in transit, vessels can be vulnerable
while moored at facilities where they are receiving or unloading their
cargoes, and the energy-related infrastructure located in ports can also
be vulnerable to attack. Vessels transiting into and out of ports and
their attendant infrastructure can be vulnerable in a number of ways.
During transit into and out of port, these vessels travel slowly, which
increases their exposure. Tankers follow timetables that are easy to track
in advance and they follow a fixed set of maritime routes. Once tankers
arrive in this country, they must wait offshore for pilots to navigate the
ship channels into many of the nation's ports.

Since the terrorist attacks of September 11, increased national attention
has been focused on the potential vulnerability of the nation's 361 major
seaports to terrorist attack. According to the National Strategy for
Maritime Security, the infrastructure and systems that span the maritime
domain have increasingly become both targets of and potential conveyances
for dangerous and illicit activities.23 GAO has previously reported that
ports are vulnerable because they are sprawling, interwoven with complex
transportation networks, close to crowded metropolitan areas, and easily
accessible.24 Ports and their maritime approaches, including waterways and
coastal areas, facilitate freedom of movement and the flow of goods while
allowing people, cargo, and vessels to transit with relative anonymity.
Some energy terminals are located in open seas where they are accessible
by water or air, while others are located in metropolitan areas, along key
shipping channels, or near pristine environmental sanctuaries where they
may be accessible by water, air, or land.

23The National Strategy for Maritime Security (Washington, D.C.: Sept.
2005).

24See GAO, Maritime Security: Enhancements Made, but Implementation and
Sustainability Remain Key Challenges, [69]GAO-05-448T (Washington, D.C.:
May 2005).

Addressing Tanker Security Vulnerabilities Involves Setting Risks in the Context
of Other Security and Nonsecurity Priorities

In the wake of the terrorist attacks of September 11, 2001, there was
widespread acknowledgement that numerous and substantial gaps existed in
homeland security. There is also widespread acknowledgment, however, that
resources for closing these gaps are limited and must compete with other
national priorities. It is improbable that any security framework can
successfully anticipate and thwart every type of potential terrorist
threat that highly motivated, well-skilled, and adequately funded
terrorist groups could perpetrate. While security efforts clearly matter,
various groups like the 9/11 Commission have emphasized that total
security cannot be bought no matter how much is spent on it. In short, the
nation cannot afford to protect everything against all threats, even
within the relatively narrow context of tanker security. Choices are
clearly involved--including decisions about the relative vulnerability
posed by attacks on energy commodity tankers as compared with attacks in
other forms, such as air safety or security in crowded urban centers.

In this context, risk management has become a widely endorsed strategy for
helping policymakers make decisions about allocating finite resources in
such circumstances.25 It emphasizes the importance of assigning available
resources to address the greatest risks, along with selecting those
strategies that make the most efficient and effective use of resources.
Risk management has received widespread support from Congress, the
President, and the Secretary of Homeland Security as a tool that can help
set priorities and inform decisions about mitigating risks.26

25See appendix V for additional information on risk management.

26For further discussion of risk management as it relates to homeland
security, see GAO, Risk Management: Further Refinements Needed to Assess
Risks and Prioritize Protective Measures at Ports and Other Critical
Infrastructure, [70]GAO-06-91 (Washington, D.C.: December. 2005).

Energy Commodity Shipments Face Varied Threats, and a Successful Attack Could
Have Substantial Consequences

Even though intelligence sources have reported that there are currently no
specific credible threats to energy tankers in U.S. waters or their
attendant facilities on U.S. soil, attacks overseas show that tankers face
several major types of threats, and if a threat were to be successfully
carried out domestically, it could have serious consequences. Overseas,
terrorists have demonstrated the ability to carry out at least three types
of threats.27 First, and of greatest concern, according to officials we
spoke with, is a suicide attack against a tanker or attendant facility.
Second is a standoff missile attack using a rocket or some other weapon
launched from a distance. Third is an armed assault by terrorists or armed
bands while a tanker is moored or in transit. There are additional types
of threats, including internal crew conspiracies and collisions with a
vessel piloted by terrorists. While attacks have so far occurred only
overseas, two Coast Guard admirals testified before Congress that
malicious maritime incursions into U.S. waters, such as immigrant or drug
smuggling, occur regularly. If an attack on a commodity tanker were
successful in U.S. waters or while docked at a U.S. unloading facility,
substantial public safety, environmental, and economic consequences could
result. Public safety and environmental consequences of an attack vary by
commodity. For instance, LNG and LPG are highly combustible and pose a
risk to public safety of fire or--in a more unlikely scenario in which
they are in a confined space--explosion. The environmental impact,
however, of LNG and LPG spills would be minimal since they dissipate in a
short period of time. Crude oil and heavy petroleum products remain in the
environment after they are spilled and must be removed, potentially
causing significant environmental damage. Potential economic consequences
of an attack include psychological market responses as well as significant
delays and possible shortages if major transit routes, key facilities, or
ports are closed.

No Credible Specific Threat of Attack at U.S. Ports to Date, but Events Overseas
Indicate Reasons for Concern

According to U.S. government intelligence sources, there have been no
specific credible terrorist threats to tankers in U.S. waters or their
unloading facilities on U.S. soil in the wake of the September 11 attacks.
Nonetheless, several events overseas and intelligence reports indicate
ongoing concern about the potential for an attack against tankers or
energy facilities.

27See appendix III for descriptions of recent terrorist attacks against
maritime or energy targets.

           o Heightened security threat levels in response to potential
           threats. The Coast Guard has raised the Maritime Security (MARSEC)
           level from Level 1 to Level 2 on several occasions in response to
           nonspecific threats based on intelligence or other warnings to the
           maritime sector.28 In the past, the Coast Guard has raised the
           MARSEC level due to general threats.

           o Other intelligence indicating ports are targets under
           consideration. Security officials in the U.S. government are
           concerned about the possibility of a terrorist attack in a U.S.
           port in the future. For example, captured terrorist training
           manuals cite seaports as targets and instruct trainees to use
           covert means to obtain surveillance information for use in attack
           planning. Terrorist leaders have also stated their intent to
           attack infrastructure targets within the United States, including
           seaports, in an effort to cause physical and economic damage, and
           inflict mass casualties.

           o Continued policy priority for port security. Four years after
           passage of the Maritime Transportation Security Act of 2002,
           Congress remained sufficiently concerned about maritime security
           to again increase security efforts under the Security and
           Accountability Act for Every (SAFE) Port Act of 2006.29 This law
           (1) required the Department of Homeland Security to conduct
           terrorist watch list checks of newly hired port employees, (2)
           provided authority for risk-based funding through security grants
           to harden U.S. ports against terrorist attacks and enhance
           capabilities to respond to attacks and resume operations, and (3)
           required the Department of Homeland Security to develop protocols
           for resuming trade after a transportation security incident.

  Officials Are Concerned about Three Primary Types of Threats

Our discussions with officials of various agencies and our review of
reports and other published documentation indicate that the following
three types of attacks on tankers or attendant facilities are considered
to be the most likely.

28MARSEC is a three-tiered system developed by the Coast Guard to
communicate the prevailing threat environment to the marine elements of
the national transportation system, including ports, facilities, and
critical assets and infrastructure. The levels align closely with DHS's
color-coded Homeland Security Alert System in the following way: MARSEC 1
applies when threat conditions Green, Blue, or Yellow are set; MARSEC 2
applies when threat condition Orange is set; and MARSEC 3 applies when
threat condition Red is set.

29Pub. L. No. 109-347, 120 Stat. 1884.

  Suicide Attacks

In the maritime domain, suicide attacks have been carried out using a
small, explosive-laden boat or vehicle that the attacker rams into a
tanker or energy facility. The intent of such an attack is maximum damage
to human or physical targets without concern for the life of the attacker.
Previous attack history underscores terrorist intentions and capability to
use small boat attacks. Moreover, intelligence experts say that the
suicide boat attack uses a proven, simple strategy that has caused
significant loss of life and significant damage to commercial and military
vessels.

Several suicide attacks have been carried out against tankers and energy
infrastructure in the Persian Gulf region. They have taken place in
restricted waterways where a ship's ability to maneuver or engage the
attackers is hampered or when a ship has stopped or moored. For example:

           o In April 2004 terrorists attacked the Al-Basrah and Khawr
           Al'Amaya offshore oil terminals in Iraq using vessels packed with
           explosives. Several oil tankers were either docked at or in the
           vicinity of the offshore terminals during the attack. Even though
           the speedboats detonated prematurely and missed striking the oil
           tankers and the offshore terminals, another small craft near the
           Khawr Al'Amaya terminal exploded when coalition forces attempted
           to intercept it, killing two U.S. Navy sailors and a U.S. Coast
           Guardsman. According to a recent study on maritime terrorism, the
           coordinated attack appears to have been part of an overall
           terrorist strategy to destabilize Iraq, and both terminals were
           shut down for 2 days, resulting in lost revenue of nearly $40
           million.30

           o Another suicide attack occurred in October 2002 when terrorists
           rammed the French supertanker Limburg as it slowed for a pilot to
           approach the Ash Shihr Terminal off the coast of Yemen. (See fig.
           7.) The resulting explosion breached the Limburg's double hull and
           ignited stored oil on board the vessel. An estimated 90,000
           barrels of oil were spilled, 1 crewman was killed, and 17 were
           injured.

           o In addition to maritime suicide attacks, terrorists have also
           targeted energy facilities on land. In February 2006, for example,
           terrorists attempted to drive vehicles packed with explosives
           through the gates of a major oil-processing facility in Saudi
           Arabia's eastern province. Al Qaeda claimed responsibility for the
           attack, which killed two Saudi guards and represented the first
           direct assault on a Saudi oil production facility.

30Michael D. Greenberg et al., Maritime Terrorism: Risk and Liability
(Washington, D.C.: RAND Corporation, 2006), 22.

Figure 7: Tanker Limburg after Terrorist Attack near Yemen

  Standoff Attacks

A second type of threat against tankers and attendant maritime
infrastructure is a standoff missile attack using a rocket, mortar, or
rocket-propelled grenade launched from a sufficient distance to evade
defensive fire. Standoff missile attacks have been aimed at military ships
in ports in the Persian Gulf, but these kinds of attacks also represent a
serious type of threat against tankers. Terrorists launched such an attack
using Katyusha rockets in 2005, narrowly missing two U.S. naval ships
moored at a Jordanian port. Compared to suicide attacks, standoff attacks
are easier to execute, but are less likely to be as effective, according
to intelligence experts. The range, size, and accuracy of explosive
projectiles used in such an attack could vary considerably.

  Armed Assaults

Armed assaults, particularly at critical shipping chokepoints, represent a
third major type of threat to tankers along the energy supply chain,
according to the International Maritime Bureau. These attacks on tankers
and energy infrastructure have taken place where maritime security is
lacking and they have been carried out in most cases by pirates seeking to
gain control of the ship for financial gain, including petty theft and
kidnapping of crew for ransom.31 Pirate attacks against tankers and cargo
ships have taken place in numerous locations, including off the coast of
Somalia, in the Gulf of Guinea and Persian Gulf, and along the Strait of
Malacca. According to officials at the International Maritime Bureau, oil
tankers account for about one-quarter of all pirate attacks. Pirate groups
armed with automatic weapons have seized tankers in the Strait of Malacca
and off the coast of Somalia. For example, in March 2006 pirates armed
with automatic weapons hijacked a tanker off the coast of Somalia and
demanded ransom payments for the release of the ship and its crew. Also,
attacks on offshore oil facilities have become commonplace in Nigeria,
where local rebel groups claim to be fighting the Nigerian government over
control of oil revenue. While no attacks on international oil tankers off
the coast of Nigeria have occurred to date, militant groups in the area
have threatened to escalate the conflict by attacking ships.

  Other Types of Threats Are Considered Less Likely

There are other types of threats besides the three above, but assessments
we reviewed and officials we met with indicated these other scenarios were
less likely to occur. Two examples cited were the following:

           o Crew conspiracies. Coast Guard intelligence reports suggest a
           hypothetical possibility that crew members (or persons posing as
           crew members) could conspire to commandeer a tanker with the
           intent of using the vessel as a weapon or disrupting maritime
           commerce. Vessel operators and industry groups do not consider
           this to be a serious threat, especially given the technical
           complexity of modern gas carriers and large oil tankers and the
           extensive vetting process for crew on these kinds of vessels. Crew
           conspiracy could also result in situations where oil tankers or
           gas carriers could be used to transport terrorists. Intelligence
           officials estimate that the number of overall stowaways on all
           vessels entering U.S. ports was expected to average 30 per month
           in 2005. There have been cases of stowaways with suspected
           terrorist connections on board U.S.-bound vessels since 2000.

           o Collisions. One scenario related to armed assaults involves
           pirates or terrorists hijacking a large ship and ramming it into a
           tanker, an energy facility, or critical infrastructure such as a
           bridge. Although such scenarios require gaining control of a ship,
           terrorists' successful takeover of aircraft in the September 11
           attacks demonstrate that such plans could be feasible. To date,
           there have been no known cases of terrorists intentionally using a
           vessel as a weapon, but there have been some close calls in
           pirate-prone areas. Security experts point to an example in 2003
           in which a group of pirates gained control of the chemical tanker
           Dewi Madrim in the Strait of Malacca. Once at the tanker's helm,
           the pirates altered the ship's speed, disabled communications, and
           steered the ship for over 1 hour before escaping with equipment
           and technical documents.

31Piracy is defined by the International Maritime Bureau, a division of
the International Chamber of Commerce that tracks and reports pirate
attacks , as, "an act of boarding or attempting to board any ship with the
apparent intent to commit theft or any other crime and with the apparent
intent or capability to use force in the furtherance of that act."

  Intelligence Reviews Indicate Threats Are Likely to Persist

Reports we reviewed and assessments we received indicate that the threat
of seaborne terrorist attack on maritime energy tankers and infrastructure
is likely to persist. The information we reviewed and discussions we had
with agency officials indicate the greatest degree of concern remains
overseas. For example, in October 2006 it was reported that there were
threats against Saudi Arabia's Ras Tanura oil terminal, which is the
world's biggest offshore oil facility, as well as a refinery in Bahrain.
As part of its mission in the area, the U.S. Navy, together with coalition
forces, continues to patrol areas containing critical maritime energy
infrastructure to ensure their security, and works with regional navies in
the Persian Gulf to improve their ability to enforce maritime security. In
addition, Coast Guard maritime threat assessments we reviewed consider the
threat of terrorists attacking vessels outside U.S. territorial waters to
be significant. According to these reports, future maritime terrorist
attacks are most likely to occur in the Persian Gulf, Red Sea,
Mediterranean Sea, and Southeast Asia.

Domestically, intelligence reports and other assessments continue to
disclose incidents that demonstrate the need for continued concern about
potential terrorist threats. For example, two Coast Guard admirals
testified that the nation is subject to an estimated four malicious
maritime incursions around the country each week.32 These incursions
represent opportunities to infiltrate homeland security and could cause
widespread human, economic, and environmental damage in our nation's
maritime points of entry. Most of these incursions to date have involved
vessels bringing illegal immigrants, drugs, or other contraband into the
country.

Possible Consequences of an Attack Include Public Safety, Environmental, and
Economic Impacts

A successful attack on an energy commodity tanker could have substantial
public safety, environmental, and economic consequences. Public safety and
environmental consequences vary by commodity. LNG and LPG are highly
combustible and pose a risk to public safety of fire and explosions, but
their environmental impact would be minimal since they dissipate in a
short period of time. Crude oil and heavy petroleum products do not
dissipate quickly and must be removed from the water, posing a greater
environmental than public safety risk. Economic consequences of an attack
could be substantial, not so much because of the loss of a tanker or its
cargo, but because of the greater shock to the economy, particularly if
major transit routes, key facilities, or ports are closed. Price spikes
that reflect fears or expectations about the price and supply of energy
commodities could also be significant.

  Public Safety and Environmental Consequences Vary by Commodity

LNG and LPG spills pose primarily a public safety hazard to structures and
people because of the potential for fires and explosions. These gaseous
energy commodities are transported as liquids either by cooling or by
pressurizing the gas. If spilled, they will return to their gaseous state,
causing vapor to form above the spill. It is these vapors that will burn.
Further, the vapors will drift away from the site of the spill if not
immediately ignited by a source such as an open flame or strong static
charge. Once ignited, the fire will travel back through the vapors toward
the initial spill site and, if fuel remains, continue to burn near the
tanker.

One of the key elements of how a fire will affect the public is the amount
of heat that is radiated away from the fire. The amount of heat radiated
away from a fire is related to how smoky the fire burns--fires with a
great deal of smoke radiate much less heat because the dark smoke absorbs
the radiation. LNG and LPG vapor fires burn very cleanly, with little
smoke, and thus emit more heat than light petroleum product or crude oil
fires.

