Transit Security Grant Program
DHS Allocates Grants Based on Risk, but Its Risk Methodology, Management Controls, and Grant Oversight Can Be Strengthened Gao ID: GAO-09-491 June 8, 2009From fiscal years 2006 through 2008, the Department of Homeland Security (DHS) has allocated about $755 million dollars to transit agencies through its Transit Security Grant Program (TSGP) to protect transit systems and the public from terrorist attacks. GAO was asked to evaluate the extent to which (1) TSGP funds are allocated and awarded based on risk; (2) DHS has allocated, awarded, and distributed TSGP grants in accordance with statutory deadlines and leading practices for collaborating agencies; and (3) DHS has evaluated the effectiveness of the TSGP and its investments. To address these objectives, GAO reviewed the TSGP risk model, fund allocation methodology and program documents, such as TSGP guidance, and interviewed DHS and transit officials, among other steps.
DHS has used a risk analysis model to allocate TSGP funding and award grants to higher-risk transit agencies, although transit agency officials have expressed concerns about changes that have occurred since the TSGP's inception, such as revised priorities. The TSGP risk model includes all three elements of risk--threat, vulnerability, and consequence--but can be strengthened by measuring variations in vulnerability. DHS has held vulnerability constant, which limits the model's overall ability to assess risk and more precisely allocate funds. Although the Transportation Security Administration (TSA) allocated about 90 percent of funding to the highest-risk agencies, lower-risk agency awards were based on other factors in addition to risk. In addition, TSA has revised the TSGP's approach, methodology and funding priorities each year since 2006. These changes have raised predictability and flexibility concerns among transit agencies because they make engaging in long-term planning difficult. DHS met the statutory timeline requirements for allocating and awarding grants, but the two agencies that manage the TSGP--TSA and Federal Emergency Management Agency (FEMA)--lack defined roles and responsibilities, and only 3 percent of the funds awarded for fiscal years 2006 through 2008 have been spent as of February 2009. There is no documentation articulating the roles and responsibilities of the agencies, and grant information has not been passed between the two agencies which affected TSA's ability to share grant status information with transit agencies. DHS met statutory deadlines for releasing grant guidance and acting upon applications, but management and resource issues have resulted in delays in approving projects and making funds available, including (1) lengthy project negotiations between transit agencies and TSA; (2) a backlog of required environmental reviews; and (3) a reported lack of personnel to conduct required reviews. As a result, according to FEMA records, as of February 2009, transit agencies have spent about $21 million of the $755 million that has been awarded for fiscal years 2006 through 2008. This spending rate is, in part, caused by agencies receiving authorization to spend grant dollars late in the grant period. Despite concerns over delays, FEMA has not communicated time frames for providing funding. In April 2004, GAO reported that timely grant awards are imperative to provide intended benefits. DHS has reported taking some actions to address delays, including shortening project approval times and hiring staff, but the effectiveness of these efforts is unknown. Although FEMA has taken initial efforts to develop measures to assess the effectiveness of its grant programs, TSA and FEMA lack a plan and related milestones for developing measures specifically for the TSGP, and thus DHS does not have the capability to measure the effectiveness of the program or its investments. Without such a plan, it will be difficult for TSA and FEMA to provide reasonable assurance that measures are being developed to assess the effectiveness of the program as intended. While FEMA is responsible for the financial controls and audits of the TSGP, it does not have a mechanism to systematically collect data and track grant projects throughout the grant process. As a result, FEMA cannot assess whether awards are timely or funds are being used effectively to reduce risk and increase transit system security
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-09-491, Transit Security Grant Program: DHS Allocates Grants Based on Risk, but Its Risk Methodology, Management Controls, and Grant Oversight Can Be Strengthened
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Report to the Chairman, Committee on Homeland Security, House of
Representatives:
United States Government Accountability Office:
GAO:
June 2009:
Transit Security Grant Program:
DHS Allocates Grants Based on Risk, but Its Risk Methodology,
Management Controls, and Grant Oversight Can Be Strengthened:
GAO-09-491:
GAO Highlights:
Highlights of GAO-09-491, a report to the chairman, Committee on
Homeland Security, House of Representatives.
Why GAO Did This Study:
From fiscal years 2006 through 2008, the Department of Homeland
Security (DHS) has allocated about $755 million dollars to transit
agencies through its Transit Security Grant Program (TSGP) to protect
transit systems and the public from terrorist attacks. GAO was asked to
evaluate the extent to which (1) TSGP funds are allocated and awarded
based on risk; (2) DHS has allocated, awarded, and distributed TSGP
grants in accordance with statutory deadlines and leading practices for
collaborating agencies; and (3) DHS has evaluated the effectiveness of
the TSGP and its investments. To address these objectives, GAO reviewed
the TSGP risk model, fund allocation methodology and program documents,
such as TSGP guidance, and interviewed DHS and transit officials, among
other steps.
What GAO Found:
DHS has used a risk analysis model to allocate TSGP funding and award
grants to higher-risk transit agencies, although transit agency
officials have expressed concerns about changes that have occurred
since the TSGP‘s inception, such as revised priorities. The TSGP risk
model includes all three elements of risk”threat, vulnerability, and
consequence”but can be strengthened by measuring variations in
vulnerability. DHS has held vulnerability constant, which limits the
model‘s overall ability to assess risk and more precisely allocate
funds. Although TSA allocated about 90 percent of funding to the
highest-risk agencies, lower-risk agency awards were based on other
factors in addition to risk. In addition, TSA has revised the TSGP‘s
approach, methodology and funding priorities each year since 2006.
These changes have raised predictability and flexibility concerns among
transit agencies because they make engaging in long-term planning
difficult.
DHS met the statutory timeline requirements for allocating and awarding
grants, but the two agencies that manage the TSGP”TSA and FEMA”lack
defined roles and responsibilities, and only 3 percent of the funds
awarded for fiscal years 2006 through 2008 have been spent as of
February 2009. There is no documentation articulating the roles and
responsibilities of the agencies, and grant information has not been
passed between the two agencies which affected TSA‘s ability to share
grant status information with transit agencies. DHS met statutory
deadlines for releasing grant guidance and acting upon applications,
but management and resource issues have resulted in delays in approving
projects and making funds available, including (1) lengthy project
negotiations between transit agencies and TSA; (2) a backlog of
required environmental reviews; and (3) a reported lack of personnel to
conduct required reviews. As a result, according to FEMA records, as of
February 2009, transit agencies have spent about $21 million of the
$755 million that has been awarded for fiscal years 2006 through 2008.
This spending rate is, in part, caused by agencies receiving
authorization to spend grant dollars late in the grant period. Despite
concerns over delays, FEMA has not communicated time frames for
providing funding. In April 2004, GAO reported that timely grant awards
are imperative to provide intended benefits. DHS has reported taking
some actions to address delays, including shortening project approval
times and hiring staff, but the effectiveness of these efforts is
unknown.
Although FEMA has taken initial efforts to develop measures to assess
the effectiveness of its grant programs, TSA and FEMA lack a plan and
related milestones for developing measures specifically for the TSGP,
and thus DHS does not have the capability to measure the effectiveness
of the program or its investments. Without such a plan, it will be
difficult for TSA and FEMA to provide reasonable assurance that
measures are being developed to assess the effectiveness of the program
as intended. While FEMA is responsible for the financial controls and
audits of the TSGP, it does not have a mechanism to systematically
collect data and track grant projects throughout the grant process. As
a result, FEMA cannot assess whether awards are timely or funds are
being used effectively to reduce risk and increase transit system
security.
What GAO Recommends:
GAO recommends, among other things, that DHS strengthen its methodology
for determining risk by measuring variations in vulnerability, define
Transportation Security Administration (TSA) and Federal Emergency
Management Agency (FEMA) roles for managing and monitoring the TSGP,
develop a plan with milestones for measuring TSGP performance, and
develop a process to systematically collect data, track grant
activities, and communicate the availability of grant funding to
transit agencies. DHS concurred with GAO‘s recommendations and
discussed actions to address them.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/products/GAO-09-491]. For more information,
contact Stephen M. Lord at (202) 512-8777 or lords@gao.gov.
