Aviation Security
TSA's Cost and Performance Study of Private-Sector Airport Screening Gao ID: GAO-09-27R January 9, 2009This report formally responds to Congress' request that GAO review the Transportation Security Administration's (TSA) Screening Partnership Program (SPP). In accordance with the Aviation and Transportation Security Act, TSA created the SPP to allow commercial airports an opportunity to apply to TSA to use private sector screeners through qualified private-screening contractors approved by TSA. In February 2008, TSA issued a report on its study comparing the cost and performance of screening services at SPP and non-SPP airports. Our briefing addresses the following questions: (1) To what extent did the design of TSA's study of the cost and performance of passenger and checked baggage screening services at selected SPP and non-SPP airports affect the usefulness of the study? (2) To what extent has TSA taken actions to identify and eliminate any unnecessary overhead/supervisory redundancies at SPP airports between TSA and contractor personnel? (3) What factors do airport operators cite as having contributed to airports' decisions about whether to participate in the SPP? We are recommending that if TSA plans to rely on its comparison of costs and performance of SPP and non-SPP airports for future decision making, the agency update its study to address the limitations we identified, for example, by including various cost elements that were excluded and conducting statistical tests to determine the level of confidence in any observed differences in screening performance. TSA generally agreed with our findings and recommendation.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-09-27R, Aviation Security: TSA's Cost and Performance Study of Private-Sector Airport Screening
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United States Government Accountability Office:
Washington, DC 20548:
January 9, 2009:
The Honorable Daniel E. Lungren:
Ranking Republican Member:
Subcommittee on Transportation and Infrastructure Protection:
Committee on Homeland Security:
House of Representatives:
The Honorable John L. Mica:
Ranking Republican Member:
Committee on Transportation and Infrastructure:
House of Representatives:
Subject: Aviation Security: TSA's Cost and Performance Study of Private-
Sector Airport Screening:
This report formally transmits the enclosed briefing in response to
your request that we review the Transportation Security
Administration's (TSA) Screening Partnership Program (SPP). In
accordance with the Aviation and Transportation Security Act, TSA
created the SPP to allow commercial airports an opportunity to apply to
TSA to use private sector screeners through qualified private-screening
contractors approved by TSA. In February 2008, TSA issued a report on
its study comparing the cost and performance of screening services at
SPP and non-SPP airports. Our briefing addresses the following
questions: (1) To what extent did the design of TSA's study of the cost
and performance of passenger and checked baggage screening services at
selected SPP and non-SPP airports affect the usefulness of the study?
(2) To what extent has TSA taken actions to identify and eliminate any
unnecessary overhead/supervisory redundancies at SPP airports between
TSA and contractor personnel? (3) What factors do airport operators
cite as having contributed to airports' decisions about whether to
participate in the SPP? We are recommending that if TSA plans to rely
on its comparison of costs and performance of SPP and non-SPP airports
for future decision making, the agency update its study to address the
limitations we identified, for example, by including various cost
elements that were excluded and conducting statistical tests to
determine the level of confidence in any observed differences in
screening performance. TSA generally agreed with our findings and
recommendation.
As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
from the date of this report. At that time, we will send copies of this
report to the Secretary of Homeland Security and other interested
parties. This report will also be available at no charge on our Web
site at [hyperlink, http://www.gao.gov].
Should you or your staff have any questions concerning this report,
please contact me at (202) 512-3404 or berrickc@gao.gov. 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
were Glenn Davis, Assistant Director; Chuck Bausell, Jr; Katherine
Davis; Stanley Kostyla; Thomas Lombardi; Frederick Lyles, Jr; Deborah
Ortega; and John Warner.
Signed by:
Cathleen A. Berrick:
Managing Director, Homeland Security and Justice Issues:
Enclosures - 2:
[End of section]
Enclosure I: Briefing Slides:
Aviation Security: TSA‘s Cost and Performance Study of Private-Sector
Airport Screening:
Briefing for Congressional Requesters:
November 12, 2008:
Contents:
Introduction:
Objectives:
Scope and Methodology:
Results in Brief:
Background:
Findings:
Conclusions:
Recommendation for Executive Action:
GAO Contacts:
Appendixes:
Related GAO Products:
Introduction:
Passenger screening is a critical component of the security of our
nation‘s commercial aviation system. Passenger screeners,[Footnote 1]
both federal and private, use metal detectors, X-ray and other
detection machines and systems, and physical searches to examine
passengers and their baggage to identify threat objects.
On November 19, 2002, in accordance with the Aviation and
Transportation Security Act (ATSA), the Transportation Security
Administration (TSA) began a 2-year pilot program at five airports
using private screening companies to screen passengers and checked
baggage.[Footnote 2] ATSA further mandates that TSA allow airports to
request that the screening of airline passengers and baggage be
conducted by private screeners in lieu of federal screeners.[Footnote
3]
In November 2004 and in accordance with ATSA,TSA created the Screening
Partnership Program (SPP) to allow all commercial airports an
opportunity to apply to TSA to use private-sector screeners through
private screening contractors approved by TSA. TSA remains responsible
for funding all passenger and baggage screening activities at SPP
airports as well as airports with federal screeners.
In May 2007, TSA awarded a contract to Catapult Consultants, in the
amount of $442,521, to conduct a cost and performance analysis of
airports with private screeners versus airports with federal screeners.
This analysis would be used to assist senior TSA leadership with
strategic decisions regarding the degree to which TSA should leverage
public/private partnerships in the area of screening services. The
contractor issued a report on its analysis to TSA in December
2007.[Footnote 4]
In February 2008, TSA issued a report on a study TSA conducted
comparing the cost and performance of screening at SPP and non-SPP
airports.[Footnote 5] The agency initiated this work in anticipation
that more airports would apply to participate in the SPP, and, because
of this, it wanted to obtain information regarding how such
participation would impact the agency‘s budget. In addition, TSA also
wanted to obtain information about how the existing SPP airports
compared to non-SPP airports.
TSA officials stated that although they used the study prepared by
Catapult Consultants to conduct their comparison of screening at SPP
and non-SPP airports, they consider the TSA study to be the official
agency study. In conducting the study,TSA compared the cost of
operating screening at SPP airports with the cost that would be
incurred in the agency‘s budget if these airports were run as fully
federal or non-SPP airports. TSA used 2007 invoice data submitted by
the following six SPP airports and determined what the cost would be if
these airports were instead staffed with federal transportation
security officers (TSO) (see app. I for additional details about TSA‘s
approach and methodology).