32Coast Guard Mission Capabilities: Hearing before the Subcommittee on
Coast Guard and Maritime Transportation of the House Committee on
Transportation and Infrastructure, 109th Cong. 18-25 (2006) (statement of
Rear Admiral Wayne Justice and Rear Admiral Joseph Nimmich, U.S. Coast
Guard, Department of Homeland Security).

Besides the danger of fire, there is also a danger of explosions if LNG or
LPG vapors are ignited in a confined area, such as under a dock. If the
attack on a tanker occurred in a congested port area, an explosion could
damage infrastructure or harm people located nearby. In addition to
potential explosions of confined vapors, a particular type of
explosion--called a boiling-liquid-expanding-vapor explosion--can occur on
tankers that carry pressurized cargoes, such as some LPG tankers.33 In
these tankers, the individual tanks carrying the LPG may rupture violently
if they are compromised by heat or explosion. Since LNG is not transported
in pressurized tanks, this type of explosion is not likely to occur.

Finally, people who come in contact with spilled refrigerated liquefied
gases could be burned due to the cryogenic (freeze) nature of the liquid.
LNG and LPG are both transported internationally in refrigerated tankers
that keep the gas so cold that it retains a liquid form. A spill of either
LNG or LPG could expose people close to the spill to the cold liquid and
cause cryogenic burns or frostbite. This is not likely to affect the
public, but could affect the crew on the tanker or other people located
close to the tanker.

LNG and LPG spills pose little threat to the environment because they
almost entirely vaporize in a matter of minutes or hours and disperse into
the atmosphere. If an LNG or LPG spill were ignited, there could be
localized impacts on wildlife near the fire, but few other environmental
effects.

Spills of light petroleum products, such as gasoline, diesel, and jet
fuel, can have both public safety and environmental consequences. Light
petroleum products produce flammable vapors when they are spilled. These
vapors can be ignited and could result in large, damaging fires. Further,
the vapors could drift away from the site of the spill if not immediately
ignited by a source such as an open flame or strong static charge. Once
ignited, the fire will travel back through the vapors toward the initial
spill site and, if fuel remains, continue to burn near the tanker. Besides
the danger of fire, there is also a danger of explosions if light
petroleum product vapors are ignited in a confined area, such as under a
dock. If the attack on a tanker occurred in a congested port area, an
explosion could damage infrastructure or harm people located nearby.

33There are three types of LPG tankers: fully refrigerated, partially
refrigerated, and fully pressurized, which describes the method used to
keep the LPG cargo in a liquid state. Partially refrigerated LPG tankers
keep their cargo in a liquid state with a combination of refrigeration and
pressure. Generally larger LPG tankers, like those used in international
trade, are fully refrigerated.

Spills of light petroleum products have varying environmental impacts,
depending on conditions. Light petroleum products evaporate--almost all of
the spill can evaporate in a few hours or up to a day. Consequently, light
petroleum products generally do not persist in the environment for long
unless the spill is churned by significant wave action. In that case, such
products can mix with water and will linger in the environment for much
longer periods of time. A 1996 spill highlighted the damage that can occur
when a light distillate oil is spilled in heavy wave conditions, resulting
in much of the oil mixing with water rather than evaporating. In this
case, a tank barge carrying home heating oil was grounded in the middle of
a storm near Point Judith, Rhode Island, spilling approximately 20,000
barrels of heating oil. An estimated 80 percent of the release was mixed
into the water, with only about 12 percent evaporating and about 10
percent staying on the surface of the water.34 The spill affected animals
and plants living on the sea bed, with an estimated mortality of 9 million
lobsters, 19.4 million clams, 7.6 million rock and hermit crabs, and 4.2
million fish. The oil spill resulted in a fishing closure for about 250
square miles in Block Island Sound for a period of 5 months.

Spills of crude oil and heavy petroleum products could result in
significant environmental consequences. Since these types of spills do not
readily evaporate, they can linger in the environment. Environmental
cleanup of crude oil and heavy petroleum product spills can take several
years and in some cases cost billions of dollars. According to ExxonMobil,
the company spent $2.2 billion on the Exxon Valdez cleanup. Crude oil and
heavy petroleum products can mix with water, particularly in the presence
of waves, causing small drops of water to be trapped inside the spilled
oil. This is called an emulsion and can hamper cleanup by making the
spilled oil difficult to skim off the water. This will greatly increase
the volume of the spill, since the water trapped within the oil also has
to be removed. In addition, residual oils are sometimes more dense than
water, allowing them to sink and contaminate bottom sediments. Finally,
crude oil and heavy petroleum products can coat birds and marine mammals,
both smothering the organisms and exposing them to them to hypothermia as
their feathers and fur lose the ability to insulate.

34Data are from National Research Council of the National Academies. "Oil
in the Sea III: Inputs, Fates, and Effects" the National Academies Press:
Washington, D.C. 2003. Numbers do not add to 100 percent due to rounding.

While crude oil and heavy petroleum products evaporate, they produce few
flammable vapors. For instance, less than half of a crude oil spill and 10
percent of heavy petroleum product spills will evaporate into vapors that
could burn or explode. While fire always raises concerns about public
safety, the smaller volume of vapors available to burn would result in
small fires that are less likely to endanger the public.

  Blockage of Key Transit Routes, Key Facilities, or Ports Could Cost Billions

Although the Exxon Valdez accident demonstrates that even one spill can
create substantial environmental cost, an attack that affects only a
single tanker is unlikely to have significant consequences on the overall
economy, other than a relative short-term market price increase. One
tanker carries a small percentage of the total daily demand for a
commodity. As mentioned above, Very Large Crude Carriers typically carry
more than 2 million barrels of oil per voyage, which is about 10 percent
of U.S. daily oil consumption. In most cases, the relatively small volume
in an individual tanker could be replaced with other imports or from
domestic storage. Two examples show the relatively small effect on supply
if the broader supply network is not substantially affected:

           o The approximately 240,000 barrels of oil released into Prince
           William Sound by the Exxon Valdez represented about 20 minutes of
           total U.S. oil consumption in 1989. The spill's actual disruption
           was somewhat greater: According to the Department of Energy, the
           incident actually resulted in an oil supply disruption of 13
           million barrels of oil over 13 days, because the spill restricted
           tanker transport in Prince William Sound and the volume of oil
           piped from the Alaskan North Slope also had to be reduced. Still,
           even this 13 million barrel disruption represented only about 18
           hours of total national consumption.35

           o More recently, an approximately 6,300-barrel oil spill in
           November 2004 significantly reduced tanker traffic on a stretch of
           the Delaware River for more than a week. As a result, a nearby
           refinery had to reduce production of refined products because of
           reduced crude oil availability. The oil spill also threatened to
           contaminate the water intake system of a nuclear power plant along
           the river, which was temporarily shut down. Despite these
           reductions in energy supply, gasoline prices actually dropped in
           the days after the oil spill.

35As we will discuss later in this report, however, concerns about supply
disruption can have an effect on price, and in the case of the Exxon
Valdez spill, price was temporarily affected.

The loss of a tanker carrying crude oil or heavy petroleum commodities
will pose additional economic costs for ship replacement and environmental
cleanup. Tankers can cost about $150 million, and the lost cargo could
cost over $100 million dollars more. The Delaware River oil spill cleanup
cost about $175 million over the course of 1 year. As the $2.2 billion
Exxon Valdez spill cleanup illustrates, a larger spill or a spill in a
more sensitive ecological zone could cost much more.

A much more significant impact could occur if an attack on a tanker
resulted in the closure of a port, damage to a key facility, or long
interruption of a key transit route. A successful attack while a tanker
was docked, for example, could result in damage to a key facility. Even if
a port were not closed altogether, the Coast Guard could increase the
MARSEC level at one or more ports or industries to MARSEC 3--the highest
level. The Coast Guard noted in the Federal Register that MARSEC Level 3
will involve significant restriction of maritime operations that could
result in the temporary closure of individual facilities, ports, and
waterways, in either a region or the entire nation. Depending on the
nature of the specific threat, this highest level of maritime security may
have a considerable impact on the stakeholders in the affected ports or
maritime areas. The ability to estimate the costs to business and
government for even a short period at MARSEC Level 3 is difficult to do
with any level of accuracy or analytical confidence due to the infinite
range of threats and scenarios that could trigger MARSEC Level 3. The
Coast Guard also noted that the length and the duration of the increased
security level to MARSEC Level 3 will be entirely dependent on the scope
of transportation security incidents or disasters that have already
occurred. The Coast Guard expects MARSEC Level 3 to increase the direct
costs to businesses attributable to increased personnel or modified
operations, and it also expects indirect costs to society of the ``ripple
effects'' associated with sustained port closures would greatly outweigh
the direct costs to individual businesses.

The scale of these effects can perhaps be seen in several hypothetical
examples, both international and domestic.

           o Strait of Hormuz. Each day, tankers transport 20 percent of
           global daily oil consumption--about 17 million barrels of
           oil--through the Strait of Hormuz, the narrow waterway that
           connects the Persian Gulf with the Arabian Sea. While there are
           some limited alternatives for exporting oil from the Persian Gulf
           without going through the strait, these alternatives could not
           make entirely for the amount of oil lost by closure of the strait.
           While the United States and other oil-importing countries have
           reserves of crude oil that they could use to mitigate the loss of
           supply from the Persian Gulf, oil could not be withdrawn fast
           enough to entirely make up the lost volumes. For example, while
           the U.S. Strategic Petroleum Reserve has 688 million barrels of
           oil, the send-out capacity of the reserves is only 4.4 million
           barrels per day. Other countries face similar constraints.
           Additionally, if closure of Hormuz lasted for an extended period
           of time, strategic reserves could run out or become so low as to
           be unable to mitigate any additional petroleum supply disruptions.

           o Northeast United States. An attack on a key port in the
           northeastern United States, such as Boston, could result in energy
           commodity shortages or price spikes. For instance, the LNG
           facility near Boston (in Everett, Massachusetts), is the only
           facility importing liquefied natural gas in the Northeast. LNG is
           very important to the Northeast during heating season because
           natural gas movement into the Northeast is constrained during the
           winter because existing pipelines to New England are fully
           utilized. A report prepared by the Power Planning Committee of the
           New England Governor's Conference, Inc., concluded that if LNG
           from the Everett facility and satellite operations elsewhere in
           the region is not available on a peak winter day, the region could
           have insufficient gas supply to meet the needs of all customers
           for space heating and some key electric generators. An attack that
           damages the Everett LNG facility during a cold winter could result
           in natural gas shortages or price spikes.

           o LOOP. A loss of import capacity at the LOOP could increase the
           price of crude oil and refined products. LOOP is a key energy
           facility--a terminal in the Gulf of Mexico that, according to DOE,
           accounts for more than 10 percent of total U.S. crude oil imports.
           LOOP and its storage terminals are connected to more than 50
           percent of the refining capacity in the United States. LOOP is
           also the only facility in the United States that can receive
           tankers of the ultra-large and very large types. Counteracting the
           impact of losing LOOP could involve release of oil from the U.S.
           Strategic Petroleum Reserve and lightering in other U.S. ports.36

36Lightering is the process of transferring oil at sea from a very large
or ultra-large carrier to smaller tankers that are capable of entering the
port.

While we did not find any studies on the economic consequences of closures
to energy facilities at ports, other broader reviews of port closures
identified possible loses in the billions of dollars. One study of the
2002 West Coast port shutdown, a 11-day closure of all West Coast ports
due to a labor dispute, developed estimates (based on models) for the
costs of the shutdown based on the losses in income by U.S. workers,
consumers, and producers based on trade flow, ability to ship goods, and
the inclination of consumers and industries to substitute for other,
available goods.37 The study found that for a shutdown lasting 4 weeks
(which was longer than the actual 11-day shutdown) total loses to the U.S.
economy would be about $4.7 billion, with industrial consumers bearing the
majority of that burden.38

Other studies have attempted to model the economic impact of terrorist
attacks on ports. For example, one study examined the potential effects of
a 15-day port closure at Los Angeles-Long Beach due to a radiological
bomb. It concluded that such a closure would result in regional impacts of
$138 million in lost economic output and 1,258 person-years of lost
employment.39 The study also analyzed the potential effects of a
simultaneous attack on key bridges in the port area. The study assumed
such an attack would cause a longer port closure and limited truck access
to the port for 120 days, and under that scenario, it estimated the
national economic impact at $34 billion and 212,000 person-years of
employment lost. This analysis did not consider the potential mitigating
effects of other modes of transportation for moving goods out of the port
(i.e., using rail instead of trucks), or potential trade diversion to
other ports during the crisis.

  Economic Consequences from the Psychological Market Reaction to an Attack
  Could Be Severe

Finally, psychological ramifications of an attack could affect prices and
supply. Researchers have noted that psychological market reactions to the
consequences of an event may cause individuals and firms to change their
decision-making processes, potentially causing consequences to ripple
outward from the incident itself. If the incident affects key facilities,
indirect effects could be magnified and also include businesses that are
unable to operate both in the port and elsewhere if they are dependent on
goods that move through the port. There is also the potential for
unemployment of indirectly affected businesses.

37Partick L .Anderson. "Lost Earnings Due to the West Coast Port
Shutdown--Preliminary Estimate--Anderson Economic Group LLC (Lansing,
Michigan, Oct. 7, 2002).

38The estimate is lower than some other studies that examined the incident
because it took into consideration that cargoes were simply delayed, and
not lost entirely.

39Peter Gordon; James Moore II; Harry Richardson; and Pan Qisheng, "The
Economic Impact of a Terrorist Attack on the Twin Ports of Los
Angeles-Long Beach" in The Economic Impacts of Terrorist Attacks, Peter
Gordon, James Moore II, and Harry Richardson, eds., (Northampton,
Massachusetts, 2006).

The movement of gasoline prices after the Exxon Valdez spill is an
illustration. Although the actual disruption in supply was relatively
small, the oil spill sent shock waves through oil markets, particularly
those most dependent on oil from the Alaskan North Slope along the West
Coast. In the first week after the oil spill, spot market prices of
unleaded regular gasoline increased $0.50 from $0.68 per gallon to $1.18
per gallon, a 74 percent increase due to fears of an extended closure of
oil from the Alaskan North Slope. In the following weeks, however, prices
began to decrease, hitting $0.99 on April 7 (2 weeks after the spill) and
$0.82 on April 14 (3 weeks after the spill). Thus as markets realized that
the supply shortage would be short lived, prices dropped sharply. The
Department of Energy concluded in its analysis of the incident that the
temporary loss of Alaskan North Slope supplies resulted in a perception of
tight oil markets rather than a significant change in fundamental supply
and demand factors.40

Although Stakeholders Are Taking Protective Measures, Implementation Challenges
Pose Difficulty Both Abroad and at Home

Many efforts are under way, both internationally and domestically, to
protect energy commodity tankers and their attendant facilities, but
significant challenges to the success of these efforts may limit the
effectiveness of these actions. These challenges are evident in protecting
the loading and transit of tanker shipments. In these settings, a broad
range of international stakeholders is involved, including IMO, foreign
governments, vessel and facility operators, and U.S. government agencies.
To help protect the international maritime supply chain, signatory
governments are responsible for implementing the requirements of IMO's
ISPS Code into law, many facility and vessel operators have taken steps to
implement ISPS Code requirements, various industry organizations have
reported security conditions in ports around the world to better inform
their members, and the U.S. Coast Guard and Navy have also established
their presence overseas. Challenges are evident, however, when examining
how this framework has been implemented to date. Our limited reviews at
foreign facilities showed wide disparity in the quality and extent of
security. The Coast Guard is limited in the degree to which it can bring
about improvements abroad when security is substandard, in part because
its activities are limited by conditions set by host nations. The Navy
takes actions that help to prevent attacks on tankers in transit, but is
limited in the areas where it can patrol. In U.S. ports and waterways, a
wide array of stakeholders is taking steps to protect arriving vessels,
but challenges persist here as well. Key participants include the Coast
Guard, CBP, and local law enforcement agencies. In some locations,
however, the Coast Guard has had difficulty meeting its own self-imposed
requirements for security activity. The completion of new LNG facilities
planned for a number of ports could further exacerbate the Coast Guard's
ability to meet current requirements with its current resources.

40John S. Cook and Charles P. Shirkey. "A Review of Valdez Oil Spill
Market Impacts," Petroleum Marketing Monthly, a publication of the Energy
Information Administration, March 1989.