[End of section]
Contents:
Letter:
Background:
DHS Uses Elements of Risk to Allocate and Award Funds to Transit
Agencies, but the Risk Model Can Be Strengthened and Transit
Stakeholders Expressed Concerns about Funding Flexibility:
TSA and FEMA Lack Documented Roles and Responsibilities for
Administering the TSGP, and Although Statutory Timeline Requirements
Were Met, Little Money Has Been Expended:
Additional Steps Needed to Develop Performance Measures to Assess TSGP
Grant Project Effectiveness and to Fulfill Administrative
Responsibilities:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Fiscal Year 2008 Project Effectiveness Groupings:
Appendix III: TSGP Risk Analysis Model:
Appendix IV: TSGP Tier I and II Regions:
Appendix V: Tier II National Review Panel Criteria, 2006 through 2008:
Appendix VI: TSGP Priorities 2006 through 2009:
Appendix VII: FEMA's Environmental and Historic Preservation Review
Project Types:
Appendix VIII: Comments from the Department of Homeland Security:
Appendix IX: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: TSGP Allocation for Fiscal Years 2006 through 2009:
Table 2: Thirty Domestic Mass Transit and Passenger Rail Agencies
Interviewed:
Table 3: TSGP Tier I Regions for 2009:
Table 4: TSGP Tier II Regions for 2009:
Figures:
Figure 1: Overview of the Grant Process for TSGP Funds for Fiscal Years
2007 through 2008:
Figure 2: DHS's Scoring Methodology for Fiscal Year 2008:
Figure 3: TSGP Funds Expended and Unexpended, Fiscal Years 2006 though
2008:
Figure 4: Average Time for TSA and FEMA to Approve Projects for Fiscal
Year 2006 through 2007:
Figure 5: TSGP Risk Model:
Abbreviations:
APTA: American Public Transportation Association:
BASE: Baseline Assessment for Security Enhancements:
DHS: Department of Homeland Security:
DOT: Department of Transportation:
EHP: Environmental and Historical Preservation:
FEMA: Federal Emergency Management Agency:
FTA: Federal Transit Administration:
GAN: Grant Adjustment Notice:
GPD: Grant Programs Directorate:
HSPD-7: Homeland Security Presidential Directive 7:
IED: improvised explosive device:
IID: improvised incendiary device:
MOU: Memorandum of Understanding:
NIPP: National Infrastructure Protection Plan:
NRP: National Review Panel:
OEHP: Office of Environmental and Historical Preservation:
RTSWG: Regional Transit Security Working Group:
TSA: Transportation Security Administration:
TSGP: Transit Security Grant Program:
TS-SSP: Transportation Systems-Sector Specific Plan:
UASI: Urban Area Security Initiative:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
June 8, 2009:
The Honorable Bennie G. Thompson:
Chairman:
Committee on Homeland Security:
House of Representatives:
Dear Mr. Chairman:
American transit passengers, who take approximately 34 million trips
each weekday, rely on mass transit and passenger rail systems to
provide efficient, reliable, and safe transportation. However,
terrorist attacks on mass transit systems around the world--such as the
2005 attack on London's underground rail and bus systems, which
resulted in 52 fatalities and over 700 injuries--highlight the
vulnerability of mass transit systems and the need for increased focus
on securing these systems. In an effort to strengthen the security of
the nation's mass transit and passenger rail systems against risks
associated with potential terrorist attacks, the Department of Homeland
Security (DHS) has awarded grant funding to the nation's transit
agencies that DHS has deemed to be of highest risk.[Footnote 1] From
2003 to 2008, DHS provided over $1 billion in federal grant funding to
U.S. mass transit and passenger rail agencies for a variety of security
activities, including developing security plans, purchasing or
upgrading security equipment, and providing security training to
transit employees.[Footnote 2] In fiscal year 2009, DHS plans to award
an additional $373 million to mass transit and passenger rail agencies
through the Transit Security Grant Program (TSGP) to protect the
traveling public from acts of terrorism, major disasters, and other
emergencies. Furthermore, the American Recovery and Reinvestment Act of
2009 appropriated an additional $150 million to DHS for the TSGP.
[Footnote 3]
Since fiscal year 2005, the federal government has provided funding for
mass transit and passenger rail security through the TSGP--one of six
grant programs that constitute DHS's transportation security grant
portfolio. The TSGP provides funds to owners and operators of mass
transit and passenger rail systems (which include intracity bus,
commuter bus, and all forms of passenger rail, including Amtrak) to
protect critical surface transportation infrastructure.[Footnote 4]
While the TSGP provides funding for mass transit, passenger rail
(Amtrak) and other systems, this report focuses exclusively on funds
provided for mass transit because they represent most of the funding.
You requested that we evaluate the TSGP, including the risk analysis
model and risk-based allocation methodology used to guide grant awards,
as well as the management of the program. Specifically, this report
addresses the extent to which:
1. TSGP funds are allocated and awarded based on risk, and grant
requirements have changed since 2006;
2. DHS has allocated, awarded, and distributed TSGP grants in
accordance with statutory deadlines and leading practices for
collaborating agencies; and:
3. DHS has evaluated the effectiveness of the TSGP as well as
investments made using funds awarded through the TSGP.
To assess the extent to which TSGP funds were allocated and awarded
based on risk and grant requirements have changed since 2006, we
analyzed DHS documents, including those related to the TSGP risk
analysis model for fiscal years 2007 through 2008, TSGP guidance, and
TSGP priorities, and attended TSGP presentations held by the
Transportation Security Administration (TSA) and Federal Emergency
Management Agency (FEMA). To provide a basis for examining DHS's
efforts to carry out risk management principles, we compared DHS's risk-
based methodology--which includes its TSGP risk analysis model--to both
the National Infrastructure Protection Plan (NIPP) and the risk
management framework that we developed based on best practices and
other criteria.[Footnote 5] We also reviewed the steps that TSA and
FEMA took to ensure the reliability of the risk model by interviewing
officials responsible for managing the model as well as reviewing DHS's
documentation on the model. We determined that the model's inputs and
results were sufficiently accurate for our purposes. To assess the
extent to which grant requirements have changed since 2006, we
interviewed TSA and FEMA officials about the TSGP grant determination
process used in fiscal years 2006, 2007, and 2008 and about the changes
made to the process for fiscal year 2009. In 2006, TSA began managing
the policy aspect of the TSGP, such as establishing grant priorities.
For this reason, we focused our review of the TSGP from this point
through the beginning of the fiscal year 2009 grant process.
To review whether DHS has administered the TSGP in accordance with
statutory deadlines and leading practices for collaborating agencies,
and to determine the status of grant expenditures, we reviewed TSGP
guidance, applicable laws, and grant project data from TSA for fiscal
years 2006 through 2008. We also obtained grant approval data from TSA
and financial data from FEMA that allowed us to examine whether
statutory deadlines in the DHS appropriations acts were being met, as
well as the time that elapsed between award notification and grant
disbursement. To verify the reliability of the project approval dates
and funding amounts provided by TSA, we compared them to the total
funding provided to each region and found that these amounts matched.
For the purposes of our report, we concluded that TSA data on project
approval dates and funding amounts were sufficiently reliable.[Footnote
6] We also analyzed any policies and procedures in place for managing
the program with criteria on leading practices for collaborating
agencies and our Standards for Internal Control in the Federal
Government.[Footnote 7] Additionally, we conducted site visits at, or
held teleconferences with, a total of 30 mass transit operators in the
United States that represent 75 percent of the nation's total mass
transit and passenger rail ridership to solicit their perspectives on
the management of the grant process. During these site visits, we
interviewed transit agency grant management personnel as well as state
administrative agency personnel from nine states who were responsible
for administering the TSGP grants at the state level.[Footnote 8] We
used specific criteria to select these mass transit and passenger rail
agencies, including eligibility for grant funding, high levels of
ridership, and a diversity of risk levels as determined by TSA. While
the information we obtained from these 30 transit agencies cannot be
generalized to all transit agencies, it enhanced our understanding of
the types of projects initiated using TGSP funds and the period of time
that elapsed between the grant award and the receipt of such funds by
transit agencies.
To determine the extent to which DHS has evaluated the effectiveness of
the TSGP as well as investments made using funds awarded through the
TSGP, we analyzed DHS's strategic plan for transportation security and
available performance data and measures related to the grant program.
To determine what performance measurement data DHS had collected that
TSA or FEMA could use to understand the progress of the TSGP, we
interviewed grant officials from TSA's Transportation Sector Network
Management Office and FEMA's Grants Program Directorate. To verify the
reliability of the FEMA data on the amount of TSGP funding distributed
and held, we compared the data to state administrative agency and
transit agency records. Any discrepancies in the data were resolved
through discussions with FEMA officials. For the purposes of our
report, we concluded that FEMA data on distribution and held funding
amounts were sufficiently reliable. We also compared TSA's and FEMA's
efforts to evaluate their programs with guidance on performance
measurement contained in previous GAO reports.[Footnote 9]
We conducted this performance audit from September 2007 to June 2009 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.
Background:
Overview and Vulnerabilities of U.S. Mass Transit Systems:
Mass transit includes four main components--heavy rail, commuter rail,
light rail, and bus.[Footnote 10] Heavy rail systems--subway systems
like New York City's transit system and Washington, D.C.'s metro--
typically operate on fixed rail lines within a metropolitan area and
have the capacity for a heavy volume of traffic. Commuter rail systems
typically operate on railroad tracks and provide regional service
(e.g., between a central city and adjacent suburbs). Light rail systems
are typically characterized by lightweight passenger rail cars that
operate on track that is not separated from vehicular traffic for much
of the way. Large bus transit service is characterized by vehicles
powered by diesel, gasoline, battery, or alternative fuel engines
contained within the vehicle. According to the American Public
Transportation Association (APTA), 10.7 billion trips were taken on
mass transportation in 2008 --the highest number of trips taken on U.S.
mass transportation in 52 years. According to TSA, transit officials,
and transit experts, certain characteristics of mass transit systems,
such as multiple access points and limited barriers to access, make
them inherently vulnerable to terrorist attack and therefore difficult
to secure. High ridership, expensive infrastructure, economic
importance, and location in large metropolitan areas or tourist
destinations also make them attractive targets for terrorists because
of the potential for mass casualties and economic damage.