1. Greater Rochester International Airport, Rochester, New York;
2. Jackson Hole Airport, Jackson, Wyoming;
3. Joe Foss Field, Sioux Falls, South Dakota;
4. Kansas City International Airport, Kansas City, Missouri;
5. San Francisco International Airport, San Francisco, California;
6. Tupelo Regional Airport, Tupelo, Mississippi;
TSA compared the performance measures of SPP airports to non-SPP
airports in the same airport category (category X, I,II, III, and
IV).[Footnote 6] Specifically, TSA analyzed 2007 performance data for
five performance measures: threat image projection projection
rates,[Footnote 7] recertification,[Footnote 8] passenger waiting, peak
wait times, and checkpoint capacity utilization. An airport was
considered an average performer if the results for these measures fell
within one standard deviation from the airport category average(the
middle 68.2 percent of the category).
TSA found that screening at SPP airports currently costs approximately
17.4 percent more to operate than at airports with federal screeners,
and that SPP airports fell within the ’average performer“ category for
the performance measures included in its analysis. Although the TSA
contractor used a different methodological approach for comparing the
cost and performance of SPP and non-SPP airports, the contractor
concluded that passenger screening at the SPP airports has historically
cost from 9 to 17 percent more than at non-SPP airports, and private
screeners performed at a level that was equal to or greater than that
of federal TSOs. (Additional information about the methodology and
findings of the TSA contractor‘s study is contained in app. II and app.
III, respectively.)
In presenting its findings, TSA also stated in its report that the
current SPP model is constrained by the law[Footnote 9] and TSA policy
and allows for little variance in the inputs for staffing,
compensation, and operations at SPP airports. Therefore, the outputs of
such a constrained model produce similar performance results with an
anticipated costs premium due to an additional layer of contractor
management.
The Ranking Republican Member of the House Committee on Transportation
and Infrastructure and the Ranking Republican Member of the
Subcommittee on Transportation and Infrastructure Protection, House
Committee on Homeland Security, requested that we provide information
on TSA‘s cost and performance study of SPP airports, any actions that
TSA has taken to identify and prevent redundancies between TSA and
contractor personnel, and factors that have contributed to an airport
operator‘s decision about whether to participate in the SPP.
Objectives:
Our objectives were to determine:
To what extent did the design of TSA‘s study of the cost and
performance of passenger and checked-baggage screening services at
selected SPP and non-SPP airports affect the usefulness of the study‘s
results?
To what extent has TSA taken actions to identify and eliminate any
unnecessary redundancies at SPP airports between TSA administrative
staff, including supervisory positions, and contractor personnel?
What factors did airport operators cite as having contributed to their
decisions about whether to participate in the SPP?
Scope and Methodology:
To determine the extent to which the design of TSA‘s study of the cost
and performance of passenger and checked-baggage screening services at
selected SPP and non-SPP airports affected the usefulness of the
study‘s results, we:
analyzed TSA‘s study and available documentation, such as calculations
used in developing the cost estimates, to determine what costs were
included in the comparisons, whether the comparisons accounted for
possible performance differences among screeners at selected SPP and
comparable non-SPP airports, whether the comparisons were supported by
a workforce analysis to identify any unnecessary redundancies at SPP
airports, and whether the study accounted explicitly for uncertainty;
compared TSA‘s study methodology as described by TSA officials to
criteria in GAO‘s Standards for Internal Control in the Federal
Government,[Footnote 10] federal accounting standards for managerial
cost accounting,[Footnote 11] GAO[Footnote 12] and Office of Management
and Budget (OMB)[Footnote 13] guidance for estimating and managing
program costs, and OMB‘s guidance for statistical surveys, data
quality, and performance assessments,[Footnote 14] and assessed whether
TSA and contractor officials took actions to ensure that the data used
in the studies were reliable;
assessed the type of performance measures that were included in the TSA
and contractor studies, the methodology used to identify differences in
private screener/TSO performance, and whether analyses were conducted
to determine if observed differences in performance were statistically
significant; and:
interviewed TSA and contractor officials to obtain information on the
models that TSA and its contractor used to assess the cost of screening
operations, and to assess the performance of private and federal
screeners at the selected SPP and comparable non-SPP airports.
To determine the extent to which TSA has taken actions to identify and
eliminate any unnecessary redundancies at SPP airports between TSA
administrative staff, including supervisory positions, and contractor
personnel:
We analyzed organizational charts, as well as information on
supervisory roles and responsibilities, for TSA personnel at six SPP
airports we visited and six non-SPP airports to identify possible
redundancies between TSA and contractor personnel. While information we
obtained at these locations is not generalizable across all airports,
we selected these airports because they represent a mixture of
different geographic locations, passenger and baggage
throughput,[Footnote 15] and checkpoint configurations. In addition,
two of the SPP airports”Kansas City International Airport and San
Francisco International Airport”also participated in TSA‘s 2-year pilot
program and, therefore, had several years of experience using private
screeners.
Table: Airports Included in GAO‘s Review:
SPP Airports:
1. Joe Foss Field, Sioux Falls, South Dakota;
2. Kansas City International Airport, Kansas City, Missouri;
3. Key West International Airport, Key West, Florida;
4. Roswell Industrial Air Center, Roswell, New Mexico;
5. San Francisco International Airport, San Francisco, California;
6. Charles M. Schulz-Sonoma County Airport, Santa Rosa, California.
Non-SPP airports:
1. Barkley Regional Airport, Paducah, Kentucky;
2. Central Illinois Regional, Bloomington, Illinois;
3. Logan International Airport, Boston, Massachusetts
4. Missoula International Airport, Missoula, Montana
5. Salt Lake City International Airport, Salt Lake City, Utah
6. Syracuse-Hancock International Airport, Syracuse, New York.
Source: GAO.
[End of table]
We assessed TSA‘s actions to identify unnecessary redundancies between
TSA and contractor personnel based on GAO[Footnote 16] and Office of
Personnel Management (OPM)[Footnote 17] guidance on workforce planning.
We interviewed TSA headquarters personnel and airport officials at the
six SPP airports we visited to obtain their views on the extent to
which redundancies were occurring between TSA and contractor personnel.