In Spite of the Widespread Adoption of the ISPS Code, the Primary Challenge
Overseas Involves Overcoming Disparities in Security at Different Locations

The ISPS Code lays out the international regime for securing port
facilities and commercial vessels. Signatory governments of port and flag
states are responsible for ensuring compliance with the ISPS Code at port
facilities and vessels under their jurisdiction. Port states enter the
compliance status of their facilities directly into an IMO database. While
the ISPS Code was adopted under the auspices of IMO, IMO officials told us
they have no way of knowing if a country's port facilities are truly in
compliance. IMO merely reports information submitted by member governments
and does not verify its accuracy. Additionally, there is no other
internationally recognized mechanism for third party review to verify
actual compliance at port facilities. Without third party compliance
review, it is extremely difficult to determine if ports are secure against
terrorism.

Within some countries, the actual security measures can vary greatly from
port facility to port facility, as indicated both by our own visits to
foreign facilities and our discussions with agency and shipping officials.
For example,

           o In one country we visited, we observed varying degrees of
           implementation of measures to control access at different port
           facilities. One facility we visited had security cameras, fences,
           guards checking perimeter security, and identification checks for
           access control. Here, we were challenged by guards regularly as we
           passed through gates, even though facility officials were
           escorting us. At another facility, however, someone came to the
           guard station only when our escort signaled for him to come over,
           and fences were collapsed in some places and had holes in others.
           o Vessel operators we met with also described differences in
           security at different ports where they load. These operators said
           they use many sources of intelligence to determine their security
           stance when entering a port. Some operators said they can call on
           the knowledge of their own intelligence sources in port states,
           including contacts with intelligence agencies. Members of
           Intertanko, an international industry organization, can access its
           database of port security conditions, a database made up of
           reports from vessel operators that experience these conditions
           when they stop at various ports. In this database, operators
           reported that some ports security conditions are substantially
           worse than would be expected for an ISPS Code-compliant facility.
           In such cases, they reported taking steps that went beyond ISPS
           requirements, such as keeping ships at security postures beyond
           those called for by the port state's declared security level.

The United States is attempting to deal with facility security lapses and
inconsistent security conditions in some overseas ports with overseas
efforts of its own. Because of congressional concern over the
effectiveness of antiterrorism measures in place at foreign ports, the
Coast Guard has implemented the International Port Security Program, which
was designed in part to assess and help improve the security at foreign
ports. This program reviews port states' implementation of port facility
security measures using established security standards, particularly the
ISPS Code. According to the Coast Guard, the ISPS Code is the benchmark
against which the effectiveness of a country's anti-terrorism measures
will be assessed. The program also reviews the country's implementation of
ship security provisions of the ISPS Code to help decide what actions to
take in reviewing that country's vessels when they call in U.S. ports.
Visits are conducted by Coast Guard personnel operating out of the
Netherlands, Japan, Singapore, and the United States. According to program
guidance, the Coast Guard officers making these visits are to exchange
information with officials of the host country, visit port facilities, and
share best practices.

The Coast Guard faces a number of challenges, however, in operating this
program. The locations to be visited are negotiated with the host country;
thus the Coast Guard team making the visit could be precluded from seeing
locations that were not in compliance. Coast Guard officials said
International Port Security Program officers typically make up to three
visits to a country, each lasting about a week. Their assessments are thus
based on conditions observed when their visits occur. We are currently
conducting a separate review of the Coast Guard's international programs,
and the report we issue will include a more complete review of the
effectiveness of its International Port Security Program.

  U.S. Military Presence Overseas Aimed at Helping Deter Maritime Terrorist
  Attacks

In certain locations, the Navy and Coast Guard have also taken more direct
action to protect oil terminals--most notably in Iraq. The Navy has set
security zones (zones where unauthorized vessels will be fired upon)
around Iraqi oil terminals and stationed warships and patrol boats around
the terminals (see fig. 8). The Navy has also stationed security personnel
on the terminal platforms.

Figure 8: Tanker Approaching an Iraqi Oil Loading Terminal as U.S. Warship
Patrols Nearby

  State Department Officials Review Crew Member Visa Applications Overseas to
  Prevent Entry of Terrorists

An additional protective measure taken overseas is the effort of State
Department (State) officials to help ensure that terrorists cannot gain
entry to the United States by working as seafarers on tankers or other
vessels. State Department regulations eliminated crew list visas and
required all crew members seeking to enter the United States to apply for
individual crew visas.41 These visas are usually presented at U.S. ports
of entry, but they can only be obtained abroad. Applicants must make
appointments with State Department officials located at embassies and
consulates and be interviewed. They must submit background information,
fingerprints, and sufficient documentation to show they are employed by a
shipping company. This information is then checked against a State
Department database that contains records provided by numerous agencies
and includes information on persons with visa refusals, immigration
violations, criminal histories, and terrorism concerns. We reported in
September 2005 steps State has taken since September 11, 2001, to improve
the visa process as an antiterrorism tool as well as some of the
additional actions that we believed State could take to further strengthen
the process.42 According to the State Department, it has corrective
actions under way that it believes will address the recommendations.

41Crew list visas are nonimmigrant visas that cover all crew members of a
vessel or aircraft included on a master list submitted to State Department
officials.

While Vessels Are in Transit, the Primary Challenge Involves Patrolling the Vast
Distances Involved

Many countries help to protect energy commodity tankers by patrolling the
sea transit routes. For example, Combined Task Force 150, which as of
December 2006 included navies of the United States, Canada, France,
Germany, Italy, Pakistan, and the United Kingdom, conducted operations in
the Arabian Sea, Gulf of Oman, Gulf of Aden, Indian Ocean, and Red Sea to
secure the waterways and prevent piracy and terrorism (see fig. 9).43
Naval and coast guard forces of Indonesia, Malaysia, and Singapore patrol
the Strait of Malacca, a major choke point in the shipment of energy
commodities. Improvements in security in the strait led to its removal
from a list of areas in which Lloyds vessel insurers could raise premiums
due to severe security risks. To protect their ships in areas of known
danger, tanker operators said they are also modifying their normal
practices. For example, tanker operators told us that they have directed
their vessels to travel much further off the shore of Somalia than they
would ordinarily. Near Somalia, the International Maritime Bureau
recommended in 2005 that commercial vessels stay 200 miles away from the
coast, and the U.S. Maritime Administration and Coast Guard issued similar
guidance for U.S.-flagged vessels. In piracy-prone waters, such as the
Strait of Malacca, actions include sailing with all lights on, using extra
lookouts, and equipping crews with fire hoses to prevent or repel
boarders.

42See GAO, Border Security: Strengthened Visa Process Would Benefit from
Additional Management Actions by State and DHS, [71]GAO-05-859 (Washington
D.C.: Sept. 13, 2005).

43The Navy and Coast Guard also work with foreign nations to improve their
ability to prevent terrorist attacks in the waters around their countries.
In exercises such as South East Asia Cooperation Against Terrorism
(SEA-CAT) and Cooperation Afloat Readiness and Training (CARAT), the Navy
works to improve other countries' skills and to increase interoperability
among nations. In these exercises the forces from the different countries
practice boarding tactics and techniques and other skills. The Navy and
Coast Guard also take part in multinational conferences, such as the
Alameda Conference on East Asian and Pacific Region Maritime Security in
February 2006. This conference, sponsored by the Coast Guard, was aimed at
coordinating maritime security assistance for the Strait of Malacca region
and beyond. Another conference, held in Benin and sponsored by the Navy,
was aimed at improving security around the Gulf of Guinea.

Figure 9: U.S. Warship Engaging Suspected Pirate Vessel near Somalia

While these actions have had some success in securing transit routes, the
vast areas to be patrolled and the small number of ships available present
the military forces of the world with great challenges in protecting the
sea lanes. For example, a multinational task force of military vessels
that patrols the Arabian Sea, Gulf of Oman, Gulf of Aden, and northwestern
Indian Ocean is made up of about 15 ships. The navies of regional
countries also patrol near their shores, but in areas such as the Horn of
Africa this multinational task force is the only major presence. Because
tankers travel so frequently and so few naval ships are available to be on
station, naval protection cannot be offered for all those who travel in
these waters.

Besides patrolling the waters, tracking the movement of tankers is another
way to monitor them. A recently passed IMO requirement calls for most
commercial vessels, including tankers, to begin transmitting
identification and location information on or before December 31, 2008, to
SOLAS contracting governments under certain specified circumstances. This
will allow the vessels to be tracked over the course of their voyages.
Under this requirement, information on the ship's identity, location,
date, and time of the position will be made available to the ship's flag
state, the ship's destination port state, and any coastal state within
1,000 miles of the ship's route. For ships approaching the United States,
an extensive tracking program is already in place. The Coast Guard
currently tracks ships as they approach the U.S. coastline and is
developing programs for longer-range tracking.44

In U.S. Waterways and Ports, the Primary Challenge Involves Coping with Limited
Resources and a Growing Security Workload

Domestically, many agencies and other stakeholders have taken steps to
develop and implement plans for helping ensure the security of maritime
energy commodity shipments. The Coast Guard's primary challenge is
utilizing its limited resources to meet its security workload. Since the
terrorist attacks of September 11, 2001, Coast Guard field units have seen
a substantial increase in their security workload.45 Coast Guard field
units at some ports have not always been able to meet their maritime
security activity requirements. Moreover, the Coast Guard's resource
demands are expected to grow as more facilities for importing LNG come on
line, increasing the number of shipments requiring Coast Guard protection.

The efforts to provide security over energy commodity shipments arriving
at U.S. waterways and port facilities involve a wide range of federal and
local agencies as well as owners and operators of the facilities that
receive the shipments. Much of the framework for port security is
contained in MTSA. DHS, which is the main agency responsible for homeland
security responsibilities contained in MTSA, has assigned most of the
responsibilities to the Coast Guard.46 To carry out this responsibility,
as well as the nation's port state oversight of foreign-flagged vessels,
the Coast Guard's efforts range from boarding ships and escorting those
shipments of greatest concern to patrolling port waters and overseeing the
security actions undertaken by vessel and facility operators. CBP has the
lead role in ensuring that only authorized persons onboard tankers come
ashore when calling on U.S. ports and that no contraband is smuggled into
the United States using the tankers.47 MTSA requires regular vulnerability
assessments of port facilities, and facility owners and operators are
required to develop and update regularly a plan for meeting basic security
requirements. Facility security plans and updates to them are to be
reviewed and approved by DHS.

44The Coast Guard has contracted with a satellite communication provider
to test the ability to receive signals up to 2000 miles from U.S. shores.

45Since September 11, 2001, the funding for the Coast Guard's homeland
security mission area--which consists of ports, waterways, and coastal
security; illegal drug interdiction; undocumented migrant interdiction;
defense readiness; and other law enforcement--has increased substantially.
It now roughly equals funding for all Coast Guard non-homeland security
mission programs. For example, in the Coast Guard's fiscal year 2007
budget request, Coast Guard requested a total of $8.4 billion, of which
$4.5 billion (54 percent) was requested for Coast Guard maritime homeland
security missions. The Coast Guard does not separate funding for security
activities to protect energy commodity tankers.

  Security Requirements Vary by Commodity

Particularly for the Coast Guard, the security activities vary greatly
depending on the type of energy commodity being carried by tankers. Two
energy commodities, LNG and LPG, are on the list of what the Coast Guard
has traditionally called Certain Dangerous Cargo (CDC).48 Coast Guard
guidance requires its field units to take certain actions to protect LNG
and LPG tankers in key port areas, which include high-population areas or
areas with critical infrastructure, such as bridges or refineries.49
Beyond protecting LNG and LPG shipments in these key port areas, Coast
Guard field units are required to implement security activities
commensurate with the extent of critical infrastructure, extent of
high-profile vessel traffic transiting through key port areas, and
availability of support of non-Coast Guard entities, such as state and
local law enforcement agencies. According to senior Coast Guard field
officials with LNG security responsibilities, LNG tanker transits have
received the greatest attention of the two, due in large part to the much
greater size of LNG tankers, the amount of hazardous cargo they are
carrying, and the public perception of the danger of LNG shipments. Many
of these security measures are now being implemented at existing LNG ports
around the country. The security measures address two phases of LNG
operations, including (1) the transit of an underway tanker through a port
and (2) the period when a tanker is moored at a receiving terminal.

46Coast Guard conducts various actions to ensure facility and vessel
operators are complying with MTSA. The Coast Guard conducts annual site
visits and spot checks to ensure facility operators are complying with
their MTSA-approved security plan--plans for access control, physical
security, and perimeter surveillance. In ensuring vessel operator MTSA
compliance, the Coast Guard conducts, among other activities, boardings to
ensure that the crew have appropriate documentation or that the vessel,
when moored, is taking steps to restrict access. Furthermore, should the
Coast Guard identify security-related deficiencies by vessel or facility
operators, it will increase the frequency of its spot inspections until it
determines that the vessel or facility operators have taken the necessary
corrective actions. We currently have another assignment under way
examining compliance with MTSA requirements in more detail. As a result,
we do not address MTSA compliance in detail in this report.

47CBP and the Coast Guard work together to handle high risk crew members
and to ensure that those crewmembers do not leave the tanker. They require
actions such as posting guards to prevent unauthorized personnel from
leaving the vessel and visits to the ship by agency personnel to ensure
high risk personnel are still on board.

48CDCs are defined in 33 C.F.R. S 160.204, a section of Coast Guard
regulations that addresses ports and waterways safety. The list primarily
includes nonenergy products that are flammable, toxic, or explosive, such
as chlorine and sulfur dioxide.

Figure 10: Safety and Security Escort for LNG Tanker

49The guidance is contained in a Coast Guard operations order called
Operation Neptune Shield (ONS). First issued in 2003 and revised
periodically since, it contains a classified set of requirements
establishing the Coast Guard's homeland security activity levels. As such,
the order sets scalable performance minimums that escalate as the MARSEC
level increases.

Figure 11: Coast Guard Enforcing Security Zone around Moored LNG Tanker

Coast Guard security activity requirements are less stringent for oil
tankers or tankers carrying many other petroleum-based products, such as
gasoline or crude oil, because they are not identified in the CDC list of
hazardous marine cargo as posing the greatest human safety risks. However,
field units do have discretion to take additional actions to protect oil
tankers and associated waterside loading facilities that are determined to
pose security concerns.

  State and Local Law Enforcement Agencies Play a Major Role in the Protection
  of Tankers and Facilities

At many ports we visited or contacted, Coast Guard field units are
receiving assistance from state and local law enforcement agencies for
help in conducting port security operations.50 These partnerships with
state and local law enforcement agencies have been encouraged by Coast
Guard headquarters. Coast Guard officials said the support has been
particularly valuable in protecting LNG carriers. For example, field units
at two of the four ports with onshore LNG importing facilities reported
using regular escort support from state or local law enforcement agencies.

50In addition to state and local law enforcement support, the Department
of Defense (Defense) can also support Coast Guard maritime homeland
security operations based on memorandums of agreement between Defense and
the Department of Homeland Security. Examples of military support provided
to the Coast Guard by Defense include conducting mine countermeasures in
ports, surveillance of terrorist maritime movements, and sustaining
Defense and Coast Guard personnel and platforms conducting offshore
operations for extended periods of time. According to a departmental
official, Defense has not been asked to provide these capabilities in a
domestic maritime terrorism incident involving tankers or energy
infrastructure to date.

In addition to state and local law enforcement agencies, facility
operators play a significant role in protecting against terrorist threats.
For those key energy ports we visited, the Coast Guard reported that the
waterfront energy facilities in those ports were taking actions to comply
with the requirements the Coast Guard established pursuant to MTSA. Of the
19 domestic waterside petroleum facilities we visited, all were reported
by the Coast Guard to be in compliance with MTSA regulations. Examples of
steps taken include key-card access systems, closed-circuit television
cameras and sensors along fencing, hardened perimeter fencing, and
reinforced gates at most access control points. Facility operators told us
they conduct regular security drills involving emergency and terrorism
scenarios and they regularly share pertinent security information with
other participants of the Area Maritime Security Committees.51 In some
cases we observed steps that go beyond MTSA requirements, such as using
radio frequency identification cards that can track the location of all
persons on facility property.

  The Coast Guard Faces Challenges Meeting Internal Security Guidance

Coast Guard records show that its field units in several of the
energy-related ports we reviewed have been unable to accomplish many of
the port security responsibilities called for in Coast Guard guidance.
According to the data we obtained and our discussions with field unit
officials, resource shortfalls were the primary reasons for not meeting
these responsibilities.

51Area Maritime Security Committees were required by Coast Guard
regulations implementing MTSA and are composed of the local Coast Guard
Captain of the Port and officials of federal, local, and state
governments; law enforcement agencies; maritime industry and labor
organizations; and other port stakeholders that may be affected by
security policies. The responsibilities of the committees include, in
part, identifying critical port infrastructure, identifying risks to the
port, developing mitigation strategies for these risks, and communicating
appropriate security information to port stakeholders.