Grant Funding for Mass Transit Security:
Because of the expense of operating and securing a transit system, the
costs are often shared among several entities. According to the
Department of Transportation's (DOT) Federal Transit Administration
(FTA), almost all U.S. mass transit systems receive funds from public
and private sector sources to maintain a public service that is
provided and managed locally, since revenues from customer fares, on
average, account for 40 percent of system operating costs. For example,
FTA provides financial assistance to public transportation through its
Large Urban Cities Grant Program which provides funding to urban areas
through a formula-based allocation.[Footnote 11] Owners and operators
of public transit systems are also responsible for ensuring the
security of their systems. According to a 2004 APTA survey, transit
agencies had more than $6 billion in transit security investment needs.
[Footnote 12]
To help defray the costs of securing U.S. transit systems, DHS has
provided transit security grant funding to transit agencies since 2003.
Beginning in fiscal year 2005, the DHS appropriations acts have
provided annual appropriations for mass transit security, including the
TSGP, which focused specifically on mass transit security.[Footnote 13]
Table 1 outlines the TSGP allocations for fiscal year 2006 through
fiscal year 2009.[Footnote 14]
Table 1: TSGP Allocation for Fiscal Years 2006 through 2009:
Intracity-rail and bus:
FY 2006: $131.0 million[A];
FY 2007: $250.5 million[A];
FY 2008: $356.1 million[A];
FY 2009[B]: $348.0 million[A];
Total: $1,085.6 million[A].
Intercity rail (Amtrak)[C]:
FY 2006: $7.2 million[A];
FY 2007: $13.4 million[A];
FY 2008: $25.0 million[A];
FY 2009[B]: $25.0 million[A];
Total: $70.6 million[A].
Total:
FY 2006: $138.2 million[A];
FY 2007: $263.9 million[A];
FY 2008: $381.1 million[A];
FY 2009[B]: $373.0 million[A];
Total: $1,156.2 million[A].
Source: GAO analysis of TSGP Grant Guidance.
[A] These dollar amounts have not been adjusted for inflation.
[B] This is the target allocation for fiscal year 2009.
[C] AMTRAK is provided specific intercity rail funding each year, which
was not the focus of this review.
[End of table]
Both DHS appropriations acts and the Implementing Recommendations of
the 9/11 Commission Act (9/11 Commission Act) outline requirements for
security funding for mass transit and provide timelines for the
issuance of grant program guidance and decisions. In addition to
appropriating funding to the TSGP, DHS appropriations acts have
provided deadlines for the issuance of grant guidance, the application
period, and when DHS must act on applications. The 9/11 Commission Act
required the Secretary of Homeland Security to establish a program for
making grants to eligible public transportation agencies for security
improvements, and DHS fulfilled this requirement through the
TSGP.[Footnote 15] Although the TSGP considered risk prior to the
passage of the 9/11 Commission Act, the act created additional
requirements for the TSGP, including that recipients of public
transportation funds be selected based on risk and that projects
address items identified in security assessments or plans. It also
outlined permissible use of funds and placed a limitation on the
percentage of funds used for operational costs.
Responsibility for administering mass transit security funding has
changed numerous times within DHS since 2003. DHS's Office of Domestic
Preparedness administered the Urban Area Security Initiative (UASI)
grant program from fiscal year 2003 to fiscal year 2005. During fiscal
year 2006, the administration of the TSGP was transferred to TSA and
the Office of Grants and Training within DHS's Preparedness
Directorate. TSA became the lead federal agency for determining the
security priorities eligible for funding and developing the criteria
for evaluating applications, while DHS's Office of Grants and Training
became responsible for grant management.[Footnote 16] The Post-Katrina
Emergency Management Reform Act of 2007 transferred most offices within
the Preparedness Directorate into FEMA; however, policy
responsibilities, such as setting grant priorities and funding
decisions, remained with TSA.[Footnote 17] As a result, during fiscal
year 2007, the Office of Grants and Training was transferred to FEMA.
In fiscal year 2008, FEMA's Grant Programs Directorate became
responsible for administering TSGP grants.
Risk Management Practices Associated with the TSGP:
Risk management has been endorsed by Congress, the President, the
Secretary of Homeland Security, GAO, and others as a way to direct
finite resources to areas that are most at risk of terrorist attack.
Risk management is a continuous process that includes the assessment of
threats, vulnerabilities, and consequences to determine what actions
should be taken to reduce or eliminate one or more of these elements of
risk. DHS released the NIPP, which created, in accordance with Homeland
Security Presidential Directive 7 (HSPD-7), a risk-based
framework.[Footnote 18] The NIPP, issued in 2006 and updated in 2009,
sets forth guidance for agencies with critical infrastructure
protection responsibilities, such as TSA, for the prioritization of
protection initiatives and investments across sectors to ensure that
government and private sector resources are applied where they offer
the most benefit for mitigating risk.
TSA created six transit security fundamentals that it states are the
foundations for a successful security program, and the agency uses
these fundamentals to prioritize TSGP projects.[Footnote 19] For the
fiscal year 2008 and 2009 grant cycles, TSA established a systematic
process to rank these priorities in awarding grant funds. To do this,
TSA established project effectiveness groupings--groups of project
types that TSA ranked in order of priority based on their ability to
reduce risk--into which transit agency projects were placed. For
example, in fiscal year 2008, there were four possible groupings
(project types) for agency projects. The highest priority for that year
focused on projects aimed at developing security plans and providing
employee security training. See appendix II for the project
effectiveness groupings for fiscal year 2008.
DHS uses a risk model to help determine the transit agencies eligible
for TSGP funds. Both TSA and FEMA share responsibility for the TSGP
risk model, with TSA providing most of the data inputs to the model
that is managed by FEMA. The TSGP's risk methodology is similar to the
methodology used to determine eligibility for other DHS state and local
grant programs. For example, the methodology for determining basic
eligibility for the TSGP is derived from the UASI grant program--both
models identify and use the same urban areas and both the UASI and the
TSGP risk models calculate risk scores for each urban area. See
appendix III for additional details on the TSGP model.
The Process for Awarding TSGP Funds:
There are three stages of the TSGP grant cycle; allocation, award, and
distribution, as discussed in figure 1. TSGP grant guidance is created
annually by TSA and FEMA and provides an overview of the TSGP, the
application materials needed to apply for funding under the program,
and DHS management requirements.
Figure 1: Overview of the Grant Process for TSGP Funds for Fiscal Years
2007 through 2008:
[Refer to PDF for image: illustration]
Department of Homeland Security:
Based on risk model, DHS allocates funding to tiers and regions.
Tier I: Higher Risk:
Stage I: Allocation.
Stage II: Award;
* Agencies have 45 days to apply. DHS has 60 days to act on
applications received;
* TSA and Tier I agencies agree on basic outline of projects to fund.
DHS announces final allocations, but projects are not finalized;
* After award announcement, Tier I agencies have 90 days to detail how
they will implement the project.
Stage III: Distribution:
When transit agencies fulfill all grant requirements and FEMA completes
review, funds are released.
Tier II: Lower Risk:
Stage I: Allocation.
Stage II: Award;
* Tier II agencies compete for funds. Agencies‘ projects are reviewed
by NRP and Executive Committee and ranked based on risk and other
factors;
* Tier II agencies receive final funding decisions on their projects
when the award is announced.
Stage III: Distribution:
When transit agencies fulfill all grant requirements and FEMA completes
review, funds are released.
Sources: GAO analysis of DHS, TSA, and FEMA data and Art Explosion
clipart.
Notes: The fiscal year 2006 award process was competitive for all
eligible transit agencies, and award decisions were made by a national
review panel (NRP). For fiscal year 2007 and 2008, DHS introduced a new
negotiation process for higher-risk (Tier I) agencies and used the
above award process. The process for lower-risk (Tier II) agencies
remained competitive.
For fiscal year 2007, DHS had 75 days to release the grant guidance
once the appropriations act had passed, and for fiscal year 2008, DHS
had 30 days to release the grant guidance once the appropriations act
had passed.
Beginning in fiscal year 2009, Tier I transit agencies submit specific
project information for award decisions prior to DHS award
announcements.
[End of figure]
Allocation:
Using the TSGP risk analysis model, DHS develops risk scores, which are
used to identify the highest-risk regions and the transit agencies
within those regions that are eligible for funding.[Footnote 20] These
regions are then placed into one of two tiers based on their risk
scores to determine initial funding allocations; however, these
allocations may change when DHS begins reviewing projects.
* Tier I: DHS determines the regions at the highest risk of a terrorist
attack and selects transit agencies within those regions eligible to
receive Tier I funding. Each Tier I region is given a target allocation
based on its share of risk (as determined by the model). Each region,
through discussions among transit agencies and TSA officials in the
regional transit security working groups (RTSWG), decides which
projects to fund on a collaborative basis. Each Tier I region has a
RTSWG that includes eligible transit agencies, law enforcement
agencies, and Amtrak (if stations exist in the region).
* Tier II: Lower-risk regions and certain transit agencies in those
regions make up the Tier II group.[Footnote 21] The Tier II allocation
is a set amount of funding allocated for all Tier II regions combined.