We interviewed TSA headquarters officials to discuss the agency‘s
approach for allocating screening and supervisory personnel at SPP and
non-SPP airports, including the extent to which TSA had conducted a
workforce analysis.
To determine what factors airport operators cite as having contributed
to airports‘ decisions about whether to participate in the SPP, we:
* reviewed the results of a survey conducted by the Airports Council
International”North America, which represents local, regional, and
state governing bodies that own and operate commercial airports in the
United States, to determine how to make the SPP more attractive to
airports, and interviewed officials from three aviation
associations[Footnote 18] to obtain their views on the SPP;
* interviewed airport managers or airport security directors at the SPP
airports we visited to determine what factors led to their
participation in the SPP;
* interviewed airport managers or security directors at six non-SPP
airports we contacted to determine why they were not participating in
the SPP; and:
* interviewed TSA officials to identify their efforts to promote the
SPP.
We conducted this performance audit from August 2007 to November2008 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Results in Brief:
TSA‘s study comparing the cost and performance of screening services at
SPP and non-SPP airports had some design strengths, such as recognizing
that cost savings would be limited given the mandated structure of the
SPP and assessing whether performance data were collected in a uniform
manner. However, based on the criteria that we used, the design was
limited because TSA did not:
* Include the impact of potential overlapping administrative
staff[Footnote 19] on the costs of SPP airports. TSA is currently
conducting a workforce analysis to identify unnecessary redundancies in
its staffing, including overlapping administrative personnel; TSA
officials stated that this effort is ongoing and has no completion
date.
* Account for workers compensation, general liability insurance, and
some retirement costs paid by the federal government, as well as the
lost corporate income tax revenue from private screening contractors,
when replacing private with federal screening.
* Call for an assessment of the reliability of the costs and
performance data, as called for in federal accounting
standards.[Footnote 20]
* Document the rationale for including the five performance measures
reviewed in the study while excluding others.
* Call for statistical analyses to determine the level of confidence in
observed differences in performance between SPP and non-SPP airports.
The limitations in the design of TSA‘s study comparing the cost and
performance of SPP and non-SPP airports were due to several key factors
related to the study‘s purpose and data availability. For example, TSA
officials stated that they did not include some cost elements in the
study because they wanted to determine the impact of the SPP on TSA‘s
budget, rather than to determine the impact to the federal government
as a whole. In addition, for its comparison of performance, TSA
analyzed measures for which information was most complete, among other
things.
Because of these limitations, we believe that TSA should not use the
study as sole support for major policy decisions regarding the SPP.
TSA has taken actions to identify unnecessary redundancies in the
duties of administrative staff assigned to SPP and non-SPP airports,
but the agency has not completed these efforts.
* According to identified effective practices,[Footnote 21] strategic
workforce planning requires, among other things, that agencies develop
strategies that are tailored to address gaps in the number, deployment,
and alignment of human capital approaches for enabling and sustaining
the contributions of all critical skills and competencies.
* TSA is conducting a workforce analysis that is intended to identify
any redundancies. TSA has collected and analyzed information, such as
data on core functions, staffing levels, hub-spoke responsibilities,
skill sets, and collateral duties. However, steps that have not yet
been completed include implementing revised job analysis tools to
provide federal security directors (FSD)[Footnote 22] with greater
flexibility in staffing, and implementing organizational models to
ensure that there is consistency in reporting relationships and
utilization of positions. TSA officials said that the agency will be
continuously updating its analysis.
* TSA and SPP contractors at the airports we visited had mixed views
about whether unnecessary redundancies at SPP airports exist.
Various factors have contributed to airports‘ decisions about whether
to participate in the SPP.
* Selected officials at the six SPP airports we visited cited various
reasons for participation. Managers at three of the airports stated
that TSA had suggested that they apply to the SPP program due to TSA
staffing constraints, two stated that they decided to participate
because they were part of the pilot program, and another stated that he
believed that private screening contractors would provide better
service than the federal government.
* Officials at the six airports we contacted that have decided not to
join the SPP stated that their decision was based largely on their
satisfaction with TSA‘s passenger and baggage screening services.
We are recommending that if TSA plans to use its cost and performance
study in future decision making regarding the SPP, it revise its study
to address the methodological limitations that we have identified. TSA
generally agreed with our findings and recommendation.
Background:
ATSA was enacted on November 19, 2001, in response to the September 11,
2001, terrorist attacks. ATSA established TSA and charged it with
responsibility for security in all modes of transportation, including
aviation.
Prior to ATSA and the establishment of TSA, passenger and baggage
screening had been performed by private screening companies under
contract to airlines. ATSA required TSA to create a federal workforce
to assume the job of conducting passenger and checked-baggage screening
at commercial airports. The federal workforce was to be in place by
November 2002.
As required by ATSA, TSA began a 2-year pilot program using private
screening companies to screen passengers and checked baggage on
November 19, 2002, and selected five airports, one in each airport
category, to participate in the program.[Footnote 23]
Although an FSD is responsible for security at every commercial
airport, not every airport has an FSD dedicated solely to that airport.
Most category X airports have an FSD responsible for that airport
alone. Other airports are arranged in a ’hub and spoke“ configuration,
in which an FSD is located at or near a hub airport but also has
responsibility over one or more spoke airports of the same or smaller
size that are generally located in geographic proximity.
Beginning in November 2004, in accordance with ATSA, all commercial
airports with federal security screening became eligible to apply to
the newly established SPP.[Footnote 24] An airport operator may submit
to TSA an application to have the screening of passengers and checked
baggage at an airport carried out by screening personnel of a private
screening company, under a contract entered into between the private
screening contractor and TSA.
TSA acknowledged that TSA and SPP contractors are constrained by both
law and TSA policy, which limits opportunities to make programmatic
changes to improve contractor performance and achieve cost savings.
Furthermore, although TSA staffs are smaller at airports that have SPP
contractors, TSA continues to be responsible for overseeing screening
operations at SPP airports and for ensuring that contract screening
companies provide effective and efficient security operations.
TSA‘s SPP fiscal year 2009 budget is about $151.3 million.[Footnote 25]
As of September 2008, 10 commercial airports were participating in the
SPP, and TSA has approved the applications of 7 additional airports.
Figure 1: Airports That Are Currently Participating in or Have Received
Approval from TSA to Participate in the SPP;
This figure is a map of the airports that are currently participating
in or have received approval from TSA to participate in the SPP.