  The Coast Guard's Near-Term Efforts to Align Requirements with Field Unit
  Capacity Have Limitations

We have noted in earlier work that the Coast Guard is ahead of many
agencies in the degree to which it has developed a sound framework for
managing its workload on the basis of risk.52 When carried out
effectively, risk management offers a way to make informed decisions about
how best to use limited resources. In the Coast Guard's case, its actions
involve a balancing act both in deciding how best to meet its various
security and nonsecurity missions agencywide, but also in weighing the
pros and cons of investing additional resources in energy commodity tanker
protection versus the wider range of other port activities that require
protection. The Coast Guard uses the requirements laid out in its guidance
to establish a port-specific security approach in which the workload
varies based on such factors as the proximity of population centers to the
port area, the extent of critical infrastructure at the port, the extent
of high-profile vessel traffic transiting through key port areas, and the
availability of support from other entities.

Given that the resource levels of some field units have limited their
ability to achieve Coast Guard security standards, the Coast Guard has
attempted to realign its security requirements to more closely match
available resource levels. Coast Guard headquarters officials meet on an
annual basis to review new risk assessments and current Coast Guard
capacity to mitigate risk. The Coast Guard also receives recommendations
from field unit commanders for introducing tactical efficiencies into
security requirements. Over the past several years, the Coast Guard has
revised its operational security guidance in two main ways:

           o Revising the standards for the amount of activity required for
           conducting some security activities. In August 2006 the Coast
           Guard substantially reduced the types of CDC-carrying vessels that
           must be escorted. The Coast Guard developed a subset list of the
           CDC commodities--called Especially Hazardous Cargo--it determined
           as posing the greatest safety and security risks. This list
           included both LNG and LPG, meaning that the activities required to
           protect them remain unchanged. However, for CDC commodities not
           included on the Especially Hazardous Cargo list, such as vinyl
           chloride, escort requirements were eliminated during normal threat
           conditions--MARSEC I.53 In all, requirements were reduced for
           about 20 different CDC commodities carried in bulk. The August
           2006 list of Especially Hazardous Cargo consisted of seven
           hazardous liquid gas or liquid commodities: acrylonitrile,
           ammonium nitrate, ammonium nitrate/fuel oil, anhydrous ammonia,
           chlorine, LNG, and LPG.

           o Providing greater operational flexibility for Area Commanders
           when resource constraints may limit the ability to meet
           requirements. The Coast Guard has introduced new tactical options
           that Area Commanders may utilize, in some cases, to accomplish
           resource intensive security activities.

52See GAO, Risk Management: Further Refinement Needed to Assess Risks and
Prioritize Protective Measures at Ports and Other Critical Infrastructure,
[72]GAO-06-91 (Washington, D.C.: Dec. 15, 2005).

The Coast Guard's methodology used to develop the Especially Hazardous
Cargo has two substantial shortcomings, however. Our specific concerns are
as follows:

           o Lack of thoroughness. To identify the highest risk CDC
           commodities, senior Coast Guard headquarters officials told us
           they reviewed available consequence analysis assessments that had
           been conducted by the Coast Guard's Special Technical Assessment
           Program and also reviewed a 2004 consequence analysis of LNG by
           Sandia National Laboratories.54 They said they also incorporated
           the views of persons with expertise in CDC commodities, including
           Coast Guard field officials. However, the Coast Guard did not
           perform consequence assessments on many CDC commodities by the
           time it created the Especially Hazardous Cargo list, and as of
           January 1, 2007, it still had not done so.

           o No systematic comparative analysis was conducted to identify and
           prioritize the highest-consequence commodities. Coast Guard
           headquarters officials acknowledged they did not conduct a
           relative risk assessment of the CDC commodities. Rather, officials
           told us they relied on the collective best judgment of Coast Guard
           experts from field units and headquarters that had significant
           experience dealing with various transportable energy and chemical
           commodities. By conducting a relative risk analysis of all CDC
           commodities, the Coast Guard would have had available more
           definitive input for determining which CDC vessels posed the
           greatest risks necessitating additional mitigation measures, which
           in this case would be an escort.

53Coast Guard policy requires Coast Guard field units to conduct
additional security activities at higher MARSEC levels.

54The objective of a consequence analysis for CDC commodities is to
predict the blast loads, damage to nearby structures, ship integrity, heat
load, potential mass casualties, environmental hazards, and potential
disruption to both commercial and military operations.

The Coast Guard is taking action to address the methodological limitations
we note. Shortly after the Coast Guard released the Especially Hazardous
Cargo list, we shared our concerns with Coast Guard officials. The Coast
Guard has since begun efforts to broaden its studies of potential
consequences to include a wide range of hazardous commodities. It
contracted with the American Bureau of Shipping to perform a comparative
analysis of the consequences of an attack on vessels carrying all
commodities on the CDC list, including LNG and LPG. The product of this
analysis is to be a ranking of the relative consequences of each of the
CDC commodities. This study is scheduled to be completed in spring 2007.
Coast Guard headquarters officials told us that following this analysis,
and subject to available funding and other considerations, they may
consider adding other commodities to the comparative analysis, such as
gasoline and jet fuel.

Going beyond the consequence analyses of hazardous commodities, the Coast
Guard has also developed a tool to compare the overall relative risk
scores of different terrorist attacks at the nation's ports. Field units
are developing risk scenarios for potential targets at their ports and
possible attack types that could be used against those targets. Using the
Maritime Security Risk Assessment Model, the units are to analyze the
different risk scenarios in relation to three key elements of risk:
reported threat of different types of attack, vulnerability of the targets
(incorporating different protective actions taken by security
stakeholders), and consequences of a successful attack (including human
health, economic, and environmental).55 Each risk scenario is to receive a
score. These risk scores are to be comparable within and between ports so
that they can be used in risk management decisions both locally and
nationally.

  Additional LNG Facilities Set to Come On Line Will Likely Pose Additional
  Challenges for Meeting Mission Requirements

In the longer term, plans for adding additional LNG facilities may require
the Coast Guard to reassess its workload yet again. Currently the Coast
Guard is faced with providing security for vessels arriving at four
domestic onshore LNG import facilities, but the number of LNG tankers
bringing shipments to these facilities will increase considerably because
of expansions that are planned or under way.56 In addition, industry
analysts expect approximately 12 more LNG facilities will be built over
the next decade (see fig. 12). Consequently, Coast Guard field units will
likely be required to significantly expand their security workloads to
conduct new LNG security missions.

55The Maritime Security Risk Assessment Model is a tool developed by the
Coast Guard to determine relative risks at ports that can be compared both
within the port and among ports.

Figure 12: Location of Operating, Planned, and Proposed LNG Marine
Terminals by U.S. Coast Guard District

56An existing LNG import facility is located in Puerto Rico.

Recognizing this coming increase in demand on security resources at LNG
ports, Coast Guard field units have been planning strategies to help meet
this demand. We found evidence that, in their planning efforts, Coast
Guard field units and affected locations are seeking assistance from a
wide range of stakeholders and sources. In particular, stakeholders
mentioned the following:

           o Manpower from state and local law enforcement. Several field
           units plan to rely on state and local agencies to conduct a
           considerable share of the new LNG workloads. While state and local
           law enforcement agencies have generally agreed to participate in
           LNG security operations, such support was largely contingent upon
           their receiving funding to cover their own resource gaps.
           According to the Coast Guard, at some ports, law enforcement
           agencies required funding to cover new capital investments, such
           as additional patrol boats, as well as operational costs such as
           funding for additional manpower or fuel for the new boats.

           o Financial help from facility operators. At some of the proposed
           LNG ports we reviewed, facility operators were also planning to
           contribute considerable financial resources to help fund new LNG
           security operations. In doing so, these companies planned to fund
           both operational and capital enhancement costs for state and local
           law enforcement agencies that had agreed in concept to support
           Coast Guard LNG security missions. At two ports where the Coast
           Guard had approved security arrangements for new LNG facilities,
           state and local law enforcement agencies had already developed, or
           were planning to develop, a cost-sharing agreement with the
           facilities. For example, at one port, a potential LNG facility
           operator made a commitment to fund most of the capital
           enhancements and operational costs of the state and local law
           enforcement agencies involved, including two patrol boats for
           state agencies, two tugboats, and communications equipment.
           Facility operators told us they were motivated to provide
           resources because they understood that doing so was essential to
           ensuring final approval of the LNG facilities. Some facility
           operators also told us that the Energy Policy Act of 2005 required
           them to develop resource cost-sharing agreements to offset state
           and local government resources used specifically for the new LNG
           facilities.57

           o Financial help through federal grants. State and local law
           enforcement agencies also reported that they were relying, in
           part, on federal grants to obtain additional resources. Of the 15
           state and local law enforcement agencies we contacted, 9 agencies
           reported applying for Port Security Grants or Urban Area Security
           Initiative grants. Law enforcement agency officials told us they
           planned to fund capital enhancements with this grant funding.
           Among those items officials planned to fund with their grants were
           new patrol boats, construction of a new boathouse and piers,
           helicopters, and security cameras to be placed along an LNG
           transit route.

57Pub. L. No. 109-58, 119 Stat. 594.

While port security grants and resource sharing agreements are expected to
address at least part of the resource needs of the Coast Guard's law
enforcement partners, the Coast Guard is likely to require additional
resources to fulfill its own new security responsibilities. To date,
however, field units have made little progress in obtaining additional
resources. Additionally, because federal law prohibits the Coast Guard
from receiving resources for its own use from private sector companies,
the Coast Guard cannot use resource-sharing partnerships to help fill its
own resource needs. Consequently, Coast Guard headquarters officials told
us they recognize that despite the efforts of Captains of the Port to
develop local solutions to new security demands, some field units will
continue to lack the resources necessary to meet their increasing LNG
security workloads.

Coast Guard headquarters officials told us they were considering two
general options to provide field units with the necessary resources to
carry out their new LNG security workloads. These two options are as
follows:

           o Redistribute resources to units with new LNG activity. Coast
           Guard officials told us they are considering shifting resources
           from ports with surplus resources to ports with new or expanded
           LNG facilities. Coast Guard headquarters officials told us,
           however, that they have not yet determined which ports would, or
           even could, provide these excess resources. Coast Guard's Atlantic
           area--where most of the new LNG activity is expected--has ordered
           districts and field units to report any excess resource capacity.
           Guided by risk management, Coast Guard headquarters may
           redistribute any available excess capacity to ports with new LNG
           security workloads. The earliest that the Coast Guard could
           reprogram assets from within the Atlantic Area is fiscal year
           2009.

           o Request new resources via budget proposals. Coast Guard
           officials also reported that they may request additional funding
           through the annual budget process to support the acquisition of
           additional boats and personnel to conduct vessel escorts and
           infrastructure patrols and the training of additional personnel.

As of January 1, 2007, Coast Guard headquarters officials told us they had
not yet developed a plan--or blueprint--for how to proceed with these two
options for addressing new LNG security resource demands. The decisions
about how to proceed may involve difficult choices, because shifting
resources to this growing need could involve trimming resources now tasked
to other homeland security duties or traditional non-homeland security
missions, and because seeking more resources involves asking Coast Guard
decision makers to weigh important, but competing, priorities. A national
plan that identifies the Coast Guard's nationwide LNG resource needs and
identifies milestones and funding needs for meeting those needs can help
the Coast Guard manage its limited resources and communicate resource
needs to Congress. It is important to complete this plan and address in it
key elements and issues so that it is both comprehensive and useful to
decision makers who must make difficult policy and budget choices.

Stakeholders Have Developed Spill and Terrorism Response Plans but Face Several
Challenges in Integrating Them

To mitigate the consequences of a terrorist attack on a tanker carrying
energy commodities, the United States has multiple plans that address
actions to be taken at the national, port, facility, and vessel levels. To
translate these plans into effective response actions, stakeholders could
face at least three main challenges. First, if an attack were to occur,
the stakeholders would need to integrate current, separate plans for the
two types of responses necessary for mitigating the consequences of an
attack--spill and terrorism responses. Second, port-level plans to
mitigate the potentially substantial economic consequences of an attack,
such as plans that set priorities for the movement of vessels after a port
reopens, could be useful. Third, stakeholders may need to obtain resources
to ensure that they can carry out the plans. At the port level, this
challenge may extend to response equipment, training, and communications
equipment. To date, federal grants for port security have been directed
mostly to prevention rather than response, but now DHS is moving toward a
more comprehensive risk-based decision-making process for allocating grant
funds. At the time of our review, DHS did not have performance measures
for determining how to allocate resources to ensure ports can effectively
respond to an energy commodities spill caused by terrorism.

Planning for Spill Response Is Largely Separate from Planning for Terrorism
Response

The planning framework for responding to spills and terrorism incidents is
extensive, involving multiple federal plans and memorandums of
understanding, port-specific plans, as well as plans for individual
facilities and vessels. As figure 13 shows, at the national level these
plans are carried out under the general framework of the National Response
Plan (NRP) but are developed into two separate lines of effort--one for
spill response, the other for terrorism response.

Figure 13: Relationship of Spill and Terrorism Response Plans and
Agreements

The NRP designates the Coast Guard as the primary agency for spill
response on water and the FBI as the primary agency for terrorism
response, and it calls on the two agencies to coordinate their responses
if the terrorist attack involves energy commodities. For this type of
incident, FBI officials stated, crime scene investigation and preservation
would take place at the same time as the environmental response activities
that would be initiated to contain the likely spill. In this situation,
the NRP notes that spill responders will provide assistance, investigative
support, and intelligence analysis for oil and hazardous materials
response in coordination with the law enforcement and criminal
investigation activities of the FBI.

As the figure shows, beneath the NRP, spill responses are coordinated by
the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), while terrorism responses are coordinated by the Terrorism Incident
Law Enforcement and Investigation Annex.58 Also at the federal level,
various other federal plans and agreements, such as the National Incident
Management System (NIMS), the Marine Operational Threat Response Plan
(MOTR), and interagency memorandums of agreement also help guide the
response. The spill and terrorism responses continue into port-level
planning, where the key guidance for spill responses is found in a port's
Area Contingency Plan (ACP) and the key guidance for terrorism responses
is found in the port's Area Maritime Security Plan (AMSP). Table 3
provides a brief description of the various plans and agreements found in
figure 13.

58Preexisting interagency plans are incorporated into sections of the NRP
as supporting operational plans. The National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) is the subplan that serves as the basis
for federal spill response activities under the NRP section for spill
response (Emergency Support Function #10).

Table 3: Federal and Port-level Plans and Agreements Governing Response to
Spills on Water and Terrorist Attacks

Plans and agreements       Description                                     
Federal plans and                                                          
agreements                                                                 
National Response Plan     As the umbrella plan for federal response, it   
(NRP)                      provides a structure for plans at the national  
                              and local levels. It also incorporates          
                              interagency plans for responding to spills and  
                              terrorist attacks. If a terrorist attack        
                              results in an energy commodity spill, calls for 
                              the Coast Guard and FBI to coordinate their     
                              response efforts, with the FBI as lead agency.  
Emergency Support Function Lays out planning and operational activities at 
#10:                       the federal and port levels for spills, and     
                              designates the Coast Guard as the lead federal  
National Oil and Hazardous agency for spills on water. The Coast Guard has 
Substances Pollution       entered into agreements to coordinate spill     
Contingency Plan (NCP)     response activities with at least 16 federal    
                              departments and agencies, (e.g., the Department 
                              of Defense may provide assistance through its   
                              Supervisor of Salvage and Diving).              
Terrorism Incident Law     Provides guidance for how federal agencies are  
Enforcement and            to coordinate with state and local responders.  
Investigation Annex        References federal terrorism response policies, 
                              priorities (with public safety receiving top    
                              priority), and tasks to be performed in         
                              responding to an attack, such as setting up     
                              interagency command and communications groups.  
                              Identifies the FBI as responsible for           
                              coordinating and conducting all federal law     
                              enforcement and criminal investigation          
                              activities after a terrorist attack.            
National Strategy for      Designed to integrate and synchronize existing  
Maritime Security          department-level strategies to ensure their     
                              effective and efficient implementation, as well 
                              as align all federal government maritime        
                              security programs and initiatives into a        
                              comprehensive and cohesive national effort.     
Maritime Operational       Aids coordination of U.S. government response   
Threat Response Plan       to threats against the United States and its    
(MOTR)                     interests in the maritime domain by             
                              establishing roles and responsibilities for     
                              government response.                            
National Incident          Used by the NRP as the framework for standard   
Management System (NIMS)   incident command and management processes,      
                              protocols, and procedures for federal responses 
                              to any incident, including terrorism, and       
                              outlines coordination steps.                    
Memorandums of             1979: Agreement between the Coast Guard and     
understanding (MOU)        FBI, aimed at ensuring coordinated efforts,     
                              eliminating delays in response time, and        
                              ensuring continued development of procedures    
                              and contingency plans.                          
                                                                              
                              2002: Agreement between the Coast Guard,        
                              Department of Justice, and other members of the 
                              National Response Team, aimed at facilitating   
                              coordination of criminal investigations,        
                              enforcement, and environmental response         
                              activities.a                                    
Port-level plans           
Area Contingency Plan      Describes what needs to be protected in the     
(ACP)                      event of an emergency and how to protect it,    
                              what resources are available to respond, and    
                              the desired outcomes from the spill response.   
Facility Response Plan     Describes how the facility will respond to,     
(FRP)                      contain, and clean up a spill.                  
Vessel Response Plan (VRP) Describes how the vessel will respond to,       
                              contain, and clean up a spill.                  
Area Maritime Security     Describes how port stakeholders will deter a    
Plan (AMSP)                terrorist attack or other transportation        
                              security incident, or secure the port in the    
                              event such an attack occurs.                    
Facility Security Plan     Describes how the facility will prevent an      
(FSP)                      incident and secure the facility when an attack 
                              occurs at the facility or on a vessel docked at 
                              the facility.                                   
Vessel Security Plan (VSP) Describes how the vessel will prevent an        
                              incident and secure the vessel when an attack   
                              occurs on the vessel.                           