Transit agencies in this tier apply for funding on a competitive basis-
-whereby their projects are evaluated against all other Tier II agency
projects proposals, instead of funding decisions being determined
collaboratively, as with the Tier I RTSWGs.[Footnote 22]
* After DHS announces target allocation amounts through the release of
the grant guidance, Tier I and Tier II transit agencies have 45 days
from the release of the guidance to apply for funding.
Award:
During the award process, DHS evaluates transit agencies' projects and
determines which projects to fund, although the evaluation process for
Tier I and Tier II agencies is different. Once the application period
closes for Tier I and II, the DHS appropriations act states that DHS
has 60 days to act upon the application, which DHS has defined as the
length of time taken to review the applications, make the award
decisions, and announce final allocations.[Footnote 23] In fiscal year
2008, as shown in figure 2, DHS created a three-part scoring
methodology for evaluating projects that included an agency's risk
score, its project effectiveness grouping, and a project quality score,
that included a regional collaboration factor.[Footnote 24]
Figure 2: DHS's Scoring Methodology for Fiscal Year 2008:
[Refer to PDF for image: illustration]
Project score equals:
Risk score: Each transit agency receives a risk score;
times:
Project effectiveness group: Project examples: Training; Public
awareness; Intrusion detection; Enhancing tunnel security;
plus:
Quality:
* Cost-effectiveness;
* Feasibility;
* Timelines;
* Sustainability;
* Regional collaboration.
Source: GAO analysis of TSGP grant guidance.
[End of figure]
In fiscal year 2009, DHS used a similar scoring methodology, although
this methodology was applied differently to Tier I and Tier II
agencies, as described below.
Tier I: In fiscal year 2006, each region's eligible transit agencies
competed for the target allocation. Under this process, transit
agencies' applications were reviewed by an NRP consisting of subject
matter experts from DHS, TSA, and FTA. An executive committee,
consisting of senior officials from TSA, reviewed the NRP
recommendations, the Secretary of Homeland Security made the final
selections for funding, and awards were announced.
In fiscal year 2007, DHS introduced a new process to award grants to
Tier I agencies that involved direct negotiations between TSA and each
RTSWG to identify the grant-funded projects that TSA would approve.
Under this approach--known as the cooperative agreement process--award
announcements were made, and transit agencies had 90 days to submit to
DHS their investment justifications which provided additional details
on how the transit agency would implement the awarded security
projects. TSA collaborated with the transit agencies to finalize the
investment justifications. Once these steps were completed, TSA
officially approved the projects.
In fiscal year 2008, TSA applied a more systematic approach for
determining project funding. For Tier I regions, project scores were
determined by weighing various factors, including the project
effectiveness grouping, the transit agencies' risk scores, and a
regional collaboration factor. According to TSA officials, project
quality was not as important a factor for Tier I agencies because TSA
participated in the project development process through the RTSWG,
which they believed helped ensure quality. DHS made award announcements
to Tier I agencies based on the project concepts discussed in the
RTSWG; however, as in the fiscal year 2007 process, final project
approval was not completed at that time. DHS officials plan to use the
same procedures in fiscal year 2009, except that they expect investment
justifications to be completed prior to the award announcements and
final project approvals are to be completed at the time of award.
Tier II: DHS has used a competitive approach for awarding funds to Tier
II agencies. From fiscal year 2006 to fiscal year 2008, projects
submitted were reviewed and ranked by an NRP. After reviewing the
transit agency risk scores and submitted projects, the panel developed
a recommended slate of projects, including proposed funding amounts. An
executive committee consisting of senior officials from TSA, DHS, and
FTA then reviewed the recommendations as well as the risk scores of the
transit agencies. The Secretary of Homeland Security made the final
selections for funding, and then funding was announced. The evaluation
criteria used by the panel have evolved from fiscal years 2006 through
2008, as shown in appendix V. Unlike Tier I agencies, Tier II agencies
received their final project funding amount for each fiscal year at the
time of award announcement. DHS plans to continue with this approach
for Tier II agencies for fiscal year 2009.
Distribution:
TSGP funds cannot be disbursed to transit agencies until FEMA ensures
the agency's compliance with federal grant management requirements,
such as the National Environmental Policy Act. Since fiscal year 2008,
TSA has approved transit agency projects (for both Tier I and II
projects) and then forwarded them to FEMA's Grant Programs Directorate
(GPD) for review.[Footnote 25] GPD is responsible for ensuring that all
grant projects adhere to federal grant requirements, including all
environmental and historical preservation (EHP) requirements.[Footnote
26] FEMA's Office of Environmental and Historical Preservation (OEHP)
assists with the EHP reviews. GPD reviews projects identified as having
limited EHP impacts, while OEHP reviews projects needing a more
extensive environmental and historical review.[Footnote 27] Until FEMA
is satisfied that all requirements have been met, no grant funding can
be released to transit agencies to begin projects. However, once funds
are awarded, transit agencies must complete the grant project within
the designated performance period for the grant year. The TSGP's
performance periods have ranged from 24 to 36 months depending on the
grant year and project type to be completed. FEMA has discretion to
extend the performance period, if necessary.
For Tier I regions with multiple states, one state administrative
agency is designated for the entire region. The DHS Appropriations Act
for fiscal year 2009 required funding to be provided directly to the
transit agencies, removing the state administrative agency from the
grant process. As a result, going forward transit agencies will be
responsible for all state administrative agency duties, including
submitting grant applications.
DHS Uses Elements of Risk to Allocate and Award Funds to Transit
Agencies, but the Risk Model Can Be Strengthened and Transit
Stakeholders Expressed Concerns about Funding Flexibility:
DHS has established an approach for allocating and awarding TSGP funds
using a risk model that incorporates the elements of risk and is
intended to allocate funding to the highest-risk regions and transit
agencies; however, the model could be strengthened to measure
variations in vulnerability across regions. Furthermore, TSA revised
its process and focus for the TSGP on numerous occasions since 2006,
but transit stakeholders expressed concern about these revisions and
their impact on funding flexibility.
DHS's TSGP Risk Model Incorporates Elements of Risk, but Could Be
Strengthened to Measure Variations in Vulnerability:
DHS uses a model to assess the risk to each transit agency region that
includes the three elements of risk--threat, vulnerability, and
consequence; however, the model does not measure variations in
vulnerability, which limits the model's overall ability to assess risk.
As we reported in June 2008, measuring vulnerability is considered a
generally accepted practice in assessing terrorism risk. However, DHS
did not specifically measure vulnerability for each region and the
associated transit agencies in the model.[Footnote 28] DHS reported
that it did not measure region and transit agency vulnerability because
it lacked data on the differences in vulnerability among transit
agencies. Therefore, DHS decided to hold this variable constant in the
risk formula. However, holding vulnerability constant may be
problematic because, for example, a region may be highly vulnerable to
one mode of attack but have a low level of vulnerability to another
depending on a variety of factors, such as countermeasures already in
place.[Footnote 29]
TSA officials acknowledged the need to incorporate vulnerability into
the risk model as a method for refining the results, but cautioned that
measuring variations in vulnerability would require time and resources.
As a result, officials reported that they were considering using
transit agency vulnerability assessment results as a source of
vulnerability information. To do this, FEMA officials acknowledged that
they must be able to consistently compare assessments across agencies
and regions, which may prove difficult given the variations in scope
and methodology of these assessments. A FEMA official stated that the
risk model is designed to incorporate other data, including
vulnerability information, when it becomes available. A TSA official
noted that TSA is considering looking into past vulnerability
assessments and its Baseline Assessment for Security Enhancements
(BASE) reviews for vulnerability information that might be used in the
model.[Footnote 30] TSA officials also remarked that they consider
ridership to be the major known vulnerability factor. A TSA official
remarked that ridership represents the number of people exposed by an
attack, which is a proxy for the openness of the system, station, or
both. However, the risk model also uses ridership to measure
consequence, so its link to vulnerability does not add additional
information about how risk may vary across regions. Without accounting
for variations in vulnerability, the effectiveness of the risk analysis
model may be limited in that it may not fully consider important
differences in regions and transit systems that could affect their
vulnerability to attack and the risk scores may not be as precise. A
more precise risk analysis could affect the allocations of funds to
Tier I or Tier II regions because allocation is determined in part by
the risk share.
The TSGP Risk Model Allocates Funding between Tier I and II and among
Tier I Regions Based on Risk:
Using its TSGP risk model, DHS placed transit agencies into one of two
tiers based on the risk of a terrorist attack occurring within a
region, and then allocated funding to those tiers based on risk. In the
fiscal year 2007 model, Tier I represented approximately 80 percent of
the total risk of all regions assessed by the model, and Tier II
represented the other 20 percent.[Footnote 31] In the fiscal year 2008
model, Tier I represented approximately 93 percent of the total risk to
all regions assessed by the model, and Tier II represented the other 7
percent. Our analysis of the risk model and the funding allocated
through the TSGP for fiscal years 2007 and 2008 showed that almost 90
percent of grant funds were allocated to the highest-risk transit
agencies--that is, those agencies in Tier I.[Footnote 32] Furthermore,
during fiscal years 2007 and 2008, the funding allocated to Tier I
regions was based on a region's risk share, which was determined by its
share of the total risk for all Tier I regions in the model. Our
analysis of the three grant cycles between fiscal year 2007 and 2008
showed that almost 90 percent of grant funds were allocated to the
highest risk transit agencies--that is, those agencies in Tier I. Tier
II received approximately 10 percent of the grant funds.