[Refer to PDF for image.]
Source: GAO analysis; Map Resources (map); TSA (data).
[End of figure]
Objective 1:
Methodological Limitations Could Affect the Usefulness of TSA‘s
Comparison of SPP and Non-SPP Airports:
While TSA‘s study comparing the cost of screening services at SPP and
non-SPP airports had some design strengths, such as recognizing that
cost savings would be limited given the mandated structure of the SPP
and using 2007 invoice data to determine the costs for the SPP
airports, its usefulness could be affected by the following
methodological limitations:
1. TSA‘s study design did not consider the impact of overlapping
administrative personnel on the costs of SPP airports. TSA is currently
conducting a workforce analysis to identify unnecessary redundancies in
its staffing, including overlapping administrative personnel, in
response to a Department of Homeland Security (DHS), Office of
Inspector General (OIG) recommendation. According to TSA officials,
this analysis is an ongoing effort and has no completion date.
2. TSA underestimated costs to the government for non-SPP airports
because the agency did not include all of the costs associated with
passenger and baggage screening services at non-SPP airports, such as
workers compensation and general liability insurance, and did not
reflect the income received by the government from corporate income
taxes paid by SPP contractors. Furthermore, the estimate for non-SPP
airports does not take into account the costs of certain retirement
benefits to be paid by OPM to TSA retirees. These costs elements can
impact the reliability of the cost estimate. According to Statement of
Federal Financial Accounting Standards No.4, Managerial Cost Accounting
Concepts and Standards for the Federal Government, the full cost of
programs is be reported to assist Congress and executives in making
informed decisions on program resources and to ensure that programs get
expected and efficient results.[Footnote 26]
TSA acknowledged that its study was narrow in scope and stated that its
purpose was to determine the impact of the SPP on TSA‘s budget, rather
than to determine the full cost of the program to the federal
government or to assist Congress or executives in decision making.
However, TSA stated that it had prepared several different versions of
its cost comparison of SPP and non-SPP airports that were excluded from
its final study report. At our request, TSA provided additional
calculations to include some of the costs that would be incurred if SPP
airports were federalized, as well as the income that private screening
contractors pay in corporate taxes to the federal government when those
same airports are operated by the contractors. These calculations
showed that the cost gap between the SPP and non-SPP airports decreased
from approximately 17.4 to 14.5 percent when the agency included some
of these costs, such as workers compensation and general liability
insurance, and offset tax revenues. If TSA had included the full cost
of federal retirement in its cost comparison, the gap would decrease
further.
3. TSA‘s study design based SPP costs primarily on actual invoice data
and non-SPP costs on estimates of TSA's cost in the first year of
transition if the SPP airports became federal airports in 2007. Thus,
there was more uncertainty embedded in the cost estimates for non-SPP
airports than those for SPP airports.
4. TSA‘s design did not include an analysis to determine how changes in
underlying assumptions would affect the size of the estimate, and its
cost comparison did not account for differences in screening
performance. Specifically, the TSA comparison did not analyze the
amount of costs associated with a particular level of performance.
According to OMB guidance, analyzing uncertainty is consistent with
best practices for preparing benefit-cost analysis of government
programs or projects.[Footnote 27] TSA stated that analyzing the amount
of costs associated with a particular level of performance would be
difficult and was not the purpose of the study. However, if
quantifiable performance measures are in place, TSA should be in a
position to compare the costs per performance measure across different
airports to determine how the costs per each performance measure vary
across airports. For example, performance measures, such as wait times
and threat image projection detection rates, are quantifiable.
5. TSA‘s comparison of SPP and non-SPP airports‘ costs was based on
fiscal year 2007 data. However, it is unclear how representative the
costs for 1year may be. For example, in future years, TSA would likely
incur workers compensation costs that TSA assumed would not be incurred
the first year it took over responsibility for operating the SPP
airports. According to GAO criteria for estimating and managing program
costs,[Footnote 28] estimates are time phased because program costs
usually span many years. Depending on the activities in the schedule,
some years may have more costs than others. Furthermore, anomalies can
be more easily discovered when the estimate is time phased. The
Catapult study evaluated cost data for multiple years.[Footnote 29]
However, in conducting its own study, the officials stated that TSA
analyzed fiscal year 2007 data because they were the most complete
information available for the SPP airports and that data from previous
years were not consistent with current TSA policy or business
practices. For example, according to the officials, the TSO workforce
was structured differently in prior years, and a recent expansion in
its part-time workforce has affected its operational costs.
6. TSA‘s study design did not call for conducting procedures needed to
ensure that cost data collected were reliable and did not prepare
documentation of its costing methodology called for in federal
accounting standards.[Footnote 30] Specific procedures and information
used in the cost study were not described in sufficient detail to allow
a knowledgeable person to carry out the procedures and to replicate the
results in their entirety.
7. Key assumptions and methods used were also not documented in
sufficient detail to justify the reasonableness of costs. According to
GAO‘s Standards for Internal Control in the Federal Government,
significant events, which can include key decisions about assumptions
and methods underlying the assignment of costs, are to be clearly
documented.[Footnote 31] TSA officials stated that the assumptions in
their study were reviewed by multiple parties within the agency and
that they could verbally ’walk someone through“ the details of their
analysis. However, without sufficient documentation, it will be
difficult for TSA to justify its decisions about assumptions and
methods used in its costing methodology.
TSA‘s comparison of screening performance at SPP and non-SPP airports
had some strengths, such as excluding performance data relating to
customer service because it had no assurance that the data were
collected in a uniform manner, but its usefulness could be affected by
several methodological limitations.
1. TSA‘s study design did not document the rationale for including the
five performance measures reviewed, while excluding other performance
measures. TSA officials stated that, for analysis purposes, they
included the five measures that they believed were the most meaningful
and for which they had complete data. While this is understandable,
TSA‘s study provided no evidence showing that the five performance
measures are the most meaningful indicators of performance or that they
provide a comprehensive basis for comparing the performance of SPP and
non-SPP airports.
2. In comparing the performance of SPP and non-SPP airports, TSA‘s
design did not control or otherwise account for other possible factors,
such as airport configuration or size, that could contribute to
performance differences but may not be associated with the SPP.
However, we recognize that controlling for such factors may be
difficult.