Source: GAO's analysis of federal and port-level plans and agreements.

aThe U.S. National Response Team (NRT) is an organization of 16 federal
departments and agencies responsible for coordinating emergency
preparedness and response to oil and hazardous substance pollution
incidents. The NRT is a planning and coordinating body under the National
Contingency Plan and provides national-level policy guidance prior to an
incident.

At the federal level, in addition to the plans and agreements governing
spill and terrorism responses in table 3, other guidance and requirements
related to economic recovery include the following:

           o The Maritime Infrastructure Recovery Plan (MIRP)--a supporting
           plan for the National Strategy for Maritime Security--contains
           procedures for managing the economic consequences and recovery of
           maritime infrastructure after a transportation security incident,
           such as a terrorist attack. The MIRP provides strategic-level
           guidance for national, regional, and local decisionmakers to set
           priorities for restoring the flow of domestic cargo. The plan
           recommends that the Captain of the Port consider key shipping
           channels and waterways for homeland security; military traffic;
           and commercial operations; key landside transportation
           infrastructure, such as tunnels and bridges; and other
           infrastructure key to maintaining continuity of operations in the
           port.

           o The SAFE Port Act of 2006 requires the Secretary of Homeland
           Security to develop protocols for the resumption of trade after a
           transportation security incident, such as a terrorist attack.59
           The protocols must include a plan to redeploy resources and
           personnel as necessary to reestablish the flow of trade, and
           appropriate factors for establishing prioritization of vessels and
           cargo that are critical for response and recovery, including
           factors related to public health, national security, and economic
           need.

59 6 U.S.C. S 942.

At the port level, under the Oil Pollution Act of 1990 and the Maritime
Transportation Security Act of 2002, the Captain of the Port is to
establish both spill and terrorism response plans.60 In doing so, the
Captain of the Port must identify local public and private port
stakeholders who will develop and revise separate plans for marine spills
of oil and hazardous materials (ACP) and for terrorism response (AMSP).
Both plans call for coordinated implementation with other plans, such as
the response and security plans developed by specific facilities or
vessels. Local stakeholders are organized into two separate groups: an
area committee for spill response (Area Committee), which develops the
ACP, and an area committee for terrorism response (Area Maritime Security
Committee), which develops the AMSP--both committees are chaired by the
Captain of the Port. Some stakeholders, such as port authorities, fire
departments, and facilities in the port, may be part of both committees,
while others may be part of only one committee. For example, oil spill
response organizations are likely to be involved only with spill response
planning.

If an energy commodity tanker was attacked while moving through a U.S.
port or while docked, a range of response activities would need to occur
to address the consequences. Figure 14 illustrates how incident response
would potentially take place following an attack and a subsequent spill.

60 MTSA calls for plans "to deter and minimize damage from transportation
security incidents," such as terrorist attacks. For the purposes of this
report the phrases "terrorism response plans" and "terrorism response" are
substituted.

Figure 14: Incident Response Sequence When an Attack Occurs Resulting in a
Spill

As figure 14 shows, incident response includes three separate but
overlapping activities, as reported by port stakeholders:

           o Initial incident response for public safety and establishment of
           the incident command site. Because energy commodity tankers carry
           flammable and/or hazardous materials, the first responders are
           likely to be area fire and police departments; receiving facility
           personnel may also respond. The first concern is always public
           safety, and therefore the fire department would begin rescuing
           victims and addressing the probable fire. Law enforcement agencies
           would secure the perimeter of the scene to prevent potential
           follow-on attacks as well as to prevent the public from moving too
           close to the attack location--both to protect the public and to
           maintain the crime scene for subsequent investigation. Initial
           responders would also establish a multi-agency incident command
           site near the location of the vessel, where all responding
           agencies with jurisdictional responsibilities for spill and
           terrorism response would congregate to manage the operations.

           o Crime scene preservation and investigation, and initial spill
           response activities. As public safety operations continue, law
           enforcement agencies would determine whether terrorism had caused
           the spill, and if so, would conduct an investigation at the same
           time that life safety operations are continuing and spill response
           operations are beginning. Investigations would involve crime scene
           and perimeter control, determining if additional devices may be
           present and disposing of them, and apprehending suspects. Spill
           operations would initially involve the laying of a containment
           boom to protect the surrounding environment from contamination
           caused by the spill. Law enforcement and spill response
           organizations will need to coordinate their activities because
           actions to mitigate environmental consequences can potentially
           damage crime scene evidence.

           o Spill and port recovery activities. Once the resulting spill is
           contained, incident commanders would determine their next steps,
           depending on conditions. Spill recovery may include intentionally
           burning contained oil, allowing the commodity to evaporate, using
           chemicals to disperse the spill, or using mechanical recovery to
           skim the oil out of the water. If a terrorist attack had occurred,
           the crime scene investigation would have to be conducted before
           the port could be fully restored for cargo and passenger ships.

According to FBI officials, the FBI would work with the Coast Guard to get
access to the incident site as soon as possible to obtain all crime scene
evidence possible, without interfering with the response.

These complex activities would be carried out by many different federal,
state, and local agencies. Figure 15 illustrates one possible scenario for
spill and terrorism response actions and shows some of the agencies that
might carry out these actions.

Figure 15: Potential Actions Taken to Respond to an Attack on an Energy
Commodity Tanker

Federal Agencies and Local Ports Could Face Challenges in Integrating Spill and
Terrorism Response Plans, Planning for Economic Response, and Obtaining Needed
Resources

In the event of a terrorist attack on an energy commodity tanker, federal
agencies and port communities could face challenges in integrating their
spill and terrorism response plans. Ports could face two additional
challenges: planning for economic response activities and obtaining the
necessary resources to respond to a terrorist attack on an energy
commodity tanker.

  Federal Agencies and Ports Could Face Challenges in Integrating Spill and
  Terrorism Response Plans

As we have noted in prior reports, a fundamental goal of emergency
preparation and response is the ability to respond to emergency incidents
of any size or cause with well-planned, well-coordinated, and effective
efforts that reduce the loss of life and property and set the stage for
recovery. In our September 2006 report on the preparation for and response
to Hurricane Katrina, we stated that fundamental to effective preparation
and response are (1) clearly defined, clearly communicated, and clearly
understood legal authorities, responsibilities, and roles at the federal,
state, and local level, and (2) identification and development of the
capabilities needed to mount a well-coordinated, effective response to
reduce the loss of life and property and set the stage for recovery.
Providing these fundamentals requires effective planning and coordination,
including detailed operational plans, and robust training and exercises in
which needed capabilities are realistically tested, assessed, and problems
identified and addressed.61 With regard to potential attacks on energy
commodity tankers in U.S. ports, the ports could face challenges if roles
and responsibilities have not been clearly defined, communicated, and
understood and if needed capabilities have not been fully identified and
appropriately tested. The National Preparedness Goal uses 15 scenarios to
identify 37 capabilities and the associated critical tasks needed to
respond to incidents of national significance--those that go beyond the
state and local levels and require a coordinated federal response.
However, the scenarios used to identify these capabilities do not
specifically encompass the capabilities needed for responding to attacks
on oil, gas, or other tankers in American ports.

61GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and
Accountability Controls Will Improve the Effectiveness of the Nation's
Preparedness, Response, and Recovery System, [73]GAO-06-618 (Washington,
D.C.: Sept. 6, 2006).

The NRP calls upon the Coast Guard and the FBI to coordinate their
response in the event of a terrorist attack on an oil or hazardous
materials tanker. However, the agencies cannot be assured that their joint
response, concurrently implementing the numerous existing plans, will be
effective unless they have developed a detailed operational plan that
integrates their spill and terrorism responses and have tested these
responses in joint exercises. According to headquarters and field office
Coast Guard and FBI officials, coordination would be managed through the
use of the unified command structure in the National Incident Management
System and the other general coordination mechanisms in the NRP and the
MOTR. However, the unified command structure and the NRP are generally not
specific in explaining how they will be made operational following an
attack. As we have recently reported, the implementation of the NRP
following Hurricane Katrina identified concerns with coordination within
and between federal government entities using the plan.62 We recommended
the development of detailed operational plans for the NRP and its
annexes.63

In addition to having operational plans, agencies should conduct joint
exercises that simulate an attack and the agencies' responses.64 Without
such exercises, it would be questionable whether joint Coast Guard and FBI
activities would proceed as planned. Simulation exercises help determine
the strengths and weaknesses of various plans and the ability of multiple
agencies or communities to respond to an emergency incident. According to
DHS's Homeland Security Exercise and Evaluation Program, well-designed and
executed exercises are the most effective means of (1) testing and
validating policies, plans, procedures, training, equipment, and
interagency agreements; (2) clarifying and training personnel in roles and
responsibilities; (3) improving interagency coordination and
communications; (4) identifying gaps in resources; (5) improving
individual performance; and (6) identifying opportunities for improvement.

62USCG headquarters officials reported that, since the end of GAO's audit
work, the USCG and the FBI have jointly responded in two maritime cases
that reflected a nexus between environmental response and transnational
crime/terrorism: M/V Tong Chang and M/V Dubai Express. GAO was not able to
review these cases and cannot comment on them because they occurred after
audit work completion. In addition, USCG headquarters officials stated
that, at the direction of the President, DHS, DOJ and DOD completed the
Maritime Operational Threat Response Forces (MOTR Forces) plan, in July
2007. According to USCG headquarters officials, the MOTR Forces plan is a
supporting plan to the base MOTR, designed to permit the interoperability
and synchronization of DHS, DOJ, and DOD maritime competencies and
capabilities. GAO was not able to review and cannot comment on the MOTR
Forces support plan because it was developed after audit work completion.

63 [74]GAO-06-618 .

64Specific details regarding exercising spill and terrorism response plans
were provided in the Sensitive Security Information version of this
report.

The value of joint simulation exercises in uncovering problems has been
demonstrated in the results of the largest national, state, and local
interagency terrorism response exercise ever conducted. This
exercise--called TOPOFF 3--was conducted in April 2005 and included
explosions and hazardous materials releases in multiple locations around
the nation (none of which were on the water). According to the Coast Guard
after-action report for one of the sites, the FBI (1) never fully
integrated into and accepted the unified command called for under NIMS,
(2) did not appropriately staff the incident command post with its
representatives, (3) maintained distinctions between hazardous materials
release response and terrorism investigation actions, and (4) kept
management of the investigation separate from the incident management
overseen by the unified command. According to the after-action report,
"concurrent management of both the investigation and all other response
functions would have increased the effectiveness and efficiency of the
response effort." The report also recommended the continuation of
multiagency training and exercises to test interagency coordination
efforts.

The need for joint spill and terrorism response exercises has been
discussed, but exercises have not been conducted, at the national level.
Specifically, planning discussions for the 2004 Spill of National
Significance (SONS) exercise identified the need to clarify how the FBI
fits into spill response activities when the possibility of terrorism is
present, but the exercise did not test integrating the FBI's and other
agencies' response.65 However, both Coast Guard guidance and the
Department of Justice's Inspector General have supported the need to
combine spill and terrorism response exercises. Specifically:

65The U.S. Coast Guard SONS exercise program is designed to increase the
preparedness of the entire response organization from the field level to
agency heads in Washington, D.C. This program is focused on exercising the
entire National Response System at the local, regional, and national
levels using large-scale, high-probability oil and hazardous material
incidents that result from unintentional causes such as maritime
casualties and natural disasters.

           o Coast Guard guidance recommends combining terrorism response
           exercises with other exercises, such as spill response. OPA 90 and
           MTSA implementing regulations require similar schedules for
           exercises of spill and terrorism response plans, and the
           integration of these exercises could improve response performance
           and complete required multiple response exercise mandates at one
           time, according to Coast Guard officials.

           o The Department of Justice's Inspector General in 2006 called for
           more joint exercises between the Coast Guard and the FBI in
           high-risk ports to, among other things, resolve potential role and
           incident command conflicts in the event of a maritime terrorism
           incident.66 The Inspector General's report emphasized the
           interaction of Coast Guard and FBI security units, but these
           recommendations are equally applicable for integrated exercises to
           respond to a spill caused by a terrorist attack. Once public
           safety is addressed, the Coast Guard and FBI have different
           priorities for their jurisdictional responsibilities--spill
           containment and cleanup and crime scene preservation and
           investigation, respectively. At the time of our review, FBI
           officials told us they knew of no upcoming joint planned
           exercises. FBI headquarters officials have not issued guidance to
           field office agents on integrating spill and terrorism responses
           activities within a single exercise.

Coast Guard officials told us that the MOTR is intended to delineate Coast
Guard and FBI roles in responding to an attack. FBI headquarters officials
told us that their participation in several MOTR conference calls
demonstrated that coordination among MOTR agencies is effective. These
telephone discussions may improve overall coordination, but exercises for
joint spill and terrorism responses should be conducted as often as
appropriate.67

At the port level, effectively integrating spill and terrorism emergency
responses requires all plans to operate in unison--the port spill response
plan (ACP) and the port terrorism response plan (AMSP), as well as
facility and vessel response plans. As figure 13 shows, there is no direct
operational link between the ACP and the AMSP.

66U.S. Department of Justice, Office of the Inspector General, The Federal
Bureau of Investigation's Efforts to Protect the Nation's Seaports, Audit
Report 06-26 (Washington, D.C.: March 2006).

67Specific details regarding coordination of the MOTR were provided in the
Sensitive Security Information version of this report.

Without a direct link, spill responders may not have the information they
need to respond to a spill caused by a terrorist attack. While the AMSP
has served as the terrorism response plan for ports since July 2004, it
contains sensitive security information and is therefore only available to
those individuals who are considered to have a "need to know." As a
result, nonsecurity personnel, such oil spill cleanup responders, may not
have access to these plans during an emergency. For example, only 3 of the
13 ports we visited had ACPs that addressed terrorism response within the
spill plan by incorporating terrorism incident annexes or other plans.
Consequently, the ACPs may need to have explicit sections for responding
to terrorism.68

The general lack of integration in the plans carries over to the separate
spill and terrorism response communities at the port level. As previously
discussed, individual members on these committees may not know all the
members of the other committee, but a terrorist attack on a tanker would
require them to respond simultaneously. We identified only a few examples
of joint committee meetings that enabled members to interact. For example,
Coast Guard officials told us that, since September 11, 2001, the Captain
of the Port at one location has facilitated meetings between spill
response providers and local offices of emergency management and federal
and local law enforcement agencies in order to improve response
coordination among all entities. They stated that if the spill and
terrorism response communities were formally joined, response integration
and efficiency would improve. In addition, at another location, Coast
Guard officials noted, the local area training and exercise workgroup
contains members of both the spill and terrorism response committees in
order to consolidate training and exercises. Finally, in an attempt to
improve communication, the FBI established Maritime Liaison Agents (MLA)
at the ports so that all stakeholders would know the local agent in the
event of an incident.69 At some ports we visited the spill responders knew
who the FBI agent was and at other ports they said they did not.

68Following the September 11, 2001, terrorist attacks, Environmental
Protection Agency (EPA) guidance recognized that local emergency spill
planning committees should consider the possibility of terrorist events as
they review existing plans and consider how to incorporate
counterterrorism measures. This guidance noted that one difference in
dealing with a terrorist-derived incident is that law enforcement
officials will be involved in the response as investigators, and that
their priorities may create emergency response coordination challenges
that spill response committees should address in their plan.