After DHS allocated funds to Tier I regions, transit agencies worked
within their respective RTSWGs in negotiating with TSA to identify
which projects would be funded with the target allocation--known as the
cooperative agreement process. TSA officials believe that the
cooperative agreement process ensured project quality because under
this approach TSA was able to work closely with transit agencies to
develop security projects. Additionally, in an effort to ensure that
grant money is spent on worthwhile projects, the grant guidance permits
TSA to transfer funding among regions if fewer quality applications are
submitted from one region and higher-priority security projects exist
elsewhere. As a result, during fiscal year 2008, TSA transferred funds
between Tier I regions and from Tier II to Tier I regions. Although TSA
worked with each Tier I region during the fiscal year 2008 grant cycle,
TSA officials reported that some regions did not submit enough projects
that exceeded the minimum project score required to receive funding. As
a result, one Tier I region saw a reduction in its target allocation.
According to TSA officials, these reductions occurred because they did
not want to fund poor quality projects just because funds were
available in a particular region. As a result, in fiscal year 2008,
Tier I gained an additional $13.7 million from Tier II, and $7.5
million from the Freight Rail Security Grant Program, for a total of
$21.2 million. Five of the eight Tier I regions received awards above
their target allocations such as the New York City region, which
received $21 million more than its target allocation. The San Francisco
Bay Area, which was the only Tier I region to see a reduction, received
$2.8 million less than its target allocation.
Although Allocation to Tiers Was Risk Based, Funding of Tier II Transit
Agency Awards Was Tied to DHS's Assessments of Project Quality:
Although DHS allocated funding to tiers based on risk, the specific
Tier II transit agency awards were not closely linked to risk. Unlike
its cooperative agreement process used to award funds for Tier I
agencies, DHS uses a competitive awards process for Tier II agencies
and does not negotiate the approval of security projects with the Tier
II agencies as it does with the Tier I agencies. Before fiscal year
2008, the executive committee considered agency risk after the NRP had
scored the agency projects based on their investment justifications;
however, the risk score was not part of a standard methodology or
formula for determining funding. This process changed in fiscal year
2008 when TSA began using Tier II agency risk scores as one part of its
three-part scoring methodology to determine project competitiveness.
[Footnote 33] Because applicants compete for Tier II funds on a project-
by-project basis, Tier II grant awards were not solely based on transit
agency risk. Rather, other factors also determined grant funding.
Specifically, our review of the NRP scores showed that project quality
was a major factor in determining if an agency received grant
funding.[Footnote 34] For example, a lower-risk agency with a high-
quality project was more likely to receive funding than a higher risk
agency with a low-quality project, based on the NRP's assessment.
TSA reported that Tier II agencies submitted projects with proposed
investments totaling $37 million during fiscal year 2008, although DHS
initially awarded $16.9 million of the total $36 million allocated to
Tier II agencies. TSA officials reported that this occurred because
many projects were ineligible because of such things as insufficient
information, lack of live monitoring for closed-circuit television
projects, or a focus on law enforcement instead of security. Because
there were not enough high-quality projects submitted to fulfill the
$36 million allocation for Tier II, according to TSA, the Secretary of
Homeland Security made the decision to recompete--that is, allow
agencies to resubmit projects for funding--for an additional $6
million. To accomplish this, TSA provided written feedback to Tier II
agencies that received partial funding or no funding from the initial
fiscal year 2008 grant cycle and invited them to reapply for the $6
million.[Footnote 35] The initial and recompeted TSGP funding for
fiscal year 2008 resulted in DHS awarding about $23 million to all Tier
II agencies. DHS officials stated that the decision to recompete $6
million ensured that the fiscal year 2008 funding for Tier II agencies
was equal to the amount of funding Tier II agencies received in fiscal
year 2007. TSA officials stated that all eligible projects recommended
by the NRP were funded with the initial $16.9 million. However, TSA
officials commented that during the recompete, there were more eligible
requests than funding available because of their efforts to provide
feedback on unsuccessful applications. Transit agencies submitted $9.1
million worth of eligible projects for the $6 million in funds, thus
projects were funded based on total project scores until the funds were
exhausted. TSA officials noted that several initially deficient
applications were modified based on feedback, resubmitted, and then
approved.
TSA Has Revised Its Grant Project Focus and Scoring Methodology since
2006, Raising Transit Stakeholder Concerns about Flexibility:
Transit Agency Stakeholders Expressed Concerns about Shifts in Grant
Project Focus since 2006:
The types of projects eligible for funding and the specific projects
TSA has focused on have changed each grant year since 2006--making long-
term planning difficult, according to officials we interviewed from 8
of 30 transit agencies and numerous stakeholders at TSGP after-action
conferences held in September and October 2008.[Footnote 36] These
changes, such as the projects that would receive priority for funding,
concerned transit agencies because they meant that the agencies had to
change their proposals in some cases. For example, results from 28 TSA
BASE reviews completed from December 2006 through January 2007
indicated that security training was an area needing improvement at
many transit agencies and was a critical vulnerability that needed to
be addressed immediately. As a result, after DHS released the fiscal
year 2007 grant guidance in January 2007, TSA officials notified all
transit stakeholders in February 2007 that the top funding priority for
fiscal year 2007 would be changed to training for key frontline
employees.[Footnote 37] TSA informed the transit agencies that this
training would be given elevated priority when the investment
justifications were evaluated for funding merit, and projects that
included training would be funded ahead of other projects. While this
change may have been necessary to adjust to a changing security
environment, the change resulted in transit agencies having less than 2
weeks to decide whether they wanted to change their grant applications
and refocus them on this priority area. See appendix VI for a listing
of grant priorities for fiscal years 2006 through 2009.
Grant Project Scoring Methodology Has Changed, and Stakeholders Have
Expressed Concerns Regarding Flexibility:
Another change in the grant program that transit stakeholders expressed
concern about occurred in the fiscal year 2008 grant cycle when DHS
changed its methodological approach for evaluating applications. Before
fiscal year 2008, the NRP evaluated Tier II grant projects for project
quality--including how those projects addressed the grant priorities.
In contrast, Tier I grant projects were determined by negotiations
between TSA and the RTSWG. However, in 2008 DHS introduced a new
scoring methodology for Tiers I and II, which was explicitly outlined
in DHS's grant guidance that year. According to TSA officials, the
change in scoring methodology was based on stakeholder feedback that
DHS be more transparent and clear about funding priorities and exactly
how projects would be prioritized and ranked.
However, 28 of 40 transit stakeholders we interviewed (30 transit
agencies and 10 state administrative agencies) and numerous
stakeholders at TSGP after action conferences held in September and
October 2008 noted that the TSGP provides limited flexibility to pursue
projects that have been identified as transit agency security needs.
Officials from one state administrative agency said that prioritizing
security projects puts forward-thinking agencies at a disadvantage
because if they have already completed projects that address TSA's
highest funding priorities, then obtaining funding for alternative
projects is difficult. Transit officials from one agency said the grant
priorities provide incentives for agencies to potentially buy things
they do not want or need, and that these technologies will eventually
just sit on the shelf. TSA officials stated that the TSGP is a limited
fund that must be allocated to best maximize the use of scarce
resources based on risk. TSA officials also reported that they receive
requests in excess of available funding, and therefore cannot fund all
eligible requests, necessitating a prioritization and ranking schema
and clear guidance on allowable project types.
Officials from five large Tier I transit agencies that have chemical
biological detection systems, or would like to install such systems,
expressed concerns that they could no longer receive funding to install
these detection systems.[Footnote 38] The TSGP listed chemical and
biological detection as an allowable expense for the grant program from
fiscal years 2005 through 2007; however, TSA did not fund chemical and
biological projects during fiscal years 2007 and 2008 and listed them
as an unallowable expense for the first time in the fiscal year 2008
guidance. TSA made this determination because its threat reports and
security assessments determined that improvised explosive devices (IED)
and improvised incendiary devices (IID) are the most common means of
attacking mass transit, and the training of frontline employees needed
to be addressed immediately. However, in fiscal year 2009 chemical and
biological detection systems became eligible, and TSA officials stated
that they may fund chemical and biological detection systems for fiscal
year 2009 because some agencies have demonstrated that they can use
this technology effectively and restoring this eligibility may allow
agencies to enhance their response and recovery capabilities.
Similar concerns over flexibility were outlined in recommendations from
the Mass Transit Security Sector Coordinating Council to the Government
Coordinating Council led by TSA in December 2007.[Footnote 39] The
transit industry members of the council were concerned about the
imbalance among the priorities listed in the fiscal year 2007 grant
guidance and noted that transit agencies are in the best position to
determine the balance of funding between capital and operating
initiatives. They specifically noted that more predictability and
flexibility in implementing priorities cited in the grant guidance is
needed to allow agencies to engage in long-term planning of security
initiatives, allowing agencies to more easily fund projects on a
multiyear basis. According to TSA officials, the collaborative efforts
between TSA and eligible transit agencies in the Tier I regions,
combined with the project effectiveness groupings that cite eligible
security enhancement measures in a prioritized listing, are intended to
enhance predictability and flexibility. In an effort to improve the
TSGP, TSA and FEMA held a conference in September 2008 to obtain
feedback from transit agencies and state administrative agency
officials on the fiscal year 2008 grant cycle. At that conference,
transit agency stakeholders continued to express concerns about the
need for greater flexibility and that funding decisions should be
informed by the regional strategies that they have put into place.