3. TSA‘s study design did not provide any statistical analyses to
indicate the level of confidence in the observed differences in
screening performance,consistent with generally accepted statistical
practices. The study also did not address the procedures needed to
ensure that performance data collected were reliable, and that there
was an appropriate, standardized, and generally accepted methodology
used for the analysis of the data. TSA officials stated that they did
not believe that statistical analyses were necessary because they
included only five performance measures in the study. However,
according to OMB guidance, federal agencies should conduct a
statistical and methodological review of all information products.
Among other things, they should review assumptions and limitations for
accuracy and appropriateness; base statements of comparisons and other
statistical conclusions on acceptable statistical practice, and when
performing comparison tests, test and report only the differences that
are substantively meaningful; and ensure that data sources and
technical documentation, including data limitations, are included or
referenced.[Footnote 32]
Without addressing the methodological limitations of TSA‘s study
comparing the cost and performance of SPP and non-SPP airports, we
could not determine the reliability of the study results. Reliable
information on both the costs and performance of federal programs, such
as the SPP, is essential for the effective management of government
operations and decision making. Therefore, the TSA study should not be
the sole support for major policy decisions.
Objective 2:
Efforts Are Under Way to Identify and Eliminate Any Unnecessary
Redundancies at SPP Airports:
TSA has initiated actions to identify and eliminate any unnecessary
redundancies at SPP airports between TSA administrative staff and
contractor personnel; however, these efforts are not yet complete.
In September 2006, the DHS/OIG recommended that TSA conduct a workforce
analysis of administrative staff and develop a staffing model to
identify the number of employees actually needed at airports.[Footnote
33]
In December 2007, the TSA contractor recommended that TSA explore
reducing the redundant general and administrative and overhead costs at
the SPP airports (see app. IV for a complete listing of the
recommendations that the TSA contractor made regarding the SPP).
* As an example of the importance of overhead costs and how they are
allocated, at one of the SPP airports we visited, general and
administrative and overhead costs accounted for half of the difference
in TSA‘s estimated $14 million cost difference between SPP and non-SPP
operations.
According to identified effective practices, strategic workforce
planning requires, among other things, that agencies develop strategies
that are tailored to address gaps in the number, deployment, and
alignment of human capital approaches for enabling and sustaining the
contributions of all critical skills and competencies.[Footnote 34]
SPP contractors and TSA have different views regarding whether
unnecessary redundancies exist at SPP airports.
Private screening contractors at four of the six SPP airports we
visited stated that they believed that unnecessary redundancies exist
between supervisory TSA and contract screening personnel. For example,
contractor officials at one airport said that TSA‘s screening managers
perform the same responsibilities as the contractor‘s supervisors. No
TSA personnel were assigned at the remaining two SPP airports that we
visited.
TSA officials at three of the SPP airports we visited stated that they
believed that there were no unnecessary redundancies in the supervisory
area between TSA and contract screening personnel. However, a TSA
official at another airport we visited suggested that duplication
between TSA and the contractor‘s staff could be reduced and resources
could be used more efficiently if the SPP concept were implemented on a
regional basis. Under the present system, a hub airport may participate
in the SPP although none of its spoke airports do so. Therefore, TSA
may use hub airport staff to perform various tasks, such as training,
for federal screening personnel working at the spoke airports, while
the private screening contractor may hire staff to perform similar
functions for private screening personnel working at the hub airport.
Our review of the organization charts and roles and responsibilities of
TSA and screening personnel at the selected SPP and non-SPP airports
revealed various staffing arrangements, but did not identify any
obvious unnecessary redundancies.
TSA officials stated that the agency is in the process of conducting a
workforce analysis to better understand the unnecessary redundancy
concerns regarding the duties of administrative staff, including
supervisory positions, at SPP and non-SPP airports, and develop a
staffing model to more effectively utilize administrative staff at its
airports. From November 2006 through January 2007, TSA visited a sample
of 37 airports and held focus groups with an additional 27 FSDs and
their staff to collect data and has conducted an analysis associated
with core functions, staffing levels, hub-spoke responsibilities, skill
sets, and collateral duties.[Footnote 35] TSA analyzed the data from
January 2007 through March 2007. Steps that have not yet been completed
include providing FSDs with greater flexibility in staffing and
implementing organizational models to ensure that there is consistency
in reporting relationships and utilization of positions. TSA officials
said that these efforts will be ongoing and collateral with its effort
to finalize and budget for the new staffing model.
In developing the workforce analysis and staffing model recommended by
DHS/OIG, TSA is taking important steps to ensure that its resources are
being allocated appropriately at both SPP and non-SPP airports. It is
important that TSA continue these efforts and use the results of the
analysis to eliminate any unnecessary redundancies and ensure that TSA
staff are used efficiently. The issue of possible redundancies has
potentially important implications for costs comparisons of SPP and non-
SPP airports. If there are administrative staffing redundancies at
individual airports and at TSA headquarters, the cost of the SPP
program would be higher than necessary.
Objective 3:
Various Factors Contribute to Airports‘ Decisions regarding SPP
Participation:
Various factors have contributed to airports‘ decisions about whether
to participate in the SPP.
* Managers at two of the SPP airports we visited stated that TSA had
strongly suggested that they apply to the SPP because of constraints on
the number of TSOs that TSA had at that time. Another airport manager
said that he applied to participate in the SPP so that he could gain
screeners at another airport, which he also managed. He was reportedly
told by TSA that the other airport would not be staffed with additional
TSA screeners due to TSA resource constraints, so he applied to
participate in the SPP at both airports.
* Another airport manager stated that he decided to participate in the
SPP because he believed that private screeners would provide better
customer service.
* Managers at the remaining two airports we visited stated that they
had decided to continue using private screeners because of their
satisfactory experience with participating in TSA‘s 2-year pilot
program that preceded the SPP.
* Officials at the six airports that we contacted that decided not to
join the SPP stated that they were pleased with the federal screener
workforce. In addition, officials at three of these airports said that
they had no interest in the SPP.
An Association Survey Provided Views on SPP Participation:
In March 2007, the Airports Council International-North America (ACI-
NA) reported on the results of a survey it conducted to determine how
to make the SPP more attractive to airports.[Footnote 36] The survey
was sent to ACI-NA airport official representatives and Public Safety
and Security Committee airport members. ACI-NA received a total of 31
survey responses.[Footnote 37] Twenty-two, or 71 percent, of the
respondents said they were not interested in participating in the SPP.