USCG guidance states that local port operators, municipalities, and public
safety agencies are expected to provide and maintain adequate disaster
response capabilities in their ports, with capability requirements likely
to vary from port to port depending on size, commodities received,
environmental considerations, relation to population, etc. Recognizing the
variability of capability requirements, the USCG has developed Critical
Success Factors (CSF) for spill response that drive a "Best Possible
Response"--that is, a set of general goals to achieve when conducting a
comprehensive and effective response. Six particular CSF are to be
considered when developing ACPs, including (1) no public or responder
injuries, illness or deaths; (2) sensitive areas protected; (3) resource
damage minimized; (4) infrastructure damage minimized; (5) economic impact
minimized; and (6) highly coordinated law enforcement and emergency
management operations. Joint exercises can maximize the ability of a given
port to carry out a "best response" in the event of an attack on a tanker.
However, we recognize that numerous scenarios could be exercised in any
given port; consequently, joint spill and terrorism response exercises may
not be the most urgent for a port that receives limited quantities of
energy commodities. Figure 16 shows firefighters preparing for a potential
marine response during a training exercise.

69According to FBI officials, FBI policy is that every field office of the
FBI that has within its jurisdiction a port or other navigable waterway
will have an agent who is assigned to serve in the MLA position. FBI
officials stated that there are 124 MLAs around the country for all
navigable waterways and ports where field offices are located.

Figure 16: Firefighters Preparing for a Maritime Terrorism Training
Exercise

Two developments--one a project at an individual port, the other a new
requirement added by Congress--may help bring about more integrated
responses. Specifically:

           o At one port, we found a potential leading practice for
           integrating a marine terrorism response. The port's Marine
           Terrorism Response (MTR) project was launched to develop and
           validate a multiagency response system and national model plan to
           help mobilize local, state, and federal resources for marine
           terrorism incidents. The MTR's goals include increasing
           preparedness, identifying gaps in emergency response capabilities,
           and planning for timely restoration of trade. The project
           generated a response plan and a field guide for how to integrate
           responses for a range of issues, such as public safety, response
           coordination, recovery, and crime scene management. Stakeholders
           plan to incorporate existing response plans, such as the ACP, as
           annexes to the MTR. According to the FBI official involved with
           the MTR planning process, the MTR serves as an effective linkage
           between the spill and terrorism response sections of the National
           Response Plan.70

           o Under the SAFE Port Act of 2006, DHS must develop interagency
           operational centers by fall 2009 for port security at all
           high-priority ports. The Coast Guard and the FBI are among the
           agencies that will be represented at these operational centers, as
           will other public and private sector stakeholders who would be
           adversely affected by a terrorist attack. These centers may also
           include stakeholders who would be involved in a joint spill and
           terrorism response. Integration may be improved through the daily
           interaction of all these stakeholders. In April 2006 testimony
           before the House Homeland Security Committee, DHS's Deputy
           Secretary stated that physically connecting the various agencies
           involved is important, and the Port of New York and New Jersey's
           Manager of Port Security voiced support for the development of
           joint operation centers in key U.S. ports.71

  Port Plans to Mitigate Economic Consequences Could Be Useful

The economic consequences of a terrorist attack on a tanker could be
significant, particularly if one or more ports are closed. Currently,
guidance in the Maritime Infrastructure Recovery Plan suggests that ports
develop priorities for bringing vessels into port after a closure.
Additionally, AMSPs must include a section on crisis management and
recovery to ensure the continuity of port operations. At the time of our
review, there was no national-level guidance for use by local ports. We
identified some ports that, on their own initiative, were incorporating
economic recovery considerations into their port-level plans, which could
benefit other ports seeking to develop their own plans for mitigating the
economic consequences of an attack.

The SAFE Port Act requires the Secretary of Homeland Security to develop
protocols for how maritime trade will be reestablished after a terrorist
attack. These protocols must include appropriate factors--related to
public health, national security, and economic need--that can be used to
set priorities for vessels and cargo entering the port after a closure.
While the act does not expressly require the development of port-level
plans for facilitating the resumption of trade after an incident, DHS
could consider developing guidance for ports to use to develop plans for
mitigating economic consequences.72

70Coast Guard headquarters is reviewing the MTR for possible dissemination
as a model approach to coordinating a terrorism response.

71Testimony of the Honorable Michael P. Jackson, Deputy Secretary,
Department of Homeland Security, before the U.S. House of Representative
Committee on Homeland Security on H. R. 4954 (To improve maritime and
cargo security through enhanced layered defenses, and for other purposes),
April 4, 2006.

  Ports Could Face Challenges in Securing Resources to Carry Out Their Response
  Plans

Ports could face challenges in marshaling resources to improve port
response capabilities, including obtaining or sharing needed marine
firefighting equipment and training, other training, and interoperable
communication systems that allow emergency responders to talk to each
other to effectively coordinate their efforts.

  Marine Firefighting Equipment and Training

The ports we visited varied considerably in their ability to combat marine
fires. Some ports had large fireboats that are designed to deal with fires
on tankers, as well as firefighters trained to conduct shipboard
firefighting operations. In contrast, other energy commodity ports relied
on land-based firefighting companies; these companies told us that they
did not have the training and/or the equipment to fight marine fires. See
figure 17 for two examples of marine firefighting response.

72Specific details regarding the operationalization and integration of
spill and terrorism response plans were provided in the Sensitive Security
Information version of this report.

Figure 17: Examples of Marine Firefighting Response

While some local ports may not be well equipped to handle marine fires,
companies operating tankers are required to provide for marine
firefighting and salvage capabilities under the Oil Pollution Act of
1990.73 However, we identified several limitations associated with these
requirements:

           o Timeliness of response not spelled out. OPA 90 does not specify
           how soon after an event either marine firefighting or salvage must
           occur. Under a Coast Guard rule proposed in 2002, and not yet
           issued as final, contracted marine firefighting resources
           generally would have to be provided within 8 hours after
           notification of an event, while salvage operations generally would
           have to begin within 16 hours. Even if this rule were in force, it
           might not be timely enough to prevent the vessel from sinking.

           o Extent of planning for salvage varies widely. Salvage is
           important for marine firefighting because a ship may sink from an
           attack, may be deliberately sunk to control the resulting fire, or
           may be accidentally sunk by the firefighters because they are not
           familiar with ship stability issues inherent in the marine
           firefighting environment. In addition to the OPA 90 requirement,
           the SAFE Port Act of 2006 requires the development of salvage
           response plans to supplement Area Maritime Security Plans. While
           all ACPs for the ports we visited contain sections on salvage, we
           found that the plans varied widely in detailing salvage responses.
           A 2003 National Transportation Safety Board workshop identified
           potential shortfalls in local salvage planning and/or capabilities
           as an issue that needed to be addressed.74 One reason for
           capability shortfalls identified was that locally available
           salvage resources may sometimes be lacking.

If ports lack marine firefighting or salvage capabilities, we identified
the following other avenues for obtaining resources to enhance these
capabilities. However, these avenues carry limitations, mainly related to
the speed with which they could be deployed on site.

           o Mutual aid agreements. Some port community members have mutual
           aid agreements in place to provide assistance in emergencies.
           These agreements can be industry-to-industry,
           municipal-to-municipal, industry-to-municipal, or
           municipal-to-industry. However, these agreements can have inherent
           delays in response time if needed resources are located some
           distance away or require considerable time for redeployment. For
           example, one refinery noted, in its site emergency manual section
           for ship fire procedures, that there is a need to evaluate whether
           refinery responders need to call the local fire department and
           request fireboat assistance because of a 45-minute delay in
           subsequent arrival of this resource. If the refinery needs to call
           for additional assistance from a nearby fire department's
           fireboats, the delay could be several hours, according to state
           fire officials.

           o National Oil Spill Response Resource Inventory. Each Coast Guard
           Captain of the Port has emergency contracting authority to obtain
           needed resources. The National Strike Force's Response Resource
           Inventory lists public and private organizations that can provide
           these needed spill response resources.75 The Coast Guard is to
           review these organizations' resources at least every 3 years to
           keep an up-to-date resource list. Again, in some cases delay in
           getting these needed resources to the incident location would
           occur.

73 As implemented by Coast Guard regulations in 33 S CFR 155.1050(k).

74 "Marine Salvage Capabilities Responding to Terrorist Attacks in U.S.
Ports--Actions to Improve Readiness," Report of the Committee for Marine
Salvage Response Capability: A Workshop of the National Transportation
Safety Board, August 5-6, 2003, Washington, D.C.

In addition to the differences in the availability of marine firefighting
equipment, we found that access to marine firefighting training, which is
highly specialized and different from land-based firefighting, can be
limited because of distance from a training center or lack of resources.
While a range of locations provide firefighter response training for
energy commodity fires in the marine environment, these facilities are
limited and are sometimes not located near a firefighting response
organization that is seeking this training.76 Some local emergency
responders told us they have not received shipboard firefighting training,
which is even more specialized than general marine firefighting, and many
of the responders we contacted identified the need for additional
training. At one port we visited, fire department officials stated that
the firefighters had not received this training but would board a burning
vessel. See figure 18 for an example of firefighters training to combat an
aviation fuel fire.

75The National Strike Force was established in 1973. Originally composed
of three 17-member Strike Teams, today's National Strike Force totals over
200 active duty, civilian, and reserve Coast Guard personnel and includes
the National Strike Force Coordination Center (NSFCC), the Atlantic Strike
Team, the Gulf Strike Team, the Pacific Strike Team, and the Public
Information Assist Team located at the NSFCC. NSFCC provides support and
standardization guidance to the [75]Atlantic , [76]Gulf , and [77]Pacific
strike teams. NSFCC is also home to National Response Resources Inventory
and the National Oil Spill Removal Organization Classification Program.

76This training is necessary for responding to an attack on a tanker,
because marine firefighting presents special considerations that are not
present in land-based firefighting, such as vessel stability, water
discharge discipline, vessel dewatering, and shipboard firefighting
systems (such as onboard firefighting foam deluge systems). The National
Fire Protection Association developed NFPA 1405: "Guide for Land-Based
Firefighters Who Respond to Marine Vessels" at the request of, and in
cooperation with, the Coast Guard and with the assistance of the fire
service and maritime communities in response to a recognized need in this
area for firefighter training.

Figure 18: Firefighters Training to Combat an Aviation Fuel Fire

  Other Training

We also found differences in training for federally established procedures
outlining coordination--known as the incident command system (ICS)--for
responding to any incident, including terrorism. Some emergency responders
identified a lack of experience and training on this system as a potential
concern for effectively coordinating and leading a response to an attack.
The Coast Guard and fire departments are familiar with ICS because they
were using it before September 11, 2001, but law enforcement does not have
equivalent experience with it. At the ports we visited, the local Coast
Guard and firefighting responders identified themselves as generally
compliant with ICS training requirements. Although the FBI would have
jurisdictional responsibility for leading the multiagency response to a
terrorist attack on a tanker, FBI personnel did not have to comply with
ICS training requirements until December 31, 2006.

  Interoperable Communications

At the ports we visited, officials identified the lack of fully
interoperable communications as an ongoing issue, as did many of the
after-action reports we reviewed.77 Spill and terrorism responders may
have difficulty coordinating their emergency response if their
communications systems are not interoperable--that is, one agency's
equipment may not be able to communicate with another's. For example,
according to local emergency planners, during one port exercise in 2006
the responders used their cell phones because of interoperability
problems. This workaround may be adequate during an exercise, an FBI
official noted, but responders may not be able to rely on the cell phone
communications network during an actual event. While interoperability is a
problem for emergency responders throughout the nation, responders in the
marine environment face additional challenges.78 These include the need
for additional equipment on or near ships so that radio signals can get
through to the ship's hold, as well as marine band radios for operating on
water.

Response organizations have some options to work around the problem of
interoperability. For example, the FBI can use a range of equipment to
coordinate the signals of all the various responding agencies'
communications equipment, but it takes some time to make this equipment
operational because the equipment has to be brought to the site, and each
responding organization has to provide a radio to the same location for
the workaround system to function. The Coast Guard also has communications
equipment for interoperability stored in locations around the nation, but
again, there would be a delay in getting this equipment to the site of an
incident.

77The DHS fiscal 2007 appropriations act calls for DHS to conduct baseline
interoperability assessments across the country by October 2007, and every
5 years thereafter.

78GAO, Homeland Security: Federal Leadership and Intergovernmental
Cooperation Required to Achieve First Responder Interoperable
Communications, [78]GAO-04-740 (Washington, D.C.: July 20, 2004).

DHS Grants May Become More Accessible for Response and Recovery Projects, but
Funding Decisions Require Better Application of Performance Measures

For ports that may be facing resource shortfalls, finding ways to pay for
improvements and enhancements is an issue. One potential funding source is
DHS's Port Security Grant Program. In the past, most DHS grants awarded to
ports were for terrorism prevention and detection projects (such as
fences, cameras, and security systems), rather than for response and
recovery projects, according to DHS officials. For some states that
contain ports we visited, officials who oversee grant resource
distribution also told us that only a limited number of post-incident
response project applications, such as marine firefighting assets or
shipboard firefighter training, have received grant funding.

This emphasis on prevention and detection is changing. Recent changes in
the grant program are more likely to result in consideration of response
and recovery projects, according to DHS officials. They told us that the
DHS Port Security Grant Program is undergoing a fundamental shift from a
facility security focus to a more comprehensive approach to managing risk
within ports. The Office of Grants and Training, within the Preparedness
Directorate, is working with the Coast Guard to develop an integrated,
risk-based decision-making process for allocating grant funds for each
port area. This shift in strategy recognizes that port security entails
not only prevention and detection activities but also response and
recovery capabilities. Plans for fiscal year 2007 grant guidance will
place more emphasis on post-incident response projects, according to DHS
officials. The SAFE Port Act of 2006 likewise emphasizes a risk-based
approach for port security grants.

To make effective judgments about such projects, performance measures are
needed to quantitatively determine the spill and terrorism resources that
should be available. Such measures help decide the extent to which a given
resource is needed to effectively conduct a response within a given time
period. At the time of our review, DHS was surveying available emergency
response capabilities within a given port, according to officials from
DHS's Office of Infrastructure Protection.

In September 2006, the New York City Fire Department Chief of
Counterterrorism and Emergency Preparedness questioned whether the nation
is prepared for an emergency and called for performance measures that
emphasized (1) capability (What can we do?), (2) capacity (How much can we
do?), (3) proficiency (How well can we perform?), and (4) deployment (How
quickly can we deploy capabilities?). As we have previously reported, in
the absence of comparable standards for emergency responder performance,
it is difficult to assess whether grant resources will be directed
effectively to reduce risk.79 Without such performance measures, the
federal government would not be able to conduct an analysis, based on
reducing overall risk, that could be used to set priorities for acquiring
needed response resources. Performance measures are critical for setting
priorities to effectively allocate federal funds.

The Captain of the Port may assist local authorities in reviewing the
adequacy of the port's overall marine firefighting and salvage capability.
Such qualitative reviews assess a range of factors related to the nature
of operations within the port. However, these assessments cannot set
priorities for addressing these shortfalls because they do not have
quantitative performance measures that would provide a way to compare one
shortfall against another to determine such priorities. Other related
assessments face the same priority-setting issues. A recent qualitative
advisory report for siting a potential future LNG facility illustrates
this problem. The assessment identified the need to send firefighters to
specialized fire schools on an annual basis to become trained in fighting
LNG fires, as well as to provide local firefighters with additional
training on hazardous materials and confined space rescue. The assessment
also identified a range of equipment procurement needs, including
additional fireboats capable of mitigating a large LNG spill on water as
well as dry chemicals and foam caches for extinguishing any resulting
fire. While all these shortfalls may need to be addressed, the assessments
do not provide a road map for setting federal funding priorities.

Conclusions

The ship-based supply chain for energy commodities remains threatened and
vulnerable, and appropriate security throughout the chain is essential to
ensure safe and efficient delivery. The threats are especially strong
internationally, where the United States faces limitations in ensuring
that facilities in foreign ports are meeting security standards and in
protecting shipments in international waters. Domestically, the nexus for
strengthening security efforts rests with the U.S. Coast Guard, which has
primary responsibility for security actions in U.S. ports and waterways.
Despite considerable efforts to protect ports and the energy traffic in
them, the level of protection is not where the Coast Guard believes it
should be. At some ports Coast Guard units are not meeting their own
levels of required security activities. Growing demand for Coast Guard
resources requires that the Coast Guard take action on several fronts. In
adjusting security standards to take into account its limited resources,
the Coast Guard needs to assure itself and other stakeholders that its
adjustments are based on a careful assessment of risk. This process has
begun with the Coast Guard's ongoing assessment of risks associated with
all CDC commodities, and since this assessment is already under way, we do
not see a need to make a recommendation in this case. The results of that
study, and of any comparative analysis that includes hazardous materials
not on the CDC list, will be important in a careful and dispassionate
analysis for ensuring that available resources are deployed in such a way
that commodities receive protection commensurate with the relative risks
involved. This is especially important with the expected growth in LNG
imports. Similarly, we believe that the results of the risk analyses
stemming from use of the Maritime Security Risk Assessment Model will be
important in determining how field units can best make use of security
resources at their ports. With the ability to compare different targets
and different levels of protection offered by security stakeholders, the
model should allow the Coast Guard to take a more complete accounting for
the various risks at U.S. ports. These two efforts are vital inputs that
are needed to ensure an accurate reflection of security risks to tankers
and the ports that receive them.