[Footnote 40]
For fiscal year 2009, DHS has reported changing the scoring methodology
to address transit agency concerns over limited flexibility.
Specifically, DHS added a grouping for other mitigation activities that
allows some of the project types that were previously excluded.
Furthermore, DHS has not explicitly excluded any type of project and
has enabled transit agencies to explain to DHS the priority groupings
into which they believe their project should be placed. The decision
about project placement, however, continues to lie with DHS and
projects that fall outside of the established project effectiveness
groupings are given the lowest-priority score. While this change could
alleviate transit agencies' concerns about limited flexibility, it is
too soon to determine whether it will address agency concerns and allow
them to secure funding for their highest security needs.
TSA and FEMA Lack Documented Roles and Responsibilities for
Administering the TSGP, and Although Statutory Timeline Requirements
Were Met, Little Money Has Been Expended:
DHS has met the statutory timeline requirements in allocating and
awarding grants. However the two agencies that manage the TSGP--TSA and
FEMA--lack defined roles and responsibilities, and the approval of
grant projects and completion of administrative requirements for grants
awarded in fiscal years 2006 through 2008 took many months.
Additionally, delays also occurred after projects were passed to FEMA
for administrative and environmental reviews because of backlogs and
reported resource constraints. TSA and FEMA have attempted to address
these delays by approving projects earlier in the grant process,
issuing guidance, and adding resources. Because of these delays,
project funds were often not available to transit agencies for months,
and in some cases years, after being awarded, and as a result, only 3
percent of grant money has been spent as of February 2009.
TSA and FEMA Have Not Defined Roles and Responsibilities for Managing
the TSGP:
While TSA and FEMA share responsibility for managing the TSGP, the two
agencies have not defined and documented their roles and
responsibilities in a memorandum of understanding (MOU), or through
similar means. TSA's responsibilities fall primarily in the award
process and include, among other things, identifying grant priorities,
while FEMA's responsibilities include administering the grant
management process to ensure compliance with applicable laws, rules,
and regulations. The roles and responsibilities of the two agencies
related to the award and postaward processes are in the grant guidance.
For example, the guidance states that FEMA has the lead for designing
and operating the administrative mechanisms needed to manage the grant
program. However, there is no documentation articulating the working
arrangement between the two agencies. For example, it is not part of
FEMA's procedures to notify TSA when funding is released to the state
administrative agencies and transit agencies, despite TSA officials
reporting several requests for access to this information. As a result,
TSA officials reported that because they do not have this information,
it is difficult for them to respond when transit agencies contact them
with questions about their grants.
As we reported in October 2005, many agencies face a range of barriers
when they attempt to work collaboratively.[Footnote 41] To enhance and
maintain effective collaboration, we reported that agencies engage in
practices such as establishing joint strategic plans to achieve common
outcomes as well as instituting compatible policies, procedures, and
other means to operate across agency boundaries. Additionally, agencies
can strengthen their commitment to work collaboratively by articulating
their agreements in documents, such as MOUs, interagency guidance, or
interagency planning documents. Standards for Internal Control in the
Federal Government also requires agencies to delegate authority and
responsibility throughout their organizations.[Footnote 42]
Articulating roles and responsibilities for managing the TSGP could
strengthen TSA and FEMA's ability to ensure that activities, processes,
and resources are aligned to achieve a common outcome and ensure smooth
coordination during the grant process. TSA officials stated that a
formal MOU and guidance documents between TSA and FEMA would be
beneficial, while FEMA officials stated that they believed the two
agencies are working together effectively.
DHS Met Statutory Requirements to Release Grant Guidance and Act on
Grant Applications, Although Some Projects Were Approved Months after
the Award:
DHS met the requirements of the TSGP to release grant guidance and act
on grant applications as defined by DHS; however, additional agency
actions are to be completed before specific transit agency projects and
funding levels are approved and transit agencies can begin projects.
Since fiscal year 2007, DHS appropriations acts have established
timelines for DHS to release the TSGP guidance and act upon transit
agency applications. For fiscal years 2007 through 2009, DHS met the
requirements to release the grant guidance within 75 days for fiscal
year 2007 and 30 days for fiscal years 2008 and 2009.[Footnote 43] The
appropriations acts also set timelines for DHS to act upon the grant
applications within 60 days, but until 2009, this did not include
approving projects. DHS policy defined the requirement to act upon
grant applications as reviewing the applications, making the award
decisions, and announcing final allocations. DHS met the requirements
to act upon the grant applications within 60 days, as defined by DHS,
for fiscal years 2007 and 2008. While there are specific statutory
deadlines for releasing grant guidance and acting on grant
applications, there are no statutory deadlines once the projects are
approved and are passed to FEMA for review and funding release to
transit agencies.
However, even though allocation amounts were announced by DHS within
the statutory time frames during fiscal years 2006 through 2008, none
of the Tier I regions had their projects approved by TSA at the time of
award because TSA procedures allowed for approval after the award. For
example, during fiscal year 2007, TSA did not begin approving Tier I
projects until more than 5 months after the award date. One Tier I
region did not receive project approval for its fiscal year 2007 grant
projects until November 2008, or 15 months after the award date. As
such, although DHS met the statutory deadlines for acting upon grant
applications within the time frames established in legislation, project
approval was not yet completed. In contrast, all Tier II agencies
involved in the competitive process, which evaluates all projects at
once, had all of their projects approved by TSA when the awards were
announced.
Delays in approving grant projects after awards were announced have
been attributed to TSA and the transit agencies involved in the
cooperative agreement process taking months to agree upon projects.
According to TSGP grant guidance, the cooperative agreement process is
valuable because it provides greater flexibility and allows TSA to work
directly with transit agencies to quickly adapt to changes as
situations arise during the grant cycle. However, this cooperative
process has also resulted in significant time passing between the award
and final project approval dates. According to TSA data, during the
fiscal year 2006 grant cycle, the average project took 9.7 months to
receive approval. During the initial grant cycle in fiscal year 2007,
the average project approval took 7.1 months. During the supplemental
grant cycle in fiscal year 2007, the average project approval took 5.5
months.[Footnote 44] Furthermore, at the time of our review, there was
still one Tier I region whose project from a previous grant cycle had
not yet been approved. Specifically, as of January 2009, a Chicago
region project totaling $2.9 million had not been approved from the
fiscal year 2006 grant cycle even though the fiscal year 2006
performance period ended in March 2009. In contrast, Tier II agencies
involved in the competitive process have their projects approved at the
time of the award and thus do not experience these delays.
TSA officials stated that some of the delays were caused by a provision
in the DHS appropriations act for fiscal year 2009, which provided that
the program could not include a cost share requirement for grants made
available for fiscal years 2008 and 2009. According to TSA officials,
the removal of this cost share requirement caused a disruption because
some transit agencies had to modify their projects, their budgets, or
both, which resulted in final project approval and disbursement delays.
One state administrative agency official in a Tier I region said that
delays in funding approval make program performance period extensions a
necessity. Further, the official stated that because some projects are
complex and involve multiple partners, delays can have a ripple effect
and slow project completion. In addition, as grant program periods are
extended, it is possible for multiple grant years to occur
simultaneously, making them a greater challenge to manage effectively.
A TSA official reported that as of late March 2009, all Tier I projects
for fiscal year 2008 were approved.
A TSA official said that TSA has made progress in managing project
approval time frames by changing some of its procedures for fiscal year
2009, but also noted that some of the delays in previous years could be
attributed to transit agency procedures as well. For example, a TSA
official noted that some transit agencies are required to have projects
approved by their boards of directors or state legislatures--efforts
which contributed to the length of time between award and project
approval. For example, one state administrative agency official said
that transit agencies cannot begin projects until state legislatures
approve the projects. The official noted that this process can take
time, especially if the legislature is not in session. According to
TSA, during fiscal year 2009 funds are to be awarded directly to
individual transit agencies; therefore, when DHS announces the awards,
each transit agency's funding amount must be finalized at that time. On
April 8, 2009, in conjunction with the award announcement, DHS issued
final allocation amounts for transit agencies for fiscal year 2009. As
a result of this administrative change, TSA officials noted that they
expected the project approval letters to be sent to FEMA soon after the
award announcement.
Postaward Delays Can Also Be Attributed to FEMA's Backlog of
Environmental Reviews and Reported Resource Constraints:
Once TSA approves projects and award amounts are finalized, FEMA takes
responsibility for ensuring compliance with federal requirements;
however, backlogs in FEMA's review processes have resulted in delays in
distributing project funding. One requirement that has caused delays
involves ensuring compliance with the National Environmental Policy
Act, which requires the consideration of the environmental impacts of
proposed actions as well as reasonable alternatives to those actions.