The most frequent reasons given for this lack of interest included:
* the airport was satisfied with TSA screening services,
* screening is a federal government responsibility, and:
* the SPP does not allow airports to have managerial control.
The survey respondents reported that liability and contract control and
oversight were also important issues with respect to SPP participation.
The most frequently cited advantages of the SPP were staffing
flexibility and customer service.
Officials at Selected Aviation Associations and Organizations Provided
Views about SPP Participation:
Officials at all three of the aviation associations we interviewed
stated that airports are concerned about liability associated with
participating in the SPP. They said that the SAFETY Act,[Footnote 38]
which offers liability and other protection to sellers of qualified
antiterrorism technologies,including private screening contractors, has
not yet been tested and that some airport managers may worry that the
public will hold them liable if a security incident occurs and they
have chosen to participate in the SPP.
However, 49 U.S.C. § 44920(g) provides that, notwithstanding any other
provision of law, an operator of an airport shall not be liable for any
claims for damages relating to an airport operator‘s decision to submit
or not submit an application to opt out of federal screening, or any
acts of negligence, gross negligence, or intentional wrongdoing by a
qualified private screening company or any of its employees while
performing its duties under contract with TSA or by employees of the
federal government providing passenger and property security screening
services at an airport.
The aviation associations suggested that airports would be more
interested in the SPP if they could:
* select the private screening contractor that would be awarded the
passenger and baggage screening contract at their respective airports
and:
* share in any cost savings resulting from their participation in the
program.
Conclusions:
With regard to the SPP, as TSA acknowledged, TSA and its private
screening contractors are constrained by both law and TSA policy, which
limits opportunities to make programmatic changes to improve contractor
performance and achieve cost savings. Therefore, it is understandable
that differences in performance and costs of SPP and non-SPP airports
may not vary considerably.
While it is commendable that TSA took the initiative to conduct a study
comparing the cost and performance of SPP and non-SPP airports, the
study contained several methodological limitations that we identified,
such as the exclusion of certain cost elements and the rationale for
why certain performance measures were included in the study. These
limitations could affect the accuracy and reliability of the results,
and its usefulness in informing future management decisions regarding
the SPP. In addition, since TSA‘s workforce analysis efforts are still
ongoing, it is unclear to what extent a reduction of any potential
unnecessary redundancies could lead to additional costs savings in the
SPP.
As additional airports apply to participate in the SPP, it is important
that TSA have accurate and reliable information about screening cost
and performance at both SPP and non-SPP airports so that the agency can
make informed decisions when considering whether to approve airport
participation in the SPP. It is also important that TSA have a well-
developed and well-documented approach for analyzing the cost and
performance of SPP airports if such comparisons are made in the future.
Because of the limitations that we have identified, the TSA study
should not be used as the sole support for making major policy
decisions.
Recommendation for Executive Action:
If TSA plans to rely on its study‘s comparisons of cost and performance
of SPP and non-SPP airports for making future management decisions
regarding the SPP, we recommend that the Assistant Secretary, TSA,
update the study to address the methodological limitations that we have
identified.
Agency Comments:
We provided a draft copy of this briefing to TSA for its review.TSA, in
its written comments, generally concurred with our findings and
recommendation and stated that its cost and performance analysis of
private-sector airport screening will be updated as data become
available. TSA also provided technical comments, which we have
incorporated into the briefing as appropriate. The full text of TSA‘s
comments is reprinted in enclosure II of our report.
GAO Contacts:
Should you or your staff have any questions on the matters discussed in
this briefing, please contact Cathleen A. Berrick at (202) 512-3404 or
berrickc@gao.gov or Glenn Davis at (202) 512-4301 or davisg@gao.gov.
Appendixes:
Appendix I: TSA‘s Approach and Methodology for Estimating Costs of SPP
and Non-SPP Airports;
Appendix II: Methodology and Findings for the TSA Contractor‘s Cost
Analysis;
Appendix III: Methodology and Findings for the TSA Contractor‘s
Performance Analysis;
Appendix IV: Recommendations Provided by the TSA Contractor to Improve
the SPP;
Appendix I:
Table: TSA‘s Approach and Methodology for Estimating Costs of SPP and
Non-SPP Airports:
Topic: Data source;
SPP airport cost estimate: * Invoice data from fiscal year 2007 for six
SPP airports;
Non-SPP airport cost estimate: * Cost estimates were based on what TSA
would have incurred if the six airports were run as fully federal or
non-SPP airports in fiscal year 2007.
Topic: Direct labor;
SPP airport cost estimate: Screener productive labor hours:
* Wage rates from invoice data and cost proposals;
* Includes on-site labor hours for management;
* Overtime pay;
Non-SPP airport cost estimate: Screener productive and nonproductive
labor hours:
* Same as SPP wage data;
* Includes increased FSD staff that would be needed if SPP was not
present:
* Premium pay.
Topic: Fringe;
SPP airport cost estimate: * Includes FICA, 401K, health, dental, and
life insurance, workers compensation, flex spending account, paid
holidays, personal time office, military leave, jury duty pay, and
bonuses;
Non-SPP airport cost estimate: * Includes FICA, Medicare, thrift
savings plan, health and life insurance, retirement, and awards.
Topic: General and administrative and overhead;
SPP airport cost estimate: * Overhead: management support staff;
* General and administrative: home office expenses, including corporate
management, accounting, human resources, information technology, and
contract administration;
Non-SPP airport cost estimate: Federal Security Staff Non-Personnel
Compensation and Benefits, Non-Personnel Compensation and Benefits,
entire Headquarters Administration Program, Project and Activity in the
Support Appropriation, hazardous materials, Representation Fund, Model
Workplace Non-Personnel Compensation and Benefits, Tort Claims, Safety
Hazard Mitigation, TSO Scheduling Tool, and the Department of Homeland
Security Working Capital Fund.
Topic: Other direct costs;
SPP airport cost estimate: * Includes consumables, recruiting,
assessments, credentials, facilities, travel, uniforms, general
liability insurance, and office equipment costs;
Non-SPP airport cost estimate: * Includes consumables, recruiting
assessments, credentialing, facilities, travel, uniforms, and airport
parking.
Topic: Fees;
SPP airport cost estimate: * Includes contract fees, such as award fee,
base fee, and fixed fee;
Non-SPP airport cost estimate: * Fees not incurred for non-SPP
airports.