79GAO, Homeland Security - DHS' Efforts to Enhance First Responders'
All-Hazards Capabilities Continue to Evolve, [79]GAO-05-652 (Washington,
D.C.: July 20005).

Local Coast Guard units have been active in preparing for the coming
growth in LNG shipments, engaging with local law enforcement agencies as a
means to augment Coast Guard resources. The assistance the Coast Guard
already receives from state and local law enforcement is vital for many
units as they try to meet security activity requirements with limited
resources. Coast Guard headquarters, however, needs to do more to help
these local efforts. More specifically, it needs to begin centralized
planning for how to address resource shortfalls across many locations. As
LNG facilities continue to multiply, the resulting increase in workload
will affect some Coast Guard units but not others, necessitating a
centralized response as well as a port-specific one. It is important for
the Coast Guard to begin this centralized planning soon, when attention
can also be paid to assessing the options for partnering with state or
local law enforcement agencies to ensure appropriate security. This
broader planning is important for ensuring a proper distribution of
resources to best meet the Coast Guard's diverse responsibilities.

In the event of a successful attack on an energy commodity tanker, ports
would need to provide an effective, integrated response to protect public
safety and the environment, conduct a terrorism investigation, and restore
operations in a timely manner. Consequently, clearly defined and
understood roles and responsibilities for all stakeholders who would need
to respond are needed to ensure an effective response. Operational plans
for the response, among the various levels of government involved, should
be explicitly linked. As we have reported previously, it is essential that
these roles and responsibilities be clearly communicated and understood.
Furthermore, while we recognize that ports may have exercise priorities
other than responding to a terrorist attack on a tanker, we believe that
combined spill and terrorism response exercises should be considered and
pursued in ports that are considered to be at risk. In addition,
national-level guidance has generally suggested that ports plan for
mitigating the economic consequences of an attack. In implementing the
post-incident recovery portions of the SAFE Port Act, DHS has an
opportunity to provide specific guidance for how ports could plan for
lessening potentially significant economic consequences, particularly if
an attack results in a port closure. Finally, DHS has just begun to focus
more on providing funding for response resources through the Port Security
Grant program. However, DHS cannot be assured that it will appropriately
target funding to the projects that most reduce overall risk because it
has not developed quantitative performance measures. These measures would
allow DHS to set priorities for funding on the basis of reducing overall
risk. To make effective judgments about such projects, performance
measures are needed to quantitatively determine the spill and terrorism
resources that should be available.

Recommendations for Executive Action

We recommend that the Secretary of Homeland Security direct the Commandant
of the Coast Guard to take the following actions:

           o Develop a national resource allocation plan that will balance
           the need to meet new LNG security responsibilities with other
           existing security responsibilities and other Coast Guard missions.
           This plan needs to encompass goals and objectives, timelines,
           impacts on other missions, roles of private sector operators, and
           use of existing state and local agency capacity.

           o Develop national-level guidance that ports can use to plan for
           helping to mitigate economic consequences, particularly in the
           case of port closures.

We also recommend that the Secretary of Homeland Security direct the
Commandant of the Coast Guard and that the Attorney General direct the
Director of the Federal Bureau of Investigation to work together to take
the following two actions:

           o At the national level, help ensure that a detailed operational
           plan has been developed that integrates the different spill and
           terrorism response sections of the National Response Plan.

           o At the local level, help ensure that spill and terrorism
           response activities are integrated for the best possible response
           by maximizing the integration of spill and terrorism response
           planning and exercises at ports that receive energy commodities
           where attacks on tankers pose a significant threat.

We recommend that the Secretary of Homeland Security work with federal,
state, and local stakeholders to develop explicit performance measures for
emergency response capabilities and use them in risk-based analyses to set
priorities for acquiring needed response resources.

Agency Comments

We provided a draft of this report to the Departments of Defense, State,
Justice, and Homeland Security, including the Coast Guard, for their
review and comment. These departments provided formal written comments,
except for the Department of State, which provided oral comments. The
Department of Defense, in its written comments, concurred with our
recommendations. The Departments of Justice, through the FBI, and Homeland
Security generally concurred with our recommendations and provided
specific comments on the recommendations that are detailed below.

Regarding our recommendation that the Coast Guard develop a national
resource allocation plan that takes into account new LNG security
responsibilities along with its other mission demands, DHS generally
concurred. It stated, however, that while it agrees with the need to
address resource demands based on forecasted increases in LNG imports, it
also stated that LNG was one of many Certain Dangerous Cargoes that add
risk to the maritime environment, and the Coast Guard would address the
risk from CDCs as a whole. We agree that there are other dangerous cargoes
and it is logical for the Coast Guard to review them holistically in
targeting its resources to where the risks are greatest. On the basis of
its comments, the Coast Guard plans to examine the risk caused by
dangerous commodities, and to take a number of steps to allocate
resources. We will monitor the Coast Guard's actions to see if these
actions, collectively or in combination with a plan, allow it to optimally
allocate its limited resource to meet growing security requirements along
with its various other mission needs. Such a plan is important to ensure
the best distribution of resources to meet the Coast Guard's diverse
responsibilities.

Regarding our recommendation to develop national-level guidance to help
ports plan how to mitigate economic consequences, particularly in the case
of port closures, DHS generally concurred. It stated that its experience
from Hurricane Katrina showed that disruptions to the maritime
transportation system can have significant economic impacts and that these
impacts need to be considered during recovery actions. It also stated that
the Coast Guard, in partnership with CBP, is currently engaged in a broad
effort to improve maritime recovery planning. While information on this
effort was not provided to us during our review, according to its comment,
the Coast Guard seems to recognize the problem and is taking action to
address the basis of our concern.

Regarding our recommendation to develop a detailed national operational
plan that integrates spill and terrorism sections of the National Response
Plan, both DHS and FBI generally concurred. They both stated, however,
that the NRP itself already serves as the basis for integrating such
response planning, and the FBI did not concur with the need to develop a
separate operational plan. As we have noted in prior reports, effective
planning and coordination require the development of detailed operational
plans for response. While the NRP serves as a strategy-level doctrinal
document, it is not an operational plan. We remain concerned that an
intentional attack on an energy commodity tanker in a U.S. port may not be
met by the best possible response without such a plan to direct the
specific circumstance when both the spill and terrorism response sections
of the NRP must be integrated and implemented simultaneously. Without a
detailed operational plan for this situation, effective and efficient law
enforcement investigation and environmental consequence mitigation may be
hindered. As we have recently reported, the implementation of the NRP
following Hurricane Katrina identified concerns with coordination within
and between federal government entities using the NRP. Further, the
October 2005 draft version of the MOTR called for DHS and DOJ to develop
specific, detailed supporting operational plans for their
responsibilities, in close consultation with other departments and
agencies. However, this requirement was dropped from the October 2006
final version of the MOTR. As a result, no detailed operational plans
exist for the situation described in the response section of this
report.80 We believe our recommendation will help fill the guidance gap
between doctrine and port-level operations.

Regarding our recommendation to maximize terrorism and spill response
planning and exercises at the local level for the best possible response,
DHS generally concurred and FBI concurred. DHS said that while these
efforts must be coordinated they need not be an amalgamation. It stated
that there are opportunities for this coordination at the local committees
that are responsible for planning terrorism and spill response and because
the Coast Guard serves as chair for both committees, coordination already
occurs. In its comments FBI listed exercises that combined terrorism and
spill response. It also stated that local Maritime Liaison Agents were
specifically directed to engage agency partners to ensure integration of
FBI response. While these actions are beneficial for increased
integration, there is no direct link between the actual local terrorism
plan and spill response plan. Also, because terrorism response plans have
distribution limited to those who need to know, many nonsecurity
stakeholders--particularly in the spill response community--would not have
access to these plans in an emergency, allowing for the possibility for
these stakeholders to take actions that may hinder terrorism response.

Regarding our recommendation that the Secretary of Homeland Security work
with federal, state, and local stakeholders to develop explicit
performance measures for emergency response capabilities, DHS responded
that it was taking the recommendation under advisement and was exploring
approaches to address our recommendation. We will follow up with DHS later
to get its formal position on this recommendation.

All of the respondents provided technical comments that we incorporated
into the report as appropriate. Written comments from DHS are reproduced
in appendix V, written comments from FBI are reproduced in appendix VI,
and written comments from the Department of Defense are reproduced in
appendix VII.

80USCG headquarters officials stated that, at the direction of the
President, DHS, DOJ, and DOD completed the Maritime Operational Threat
Response Forces plan, in July 2007. According to USCG headquarters
officials, the MOTR Forces plan is a supporting plan to the base MOTR,
designed to permit the interoperability and synchronization of DHS, DOJ,
and DOD maritime competencies and capabilities. GAO was not able to review
and cannot comment on the MOTR Forces support plan because it was
developed after audit work completion.

As arranged with your office, unless you publicly announce its contents
earlier, we plan on no further distribution of this report until 30 days
after its issue date. At that time we will send copies of this report to
the Secretary of Homeland Security, the Commandant of the U.S. Coast
Guard, and the Attorney General. We will also make copies available to
others at no charge at GAO's Web site at http://www.gao.gov.

This report was prepared by two teams within GAO, each of which
concentrated on particular aspects of the assignment. If you or your
staffs have any questions regarding (1) the types of threats to tankers
carrying energy commodities and (2) the measures being taken to protect
tankers and the challenges federal agencies face in making these actions
effective, please call Stephen L. Caldwell at (202) 512-9610, or
[email protected]. For questions regarding (1) the potential consequences
of a successful attack on tankers or energy infrastructure or (2) the
plans in place and the potential challenges in responding to an attack,
please call Mark Gaffigan at (202) 512-3841, or [email protected]. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. Key contributors to this report
are listed in appendix IX.

Stephen L. Caldwell
Director, Homeland Security and Justice Issues

Mark Gaffigan
Acting Director, Natural Resources and Environment Issues

Appendix I: Objective, Scope, and Methodology

The objectives of this report were to (1) determine the types of terrorist
threats to tankers carrying energy commodities and the potential
consequences of a successful attack; (2) describe what measures are being
taken both internationally and domestically to protect these tankers, and
what challenges, if any, federal agencies face in making these actions
effective; and (3) if a terrorist attack succeeds despite these protective
measures, describe what plans are in place to respond and discuss the
potential challenges federal agencies may face in responding to a future
attack.

To determine the types of terrorist threats to tankers carrying energy
commodities, we conducted interviews with maritime intelligence officials
from the U.S. Coast Guard and Navy at the National Maritime Intelligence
Center.1 We also met with Coast Guard and Customs and Border Protection
officials at headquarters and in the field responsible for port and vessel
security to determine their views about maritime terrorism related to
energy tankers and infrastructure. During site visits to domestic ports,
we also interviewed operators of petroleum waterside facilities and
tankers to determine their understanding of the threat environment. We
also met with shipping and vessel management companies to discuss their
views of the threats they face at foreign loading ports and while in
transit to the United States. To gain an international perspective on
threats to tankers and loading facilities, we conducted interviews with
officials from international maritime organizations, international
shipping and petroleum trade associations, vessel operators, vessel
insurers, and private security and risk management organizations. We also
reviewed classified intelligence documents, including port threat
assessments, and government directives related to maritime security.

Continuing with our first objective to describe the potential public
safety, environmental, and economic consequences of a successful terrorist
attack on a waterside energy facility or tanker, we met with officials
from the Department of Energy, the Environmental Protection Agency, the
U.S. Maritime Administration, the Coast Guard, and the Federal Energy
Regulatory Commission. In addition, we conducted a panel study with
academic and industry experts to specifically determine the consequences
of an attack on a liquefied natural gas (LNG) tanker. We also visited
major petroleum, LNG, and liquefied petroleum gas terminals to discuss
possible consequences of attacks at these locations. We also analyzed
import data from U.S. government sources for petroleum and other energy
commodities into the United States and the ports receiving the imports.
Finally, we reviewed published information, such as studies and scholarly
articles, to determine the environmental and public health and safety
consequences of a terrorist attack to a petroleum waterside facility or
tanker.

1Central Intelligence Agency officials declined our request for a briefing
on threats to energy tankers.

To describe measures that are being taken to protect these tankers, and
what challenges, if any, federal agencies face in making these actions
effective, we interviewed a variety of foreign and domestic government
officials and private industry representatives. To determine the actions
taken in foreign nations, we visited four countries. The selection
criteria for our overseas site visits were the amount of energy
commodities exported to the United States and the opportunity to learn
about maritime anti-terrorism best practices. At the countries we visited
we conducted interviews with government officials responsible for maritime
security activities and petroleum waterside facility and tanker operators.
We also obtained information from the Coast Guard, international maritime
organizations, tanker operators, vessel management companies, and insurers
to understand port and vessel security practices and procedures overseas
and while tankers are in transit to the United States.

To determine the actions taken domestically, we met with officials in the
Departments of Homeland Security, Defense, State, Energy, Transportation,
and Justice; private sector facility and vessel operators; and state and
local officials dealing with homeland security, emergency response, and
law enforcement.

We also conducted site visits to a nonprobability sample of petroleum and
liquefied gas import and export facilities in the United States. During
our site visits we observed security practices and conducted interviews
with representatives of federal agencies that oversee the security of the
energy facilities, as well as facility security officers and relevant
local and state law enforcement officials. The information obtained from
these site visits cannot be generalized to all petroleum and liquefied gas
import and export facilities nationwide.

We also reviewed government and industry documents and data sources
relevant to domestic actions taken by agencies and companies to prevent
terrorist attacks. To establish criteria for evaluating the Coast Guard's
ability to mitigate the risk of maritime terrorism, we obtained 9 months
of Operation Neptune Shield (ONS) Scorecard security performance data--the
Coast Guard's performance measurement tool for tracking performance in
meeting security activities at the nations most strategically important
ports--from select Coast Guard field units covering the months of November
2005 through July 2006. We chose to review scorecard data for ports that
the U.S. Maritime Administration identified as being top ports for
receiving energy commodity tankers. We calculated the ONS 9-month average
of both the monthly activity requirement attainment percentages and share
of workload conducted by other government agencies. In conducting this
work, we met with Coast Guard headquarters personnel on several occasions
to further our understanding. We also asked Coast Guard officials
responsible for the scorecard data what steps they took to ensure the
reliability of the data and determined that they were sufficiently
accurate for our purposes.

To describe what plans are in place for responding to a terrorist attack,
should one occur despite protective measures, and discuss the challenges
federal agencies may face in responding, we conducted interviews with
officials from the Departments of Homeland Security and Justice; the
Environmental Protection Agency; as well as officials representing port
authorities, state and local offices of public safety and emergency
management, oil and gas facilities, and first responders, including police
and fire departments. These interviews were conducted to identify spill,
terrorism, and economic response plans and priorities; mechanisms for
response coordination; access to resources; training availability; types
of exercises conducted; potential communications challenges; performance
metrics; and information-sharing systems. During our site visits, we
observed port operations and the working relationships between some
government and private stakeholders. To assess the integration of national
and local spill and terrorism response plans, we gathered and reviewed
identified plans. Finally, we interviewed emergency response officials and
reviewed after-action reports to identify best practices and lessons
learned as a result of emergency response exercises and incidents.

We conducted our work from April 2005 to February 2007 in accordance with
generally accepted government auditing standards.

Appendix II: Selected Energy Commodities Transported by Tanker into United
States

Crude Oil

           o Crude oil is used to produce a wide array of petroleum products,
           including gasoline, diesel and jet fuels, heating oil, lubricants,
           asphalt, plastics, and many other products used for their energy
           or chemical content.

           o Crude oils range from very light (high in gasoline) to very
           heavy (high in residual oils). Sour crude is high in sulfur
           content. Sweet crude is low in sulfur and therefore often more
           valuable than other kinds.