FEMA's GPD works in conjunction with FEMA's OEHP to complete the
Environmental and Historical Preservation (EHP) reviews of each
project. GPD reviews projects that have no, or limited, EHP impacts,
and OEHP reviews those projects needing a more comprehensive
environmental and historical preservation review. Before April 2007,
DHS's Office of Grants and Training and TSA shared responsibility for
managing the TSGP. According to OEHP officials currently managing the
EHP review process, when FEMA assumed responsibility for administering
the TSGP in April 2007, they discovered that the EHP requirements had
not been fully integrated into the TSGP and that there was a lack of
institutional knowledge among DHS's staff about how to manage the EHP
process and TSGP requirements. This lack of experience, in combination
with the lengthy process of collecting the necessary EHP information
from grant applicants, led to a backlog of EHP reviews from fiscal
years 2005 through 2007.
According to FEMA officials, there is a need for additional personnel
to address the EHP backlog and other anticipated workload issues.
According to GPD officials, the backlog created by pending EHP reviews
led to a sizable workload for GPD's limited staff. In addition, GPD
officials estimated that when transit agencies begin applying directly
to FEMA for TSGP grants in fiscal year 2009, instead of going through
their state administrative agencies, this approach will generate a
fivefold increase in TSGP applications as individual transit agencies
apply rather than state administrative agencies. In February 2009, GPD
officials reported that several efforts are under way to manage their
workload. For example, GPD expects to hire six more program analysts--
in addition to the two already in place--to manage the expected
workload increase. FEMA officials also reported in February 2009 that
they expected to have these new staff hired and in place by March or
April 2009. Additionally, GPD reported that it augmented its staff with
contractor support in December 2007, to reduce the time for EHP reviews
and expedite the release of funds. In March 2009, GPD officials said
that they planned to expand the contract within 2 months to include
another person for EHP support. They also reported that they are in the
process of conducting a workforce study, to commence in late spring
2009, to determine staffing needs for the additional workload, and
expect to have this study completed by the end of fiscal year 2009.
EHP Backlog Remains Despite FEMA's Efforts to Address It:
In a separate effort to address the backlog of EHP reviews, in 2007
OEHP developed new guidance for conducting environmental reviews. The
new guidance is aimed at addressing the backlog and heavy workload
brought about by the integration of GPD grants into FEMA by focusing
GPD and OEHP staff resources on project reviews with the greatest
potential for environmental impact.[Footnote 45] FEMA officials
reported that the backlog prior to the release of the guidance resulted
in projects taking several weeks to several months for EHP approval,
depending on the complexity and level of review. Officials also
reported that the internal processing time has improved by 50 percent
since the EHP guidance was released, and the guidance has also helped
to identify the need for EHP training for external and internal
stakeholders. See appendix VII for FEMA's EHP review project types.
Additionally, DHS revised its grant guidance for fiscal year 2009 to
clarify to grant recipients the EHP information that they should submit
so that FEMA can begin reviewing their projects. The intention of this
revision was to reduce the amount of time between collecting the
information and beginning the EHP review process.
Despite these efforts, there remains a backlog of grant projects
awaiting review. According to FEMA officials, as of March 2009, 72
projects were still in review, accounting for $88 million. Twenty-four
were projects from fiscal year 2006, and 48 projects from fiscal year
2007.[Footnote 46] FEMA officials further noted that a large number of
these projects were in EHP review. As of March 2009, FEMA's EHP
regulations were disaster focused, and have not been revised since
1996--before DHS existed. FEMA officials reported in March 2009 that
the agency would revise its environmental regulations to be more
inclusive of all types of projects, including non disaster homeland
security grants, that FEMA funds. However, FEMA did not have a timeline
for when the new regulations would be published. Best practices for
project management call for milestone dates, among other factors, in
carrying out a project successfully.[Footnote 47] Establishing
milestones could help FEMA ensure that revisions to its environmental
regulations are conducted as management intended.
A Small Amount of Grant Funds Has Been Spent Because of the Length of
Time to Make Funds Available:
From fiscal years 2006 through 2008, DHS awarded about $755 million in
transit security grants; however, as of February 2009, only about $21
million, or 3 percent, of this total had been expended by transit
agencies largely because of TSA's lengthy cooperative agreement
process, the EHP backlog, and delays in receiving disbursement approval
from FEMA.[Footnote 48] As of February 2009, for fiscal years 2006
through 2008, approximately $334 million dollars has been distributed
to transit agencies and approximately $421 million is still being held
pending review (with the majority of the held funds from fiscal year
2008). As might be expected, more recent fiscal years showed higher
unexpended balances. However, low grant expenditures by transit
agencies was commonly reported across all TSGP grant years, as shown in
figure 3, and are related to many transit agencies receiving
authorization to spend their grant dollars near the end of each 2 to 3
year grant performance period.[Footnote 49] FEMA officials reported
that transit agencies may choose to draw down their award at any time
during the performance period.
Figure 3: TSGP Funds Expended and Unexpended, Fiscal Years 2006 though
2008:
[Refer to PDF for image: stacked vertical bar graph]
Grant year: 2006;
Expanded funds: $7,853,153;
Unexpanded funds: $128,144,937.
Grant year: 2007;
Expanded funds: $9,476,631;
Unexpanded funds: $253,394,039.
Grant year: 2008;
Expanded funds: $4,163,444;
Unexpanded funds: $351,945,127.
Grant year: Total;
Expanded funds: $21,493,231;
Unexpanded funds: $733,484,103.
Source: GAO analysis of FEMA data as of February 2009.
[End of figure]
Our analysis of TSA project approval and FEMA grant adjustment notices
(GAN) from fiscal year 2006 or release of funds memos for fiscal year
2007 showed that it could take up to 20 months for transit agencies to
receive approval to begin projects, which accounted for a significant
portion of the grant performance period. FEMA used GANs and release of
funds memos to notify the state administrative agency and the transit
agency that they may begin a project. In fiscal year 2006, state
administrative agencies may have received more than one GAN for each
project. The first GANs were to notify the state administrative
agencies to "obligate and expend" the funds, which meant that they
could begin the projects. However, this did not mean that they could
draw down any funding. Only upon receipt of the "obligate, expend, and
draw down" GAN could the funds be withdrawn. This two-part GAN process
created some confusion among transit stakeholders and, in fiscal year
2007, FEMA clarified the GAN process. In fiscal year 2008, FEMA changed
this procedure again to include the use of a single release of funds
memo, which allowed transit agencies to draw down funds.[Footnote 50]
See figure 4 for the average amount of time it took for transit
agencies to receive approval from TSA and FEMA to begin projects after
the grant award date.
Figure 4: Average Time for TSA and FEMA to Approve Projects for Fiscal
Year 2006 through 2007:
[Refer to PDF for image: multiple vertical bar graph]
Grant cycle: Fiscal year 2006;
Tier I: 20.3 months;
Tier II: 7.6 months.
Grant cycle: Fiscal year 2007 base;
Tier I: 9.2 months;
Tier II: 1.8 months.
Grant cycle: Fiscal year 2007 supplemental;
Tier I: 9.2 months;
Tier II: 0.
Source: GAO analysis of TSA and FEMA data as of February 2009 and Tier
II data as of December 2008.
Note: Tier II fiscal year 2007 supplemental funds that were released
were available the same day as the award. Fiscal year 2008 projects
have not yet been approved by FEMA for distribution.
[End of figure]
In addition to the delay between announcing awards and obtaining final
project approvals, 25 of 40 transit stakeholders we interviewed,
including state administrative agency officials, also reported time
delays in receiving their grant monies. Furthermore, numerous transit
stakeholders attending the TSGP after-action conferences raised
concerns about the time it took to receive awarded funds after projects
were approved, and stated that they believed the process was broken.
They also reported that they believed the performance period needed to
start when the GANs were received, not when awards were announced. For
example, during fiscal year 2006, one Tier I transit agency was awarded
$4 million for a new integrated security response center, but the
agency did not receive approval to begin the project until June 11,
2008. As a result, unless this transit agency receives an extension, it
will have less than 10 months to complete the project to stay within
the original 30-month performance period. A transit agency official
told us that the agency requested an extension until June 30, 2010, to
complete this project, and was awaiting FEMA's response. In addition,
in December 2008, a state administrative agency official for one state
sent a request to FEMA for a 2-year extension to the performance period
for the entire state's fiscal year 2006 TSGP grant because the "delays
from the federal level have left many of these projects without a
chance of success during the performance period."
Transit stakeholders also said that concerns about funding delays have
hampered their ability to effectively plan for and manage projects. For
example, one transit agency official said that because of delays in
receiving grant funding the agency is constantly seeking extensions,
which are often not approved for longer than 3 months. In addition,
another transit agency official stated that state procurement processes
can take additional time to complete, which can also reduce the amount
of available time to complete the project within the performance
period. FEMA officials noted that 2006 was an unusual year for the
grant program because the multiple GANs they issued to state
administrative agencies resulted in confusion among transit agencies
about when projects could begin or when they could start spending
money. As a result of the delays encountered in the fiscal year 2006
grant process, FEMA officials stated in March 2009 that they were
notifying transit agencies of one-year extensions for all fiscal year
2006 grants that were set to end on March 31, 2009. Despite the
concerns over funding delays, FEMA has not established or communicated
time frames for providing grant funding to transit agencies once
projects have been approved by TSA. In April 2004, we reported that
timely awarding of grant funds is imperative to provide the intended
benefit of the grant program.[Footnote 51] Additionally, the purpose of
the TSGP is to provide funding to owners and operators of transit
systems to protect critical surface transportation infrastructure and
the traveling public. Ensuring the timely distribution of grant funds
is essential for ensuring that transit system owners and operators
receive necessary funds early enough in the performance period to
complete their security projects.