Source: TSA.
[End of table]
Appendix II: Methodology and Findings for the TSA Contractor‘s Cost
Analysis:
TSA‘s contractor used two separate models to develop its cost analysis
of SPP and non-SPP airports.
Under the first model, the contractor compared the costs of six SPP
airports with the costs of six comparable non-SPP airports with
normalizing[Footnote 39] adjustments.
Figure 2: Airports Included in the Contractor‘s Cost Analysis:
This figure is a chart with the following data:
SPP airport: San Francisco International Airport;
Comparable airport: Logan International Airport.
SPP airport: Kansas City International Airport;
Comparable airport: Salt Lake City International Airport.
SPP airport: Greater Rochester International Airport;
Comparable airport: Syracuse-Hancock International Airport.
SPP airport: Joe Foss Field;
Comparable airport: Missoula International Airport.
SPP airport: Jackson Hole Airport;
Comparable airport: Central Illinois Regional Airport.
SPP airport: Tupelo Regional Airport;
Comparable airport: Barkley Regional Airport.
[Refer to PDF for image]
Source: Catapult Consultants.
[End of figure]
Under the second model, the contractor used data from approximately 450
airports to compare the costs for each of the 6 SPP airports to a
regression-based model[Footnote 40] for a fully federal operation at
the same SPP airport. That is, the model was used to determine what the
SPP airport would cost if it used federal screeners.
The contractor concluded that SPP airports have historically cost more
to operate than airports with federal screeners. According to the
regression-based model, the average SPP cost premium is 9 percent,
while the adjusted comparable model showed an average SPP cost premium
of 17 percent.
Appendix III: Methodology and Findings for the TSA Contractor‘s
Performance Analysis:
The TSA contractor analyzed four performance measures:[Footnote 41]
1. Threat image projection detection rates
2. Recertification pass rate
3. Wait times
4. Customer satisfaction
The TSA contractor:
* Compared the performance of six SPP airports to six ’comparable“ non-
SPP airports and to the national average for the appropriate airport
category.
* Determined that an airport was a better or worse performer by
comparing SPP performance to its airport category average.
* Examined 4 years of performance data (fiscal years 2004 through 2007).
The contractor‘s analysis found that SPP airports‘ overall performance
results are equal to or better than those delivered by non-SPP
airports.
Appendix IV: Recommendations Provided by the TSA Contractor to Improve
the SPP:
The contractor‘s December 2007 report, which summarized the results of
its SPP analysis, included the following recommendations to TSA to
improve the operational effectiveness and cost efficiency of the SPP:
1. Explore reducing the redundant general and administrative and
overhead costs at SPP airports.
2. Explore the use of the SPP model as a tool to improve performance at
low-performing fully federal airports.
3. Explore the use of the SPP model at ’hard-to-hire“ airports and for
airports with significant seasonal requirements.
4. Explore providing additional ’degrees of freedom“ to SPP contractors
to foster innovation, superior performance, and cost controls.
TSA officials stated that they have not committed to implementing the
recommendations made by the contractor.
TSA officials informed us that the agency maintains a neutral position
on the SPP and neither encourages or discourages airports from applying
to participate in the program.
Related GAO Products:
Aviation Security: TSA‘s Staffing Allocation Model Is Useful for
Allocating Staff among Airports, but Its Assumptions Should Be
Systematically Reassessed. GAO-07-299. Washington, D.C.: February 28,
2007.
Aviation Security: Progress Made to Set Up Program Using Private-Sector
Airport Screeners, but More Work Remains. GAO-06-166. Washington, D.C.:
March 31, 2006.
Aviation Security: Preliminary Observations on TSA‘s Progress to Allow
Airports to Use Private Passenger and Baggage Screening Services. GAO-
05-126. Washington, D.C.: November 19, 2004.
Aviation Security: Private Screening Contractors Have Little
Flexibility to Implement Innovative Approaches. GAO-04-505T.
Washington, D.C.: April 22, 2004.
Aviation Security: Transportation Security Administration Faces
Immediate and Long-Term Challenges. GAO-02-971T. Washington, D.C.: July
25, 2002. Page 48 GAO-09-27R Airport Screening
[End of section]
Enclosure II: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
Homeland Security:
December 30, 2008:
Ms. Cathleen A. Berrick:
Director, Homeland Security and Justice Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Ms. Berrick:
Re: Draft Report GAO-09-27R, Aviation Security: TSA's Cost and
Performance Study of Private-Sector Airport Screening (GAO Job Code
440647)
The Department of Homeland Security appreciates the opportunity to
review and comment on the draft report referenced above. The report
documents the Government Accountability Office's (GAO) analysis of the
Transportation Security Administration's (TSA) cost and performance
study of Screening Partnership Program (SPP) airports, actions TSA has
taken to identify and reduce personnel redundancies, and factors that
contribute to an airport operator's decision about whether to
participate in the SPY.
TSA appreciates that GAO recognized the underlying constraints when
analyzing cost and performance of SPP and non-SPP airports. GAO did not
identify any redundancies between administrative staff assigned to SPP
and non-SPP airports, and noted TSA's efforts to identify any such
redundancies. Finally, GAO found that various factors contribute to
airports' decisions to participate in SPP.
GAO noted some limitations of the cost and performance study of SPP due
to study purpose and data availability, and recommends that the study
be revised to account for those limitations if TSA plans to use the
study for SPP decision making. TSA officials concur with this
recommendation, and as the report notes, update the analysis as data
becomes available.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison Office:
[hyperlink, http://www.dhs.gov]
[End of section]
[1] Federal screeners are employed by the Transportation Security
Administration (TSA) and are referred to as transportation security
officers; private screeners are employed by qualified private screening
companies under contract to TSA.
[2] See Pub. L. No. 107-71, § 108, 115 Stat. 597, 611-13 (2001)
(codified at 49 U.S.C. § 44919).
[3] See Pub. L. No. 107-71, § 108, 115 Stat. at 611-13 (codified as
amended at 49 U.S.C. § 44920).
[4] Catapult Consultants, Private Screening Operations: Business Case
Analysis, Transportation Security Administration, Screening Partnership
Program, December 14, 2007.
[5] Transportation Security Administration, A Report on SPP Airport
Cost and Performance Analysis and Comparison to Business Case Analysis
Finding, February 1, 2008.