Gasoline

           o A complex mixture of relatively volatile hydrocarbons with or
           without small quantities of additives, blended to form a fuel
           suitable for use in spark-ignition engines.

           o Motor gasoline includes conventional gasoline; all types of
           oxygenated gasoline, including gasohol; and reformulated gasoline,
           but excludes aviation gasoline.

Jet Fuel

           o A refined petroleum product used in jet aircraft engines.

           o Kerosene-type jet fuel is used for commercial and military
           turbojet and turboprop aircraft engines.

           o Naphtha-type jet fuel is used primarily for military turbojet
           and turboprop aircraft engines because it has a lower freeze point
           than other aviation fuels and meets engine requirements at high
           altitudes and speeds.

LNG

           o A natural gas that has been cooled to minus 260 degrees
           Fahrenheit to a liquid state so that it can be transported.

           o Consists almost entirely of methane (85-95 percent) along with
           small concentrations of ethane, propane, butane, and trace amounts
           of nitrogen.

           o Mainly used as fuel for electricity generation, home heating,
           industrial manufacturing, and, to a lesser extent, motor vehicles.

LPG

           o Group of hydrocarbons, such as propane and butane, derived
           mainly as a byproduct of oilfield production and crude oil
           refining processes.
           o The vast majority of LPG traded internationally consists of
           propane and butane cargo.

           o LPG has a variety of agricultural, household, petrochemical,
           and, to a lesser extent, vehicle fuel applications.

Appendix III: Recent High-Profile Terrorism Incidents against Tankers and
Energy Infrastructure

Table 4: High-Profile Terrorism Incidents against Tankers and Energy
Infrastructure by Target and Attack Method since 2002

Date       Target, location  Attack method Description                     
June 2006  Shell Gas         Armed assault Nigerian militants attacked an  
              Facility, Nigeria               energy facility and abducted    
                                              foreign oil workers in the      
                                              oil-rich Niger delta. The       
                                              Movement for the Emancipation   
                                              of the Niger Delta is           
                                              responsible for a wave of       
                                              militant attacks in Nigeria.    
Feb. 2006  Saudi Aramco      Suicide       Two cars packed with explosives 
              facility, Abqaiq, attack        tried to attack a major oil     
              Saudi Arabia                    processing facility in Saudi    
                                              Arabia's eastern province. Al   
                                              Qaeda suicide attackers were    
                                              killed along with two Saudi     
                                              guards.                         
April 2004 Al Basrah and     Suicide       Closely timed suicide boat      
              Khawr Al Amaya    attack        attacks on northern Persian     
              oil terminals,                  Gulf oil terminals in Iraq left 
              Iraq                            two Navy sailors and one Coast  
                                              Guardsman dead and five others  
                                              injured.                        
Aug. 2003  M/V Penrider, en  Armed assault The Free Aceh Movement claimed  
              route from                      responsibility for hijacking    
              Singapore to                    the M/V Penrider, a fully laden 
              Malaysia                        tanker shipping fuel oil in     
                                              Southeast Asia. Three hostages  
                                              were eventually released        
                                              following a ransom payment.     
March 2003 Chemical Tanker   Armed assault Ten pirates boarded tanker from 
              Dewi Madrim,                    a speedboat. Pirates took the   
              Strait of Malacca               helm, altered the speed,        
                                              disabled ship's radio, and      
                                              steered the vessel for an hour. 
                                              Pirates left with cash and      
                                              abducted captain and first      
                                              officer.                        
Oct. 2002  M/V Limburg,      Suicide       Small boat filled with          
              Yemen             attack        explosives rammed the side of   
                                              the French-flagged oil tanker   
                                              Limburg as it was approaching   
                                              the Ash Shihr Terminal several  
                                              miles off the coast of Yemen.   
                                              The suicide attack killed one   
                                              crew member and 90,000 barrels  
                                              of oil spilled.                 

Source: GAO.

Appendix IV: Assessing and Managing Risks Using a Risk Management Approach

Risk management is a systematic approach for analyzing risk and deciding
how best to address it. Because resources are limited and cannot eliminate
all risks, careful choices need to be made in deciding which actions yield
the greatest benefit. Figure 19 depicts a risk management framework that
is our synthesis of government requirements and prevailing best practices
previously reported.1 To be effective, this process must be repeated when
threats or conditions change to incorporate any new information to adjust
and revise the assessments and actions.

Figure 19: Risk Management Framework

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

1See GAO, Risk Management: Further Refinements Needed to Assess Risks and
Prioritize Protective Measures at Ports and Other Critical Infrastructure,
[80]GAO-06-91 (Washington, D.C.: December 2005).

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

           o A threat assessment identifies and evaluates potential threats
           on the basis of factors such as capabilities, intentions, and past
           activities.
           o A criticality or consequence assessment evaluates and
           prioritizes assets and functions in terms of specific criteria,
           such as their importance to public safety and the economy, as a
           basis for identifying which structures or processes are relatively
           more important to protect from attack.
           o A vulnerability assessment identifies weaknesses that may be
           exploited by identified threats and suggests options to address
           those weaknesses.

Information from these three assessments contributes to an overall risk
assessment that characterizes risks on a scale such as high, medium, or
low and provides input for evaluating alternatives and management
prioritization of security initiatives.

The next two steps involve deciding what mitigation measures to adopt.
Alternatives evaluation considers what actions may be needed to address
identified risks, the associated costs of taking these actions, and any
resulting benefits. This information is provided to agency management to
aid in completing the next step--selecting alternative actions best suited
to the unique needs of the organization.

The final step in the approach involves implementing the selected actions
and evaluating the extent to which they mitigate risk. This involves
developing criteria for monitoring the performance of these actions and
follow-up to ensure that these actions are effective and reflect evolving
risk.

Risk management has received widespread support from Congress, the
President, and the Secretary of Homeland Security as a tool that can help
set priorities and inform decisions about mitigating risks.

Appendix V: Comments from the Department of Homeland Security

Appendix VI: Comments from the Federal Bureau of Investigation

Appendix VII: Comments from the Department of Defense

Appendix VIII: GAO Contacts and Staff Acknowledgments:

GAO Contacts: 

Stephen L. Caldwell, (202) 512-9610, or [email protected]: 

Mark Gaffigan, (202) 512-3841, or [email protected]: 

Staff Acknowledgments: 

In addition to the contacts named above, Jonathan Bachman, Jason 
Berman, Steven Calvo, Jonathan Carver, Frances Cook, Frank Chase Cook, 
Amy Higgins, David Lysy, Jean McSween, Erica Miles, Jobenia Odum, Josh 
Ormond, Janice Poling, Franklin Rusco, Peter Singer, Carol Shulman, 
Stan Stenerson, Barbara Timmerman, James Turkett, Jim Wells, and 
Margaret Wrightson made key contributions to this report. 

Related GAO Products 

Related GAO Products: 

Maritime Security: The SAFE Port Act: Status and Implementation One 
Year Later. GAO-08-126T. Washington, D.C.: October 30, 2007. 

Maritime Security: One Year Later: A Progress Report on the SAFE Port 
Act. GAO-08-171T. Washington, D.C.: October 16, 2007. 

Maritime Security: The SAFE Port Act and Efforts to Secure Our Nation's 
Seaports. GAO-08-86T. Washington, D.C.: October 4, 2007. 

Department of Homeland Security: Progress Report on Implementation of 
Mission and Management Functions. GAO-07-1240T. Washington, D.C.: 
September 18, 2007. 

Department of Homeland Security: Progress Report on Implementation of 
Mission and Management Functions. GAO-07-1081T. Washington, D.C.: 
September 6, 2007. 

Department of Homeland Security: Progress Report on Implementation of 
Mission and Management Functions. GAO-07-454. Washington, D.C.: August 
17, 2007. 

Homeland Security: Observations on DHS and FEMA Efforts to Prepare for 
and Respond to Major and Catastrophic Disasters and Address Related 
Recommendations and Legislation. GAO-07-1142T. Washington, D.C.: July 
31, 2007. 

Information on Port Security in the Caribbean Basin. GAO-07-804R. 
Washington, D.C.: June 29, 2007. 

Homeland Security: Observations on DHS and FEMA Efforts to Prepare for 
and Respond to Major and Catastrophic Disasters and Address Related 
Recommendations and Legislation. GAO-07-835T. Washington, D.C.: May 15, 
2007. 

[End of section] 

Homeland Security: Management and Programmatic Challenges Facing the 
Department of Homeland Security. GAO-07-833T. Washington, D.C.: May 10, 
2007. 

Maritime Security: Observations on Selected Aspects of the SAFE Port 
Act. GAO-07-754T. Washington, D.C.: April 26, 2007. 

Port Risk Management: Additional Federal Guidance Would Aid Ports in 
Disaster Planning and Recovery. GAO-07-412. Washington, D.C.: March 28, 
2007. 

Maritime Security: Public Safety Consequences of a Terrorist Attack on 
a Tanker Carrying Liquefied Natural Gas Need Clarification. GAO-07-316. 
Washington, D.C.: February 23, 2007. 

Catastrophic Disasters: Enhanced Leadership, Capabilities, and 
Accountability Controls Will Improve the Effectiveness of the Nation's 
Preparedness, Response, and Recovery System. GAO-06-618. Washington, 
D.C.: September 6, 2006. 

Coast Guard: Non-Homeland Security Performance Measures Are Generally 
Sound, but Opportunities for Improvement Exist. GAO-06-816. Washington, 
D.C.: August 16, 2006. 

Coast Guard: Observations on the Preparation, Response, and Recovery 
Missions Related to Hurricane Katrina. GAO-06-903. Washington, D.C.: 
July 31, 2006. 

Maritime Security: Information Sharing Efforts Are Improving. GAO-06- 
933T. Washington, D.C.: July 10, 2006. 

Energy Security: Issues Related to Potential Reductions in Venezuelan 
Oil Production. GAO-06-668. Washington, D.C.: June 27, 2006. 

Coast Guard: Observations on Agency Performance, Operations, and Future 
Challenges. GAO-06-448T. Washington, D.C.: June 15, 2006. 

Emergency Preparedness and Response: Some Issues and Challenges 
Associated with Major Emergency Incidents. GAO-06-467T. Washington, 
D.C.: February 23, 2006. 

Homeland Security: DHS Is Taking Steps to Enhance Security at Chemical 
Facilities, but Additional Authority Is Needed. GAO-06-150. Washington, 
D.C.: January 27, 2006. 

Risk Management: Further Refinements Needed to Assess Risks and 
Prioritize Protective Measures at Ports and Other Critical 
Infrastructure. GAO-06-91. Washington, D.C.: December 2005. 

Border Security: Strengthened Visa Process Would Benefit from 
Additional Management Actions by State and DHS. GAO-05-859. Washington, 
D.C.: September 13, 2005. 

Maritime Security: Enhancements Made, but Implementation and 
Sustainability Remain Key Challenges. GAO-05-448T. Washington, D.C.: 
May 17, 2005. 

Maritime Security: New Structures Have Improved Information Sharing, 
but Security Clearance Processing Requires Further Attention. GAO-05- 
394. Washington, D.C.: April 15, 2005. 

Coast Guard: Observations on Agency Priorities in Fiscal Year 2006 
Budget Request. GAO-05-364T. Washington, D.C.: March 17, 2005. 

Coast Guard: Station Readiness Improving, but Resource Challenges and 
Management Concerns Remain. GAO-05-161. Washington, D.C.: January 31, 
2005. 

Homeland Security: Process for Reporting Lessons Learned from Seaport 
Exercises Needs Further Attention. GAO-05-170. Washington, D.C.: 
January 14, 2005. 

Port Security: Better Planning Needed to Develop and Operate Maritime 
Worker Identification Card Program. GAO-05-106. Washington, D.C.: 
December 10, 2004. 

Maritime Security: Better Planning Needed to Help Ensure an Effective 
Port Security Assessment Program. GAO-04-1062. Washington, D.C.: 
September 30, 2004. 

Maritime Security: Partnering Could Reduce Federal Costs and Facilitate 
Implementation of Automatic Vessel Identification System. GAO-04-868. 
Washington, D.C.: July 23, 2004. 

Maritime Security: Substantial Work Remains to Translate New Planning 
Requirements into Effective Port Security. GAO-04-838. Washington, 
D.C.: June 30, 2004. 

Coast Guard: Key Management and Budget Challenges for Fiscal Year 2005 
and Beyond. GAO-04-636T. Washington, D.C.: April 7, 2004. 

Homeland Security: Summary of Challenges Faced in Targeting Oceangoing 
Cargo Containers for Inspection. GAO-04-557T. Washington, D.C.: March 
31, 2004. 

Homeland Security: Preliminary Observations on Efforts to Target 
Security Inspections of Cargo Containers. GAO-04-325T. Washington, 
D.C.: December 16, 2003. 

Maritime Security: Progress Made in Implementing Maritime 
Transportation Security Act, but Concerns Remain. GAO-03-1155T. 
Washington, D.C.: September 9, 2003. 

Homeland Security: Efforts to Improve Information Sharing Need to Be 
Strengthened. GAO-03-760. Washington, D.C.: August 27, 2003. 

Container Security: Expansion of Key Customs Programs Will Require 
Greater Attention to Critical Success Factors. GAO-03-770. Washington, 
D.C.: July 25, 2003. 

Homeland Security: Challenges Facing the Department of Homeland Security
in Balancing Its Border Security and Trade Facilitation Missions.
GAO-03-902T. Washington, D.C.: June 16, 2003.

Transportation Security: Post-September 11th Initiatives and
Long-Term Challenges. GAO-03-616T. Washington, D.C.: April 1, 2003.

To view the full product, including the scope
and methodology, click on [98]GAO-08-141 .

For more information, contact Stephen Caldwell at (202) 512-9610 or
[email protected] or Mark Gaffigan at 202-512-3841 or [email protected]

Highlights of [99]GAO-08-141 , a report to Congressional requesters

December 2007

MARITIME SECURITY

Federal Efforts Needed to Address Challenges in Preventing and Responding
to Terrorist Attacks on Energy Commodity Tankers

U. S. energy needs rest heavily on ship-based imports. Tankers bring 55
percent of the nation's crude oil supply, as well as liquefied gases and
refined products like jet fuel. This supply chain is potentially
vulnerable in many places here and abroad, as borne out by several
successful overseas attacks on ships and facilities. GAO's review
addressed (1) the types of threats to tankers and the potential
consequences of a successful attack, (2) measures taken to protect tankers
and challenges federal agencies face in making these actions effective,
and (3) plans in place for responding to a successful attack and potential
challenges stakeholders face in responding. GAO's review spanned several
foreign and domestic ports, and multiple steps to analyze data and gather
opinions from agencies and stakeholders.

[100]What GAO Recommends

GAO recommends that cognizant agencies (1) plan for meeting a growing
security workload for protecting liquefied natural gas shipments, (2) help
ensure that ports plan for dealing with economic consequences of an
attack, (3) integrate terrorism and spill response plans at the national
and (4) local level, and (5) work to develop performance measures for
emergency response. The agencies generally agreed with our
recommendations, but the Department of Homeland Security took the final
recommendation under advisement.

The supply chain faces three main types of threats--suicide attacks such
as explosive-laden boats, "standoff" attacks with weapons launched from a
distance, and armed assaults. Highly combustible commodities such as
liquefied gases have the potential to catch fire or, in a more unlikely
scenario, explode, posing a threat to public safety. Attacks could also
have environmental consequences, and attacks that disrupt the supply chain
could have a severe economic impact.

Much is occurring, internationally and domestically, to protect tankers
and facilities, but significant challenges remain. Overseas, despite
international agreements calling for certain protective steps, substantial
disparities exist in implementation. The United States faces limitations
in helping to increase compliance, as well as limitations in ensuring safe
passage on vulnerable transport routes. Domestically, units of the Coast
Guard, the lead federal agency for maritime security, report insufficient
resources to meet its own self imposed security standards, such as
escorting ships carrying liquefied natural gas. Some units' workloads are
likely to grow as new liquefied natural gas facilities are added. Coast
Guard headquarters has not developed plans for shifting resources among
units.

Multiple attack response plans are in place to address an attack, but
stakeholders face three main challenges in making them work. First, plans
for responding to a spill and to a terrorist threat are generally separate
from each other, and ports have rarely exercised these plans
simultaneously to see if they work effectively together. Second, ports
generally lack plans for dealing with economic issues, such as
prioritizing the movement of vessels after a port reopens. The President's
maritime security strategy calls for such plans. Third, some ports report
difficulty in securing response resources to carry out planned actions.
Federal port security grants have generally been directed at preventing
attacks, not responding to them, but a more comprehensive risk-based
approach is being developed. Decisions about the need for more response
capabilities are hindered, however, by a lack of performance measures
tying resource needs to effectiveness in response.

Tanker Limburg after Terrorist Attack near Yemen

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