[6] TSA classifies the commercial airports in the United States into
one of five security risk categories (X, I, II, III, and IV) based on
various factors, such as the total number of takeoffs and landings
annually, and other special security considerations. In general,
category X airports have the largest number of passenger boardings, and
category IV airports have the smallest.
[7] The Threat Image Projection system is designed to test TSOs‘ and
private screeners‘ detection capabilities by projecting threat images,
including images of guns and explosives, into bags as they are
screened. TSOs and private screeners are responsible for positively
identifying the threat image and calling for the bag to be searched.
[8] TSOs and private screeners must pass an annual standardized
recertification test composed of image, job knowledge, and Standard
Operating Procedures tests.
[9] See, e.g., § 44920(c) (providing that private screening companies
selected by TSA must provide its screening personnel compensation and
other benefits at a level not less than the compensation and other
benefits provided to federal government personnel).
[10] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/GAO-AIMD-00-21.3-1]
(Washington, D.C.: November 1999).
[11] Federal Financial Accounting Standards No. 4, Managerial Cost
Accounting Concepts and Standards for the Federal Government.
[12] GAO, Cost Assessment Guide: Best Practices for Estimating and
Managing Program Costs, [hyperlink, http://www.gao.gov/products/GAO-07-
1134SP] (Washington, D.C.: July 2007).
[13] OMB Circular A-76, Performance of Commercial Activities, and OMB
Circular A-94, Guidelines and Discount Rates for Benefit-Cost Analysis
of Federal Programs.
[14] OMB, Standards and Guidelines for Statistical Surveys, September
2006; Guidelines for Ensuring and Maximizing the Quality,
Objectivity,Utility, and Integrity of Information Disseminated by
Federal Agencies, October 1, 2001; and Program Assessment Rating Tool
Guidance, No. 2008-01, January 29, 2008.
[15] Throughput refers to the number of passengers and bags that are
processed by TSA.
[16] GAO, Human Capital: Key Principles for Effective Strategic
Workforce Planning, [hyperlink, http://www.gao.gov/products/GAO-04-39]
(Washington, D.C.: Dec. 11, 2003).
[17] OPM, Workforce Planning Model, September 2005.
[18] Air Transport Association, Airports Council International”North
America, and the American Association of Airport Executives. Because we
selected a nongeneralizable sample of aviation organizations, the
information we gathered from our interviews with these organizations
cannot be used to make inferences about all aviation organizations.
However, we believe that the information we obtained was useful in
learning about how such organizations view the SPP.
[19] TSA administrative staff include federal security directors,
deputy federal security directors, assistant federal security
directors, scheduling operations officers, stakeholder liaisons,
training coordinators/specialists, customer service managers,
industrial engineers/metric specialists, administrative officers, human
resources specialists,financial specialists, executive secretaries,
security (Office Automation), and screening managers.
[20] Federal Financial Accounting Standards No. 4, Managerial Cost
Accounting Concepts and Standards for the Federal Government.
[21] [hyperlink, http://www.gao.gov/products/GAO-04-39].
[22] FSDs are the ranking TSA authorities responsible for leading and
coordinating TSA security activities at the nation‘s commercial
airports.
[23] See 49 U.S.C. § 44919.
[24] See 49 U.S.C. § 44920.
[25] See 152 Cong. Rec. H9792, 9797-98 (daily ed. Sept. 24, 2008)
(explanatory statement accompanying Pub. L. No. 110-329, Div. D, 122
Stat. 3574 (2008), the Department of Homeland Security Appropriations
Act, 2009).
[26] Statement of Federal Financial Accounting Standards No.4,
Managerial Cost Accounting Concepts and Standards for the Federal
Government, establishes standards for managerial cost accounting
information at federal agencies.
[27] OMB Circular A-94 (Revised) provides guidelines and discount rates
for benefit cost analysis of federal programs. Among other things, OMB
Circular A-76 instructs agencies to base decisions on competitions
among public and private-sector entities in accordance with the Federal
Acquisition Regulation, which allows for considering the relative
importance of both price and technical factors, commonly known as the
’best value“ trade-off process. The use of best value permits trade-
offs between price and nonprice factors, allowing acceptance of other
than the lowest-priced proposal.
[28] GAO, Cost Assessment Guide: Best Practices for Estimating and
Managing Program Costs, [hyperlink, http://www.gao.gov/products/GAO-07-
1134SP] (Washington, D.C.: July 2007).
[29] The study showed that the cost of operating screening was
generally higher at the six SPP airports for each of the years that it
studied.
[30] Statement of Federal Financial Accounting Standards No.4,
Managerial Cost Accounting Concepts and Standards for the Federal
Government.
[31] [hyperlink, http://www.gao.gov/products/GAO-AIMD-00-21.3-1].
[32] OMB, Standards and Guidelines for Statistical Surveys.
[33] Department of Homeland Security, Office of Inspector General,
Review of TSA Non-Screener Administrative Positions, OIG-06-65,
September 2006.
[34] [hyperlink, http://www.gao.gov/products/GAO-04-39].
[35] This sample represented 52 percent of administrative personnel
nationwide; included hub, spoke, stand-alone, and privatized airports;
and was based on characteristics that were most likely to impact
staffing needs, such as airport category, hub-spoke composition,
privatized versus federalized, and geographic area.
[36] Airports Council International-North America, Screening
Partnership Program: Interest and Considerations, March 12, 2007.
[37] Due to the low response rate to the survey, the views reported in
the survey reflect the views of the 31 who responded to the survey and
not necessarily the views of the membership as a whole.
[38] Support Anti-terrorism by Fostering Effective Technologies Act of
2002, Pub. L. No. 107-296, §§ 861-65, 116 Stat. 2135, 2238-42. See 71
Fed. Reg. 33,147 (June 8, 2006) (implementing SAFETY Act regulations
codified at 6 C.F.R. pt. 25).
[39] The purpose of data normalization (or cleansing) is to make a data
set consistent with and comparable to other data used in an estimate.
[40] A regression-based model is used to predict one variable from one
or more other variables. Regression models provide the scientist with a
powerful tool, allowing predictions about past, present, or future
events to be made with information about past or present events.
[41] According to the contractor‘s study, these four performance
measures were nationally standardized and had large enough sample sizes
to conduct meaningful analysis. While some of these measures were
similar to those included in TSA‘s study, only one identical
performance measure was included in both analyses.
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