Additional Steps Needed to Develop Performance Measures to Assess TSGP
Grant Project Effectiveness and to Fulfill Administrative
Responsibilities:
TSGP Lacks a Plan and Related Milestones for Developing Performance
Measures:
While the purpose of the TSGP is to provide funds to protect critical
surface transportation infrastructure and the traveling public, the
program lacks a plan and related milestones for developing measures to
track progress toward achieving program goals. While FEMA reported that
it was beginning to develop measures to better manage its portfolio of
grants, TSA and FEMA have not collaborated to produce performance
measures for assessing the effectiveness of TSGP-funded projects, such
as how funding is used to help protect critical transportation
infrastructure and the traveling public from possible acts of
terrorism. Further, FEMA does not yet have performance measures in
place for its administrative duties, such as measuring the time taken
to complete reviews of financial and administrative requirements. As we
reported in October 2005, to enhance and maintain effective
collaboration, agencies should engage in practices to achieve common
outcomes and establish compatible policies, procedures, and other means
to operate across agency boundaries.[Footnote 52] Additionally,
according to best practices for project management, the development of
a project management plan--which defines how the project is executed,
monitored and controlled, and closed--is a key element of project
management.[Footnote 53] Best practices for project management also
call for milestone dates, among other factors, in carrying out a
project successfully.
FEMA officials reported in October 2008 that while they were in the
process of establishing baselines and targets for measures identified
through the Program Assessment Rating Tool (PART) requirement,
additional work was needed to develop meaningful measures.[Footnote 54]
FEMA officials stated that performance measures for the TSGP are likely
to focus on the increased security capabilities of the transit
agencies, such as the number of canine teams a transit agency deploys.
In addition, FEMA has also been developing a cost-to-capability
assessment that officials report will allow them to analyze grant
program accomplishments from fiscal years 2003 through 2007. Still in
its early stages, the cost-to-capability assessment focuses on efforts
to measure a jurisdiction's capability to prevent and respond to
various types of disasters compared to a target level of capability.
[Footnote 55] Although TSA has lead responsibility for surface
transportation security, a TSA grant program official stated that TSA
does not have any role in FEMA's cost-to-capability assessment and only
learned about it in late 2008. This official also reported that the
assessment raised some concerns as it might not be tailored
appropriately to each transportation mode.
TSA officials reported that they are considering using the BASE review
and TSA inspectors to develop and monitor performance measures for the
TSGP; however, TSA officials reported not taking any action to develop
performance measures because of resource constraints for managing the
program. As we have reported, federal programs contributing to the same
or similar results should collaborate to ensure that goals are
consistent and, as appropriate, program efforts are mutually
reinforcing.[Footnote 56] Until TSA and FEMA collaborate to develop a
plan with related milestones, it will be difficult for the agencies to
provide reasonable assurance that measures are being developed to
ensure that the program is achieving its stated purpose of protecting
critical surface transportation infrastructure.
FEMA Lacks Mechanisms to Systematically Collect Data and Track Grant
Activities for Administrative Purposes:
FEMA is responsible for conducting both a budget review and
programmatic review of grant projects including reviews of EHP
requirements. However, despite this role, FEMA does not have a
mechanism for systematically collecting data on the status of
individual grant projects throughout this review process, including
tracking the status of the reviews it conducts and the release of funds
to transit agencies. Although FEMA has systems to track financial
information related to all of its grant programs, these systems do not
allow FEMA to track the status of grant reviews, such as EHP reviews.
As a result, GPD staff reported that they created a spreadsheet to
track this information, including identifying when TSGP funds were
released once requirements were met. Under this tracking process, each
program analyst was responsible for maintaining accurate records in the
spreadsheet. However, TSA did not have access to it and, until February
2009, the information was not monitored for accuracy. Further, we found
inconsistencies between FEMA's spreadsheets and data collected through
FEMA's financial systems, including the amount of funding being held
pending EHP and other reviews. For example, we found that the total
amount of funds on hold in the GPD internal spreadsheets was not equal
to the hold amounts in FEMA's financial systems. GPD officials told us
that FEMA's financial systems were the official record for the awards.
A FEMA official reported that there are multiple information systems
involved in managing the TSGP. FEMA is in the process of implementing a
new consolidated grants management system--expected to be operational
for the TSGP by October 2009. According to FEMA, the new system is to
include functions that support the application process and is expected
to be fully operational throughout DHS in 2011. Although the system
will not initially support the tracking of grant disbursements, FEMA
officials reported that their intention is to have the system support
these functions in future releases. However, FEMA officials did not
have a specific date for when these capabilities would be available.
[Footnote 57] In addition, as of March 2009, there was no mechanism for
TSA to gain access to grant review or financial information, even
though TSA officials reported requesting information regarding when
funds were released to transit agencies so that they could track this
information. Standards for Internal Control in the Federal Government
requires agencies to ensure that pertinent information is recorded and
communicated to management and others within the entity in a form and
within a time frame that enables them to carry out their internal
control and other responsibilities.[Footnote 58] Moreover,
systematically collecting data on the status of grant projects
throughout the grant process could strengthen FEMA and TSA's ability to
effectively manage the program.
Similarly, the GPD is responsible for the financial controls and audits
of the TSGP to ensure that funds are appropriately disbursed and used
in accordance with grant requirements. However, the agency does not
have a plan for targeting its monitoring activities related to the use
of grant funds once projects have been implemented. GPD officials said
that their office conducts on-site visits to transit agencies to
collect information on the use of grant funds, but because of a lack of
staff resources, their efforts have mostly been limited to the largest
Tier I transit agencies that either have not spent their grant funding
or were not able to complete projects within the designated grant
period. GPD officials said that they also conduct document reviews,
including reviewing quarterly financial reports, progress reports, and
special conditions to release funds. Although they reported having
limited resources, GPD officials said that they were able to conduct
approximately 24 site visits during fiscal years 2006 through 2008,
attend numerous RTSWG meetings, and interact with transit agencies at
conferences as part of their efforts to monitor the awards. GPD
officials also reported creating a monitoring tool for the fiscal year
2007 grant cycle to be used during on-site visits, and officials stated
that the agency plans to modify the tool each grant year based on the
specific grant requirements for that year. GPD officials also reported
that the tool has been used by GPD program analysts during their site
visits.
While GPD's monitoring tool will likely strengthen the agency's ability
to monitor grant activities, GPD lacks a plan to delineate how and when
this monitoring will take place. GPD officials acknowledged that a
robust monitoring plan needs to be implemented with processes in place
to ensure that the agency visits each transit agency at least once a
year. According to grants management best practices, monitoring grantee
performance helps ensure that grant goals are reached, and it is
important that agencies identify, prioritize and manage potential at-
risk recipients.[Footnote 59] For example, one federal agency with
grant-making responsibilities has created monitoring plans that include
criteria to perform risk assessments, which consider factors affecting
a grantees ability to effectively manage grants.[Footnote 60] This
information could be used to prioritize monitoring activities given
GPD's limited personnel. In addition, in September 2006 we reported on
the value of feedback provided through performance monitoring plans and
tools such as site visits.[Footnote 61] Moreover, TSA officials stated
that their agency currently has no role in the oversight of grant
expenditures, but believed that the use of its inspectors to provide
grant oversight would be a key component of the overall approach to
mass transit security. TSA's surface transportation security
inspectors, who are located throughout the United States, interact with
transit agencies for other purposes on a regular basis, and could be
used for on-site monitoring. In October 2005, we reported that
leveraging resources is vital to achieving effective collaboration.
[Footnote 62] A monitoring plan would provide GPD with a road map for
how it will carry out its monitoring activities to help ensure that it
is effectively using its limited resources. In addition, by working
collaboratively with TSA and its surface inspectors, who have security
expertise, GPD could leverage existing resources to ensure that transit
agencies are complying with security specifications set out in TSGP
grant guidance and the agencies' own investment justifications.
Conclusions:
As terrorist attacks on transit systems overseas have made clear, even
with a variety of security precautions in place, mass transit systems
that move high volumes of passengers daily remain vulnerable to attack.
Risk management has been endorsed by the federal government as a way to
direct finite resources to those areas at greatest risk of a terrorist
attack. While DHS uses a risk-based process to allocate funding for the
TSGP, without considering possible variations in vulnerability in the
risk model, the risk scores developed through the model are not as
precise as they could be, which could affect the allocation of funds to
Tier I and Tier II agencies. In addition, articulating roles and
responsibilities for managing the TSGP could strengthen TSA and FEMA's
ability to ensure that activities, processes, and resources are aligned
to achieve a common outcome and ensure smooth coordination during the
grant process. Further, TSA's delays in approving projects and FEMA's
backlog of project reviews are contributing to delays, which negatively
affect the ability of transit agencies to complete their projects
within grant performance periods. However, TSA has made changes to the
project approval process for fiscal year 2009, which resulted in all
projects being approved at the same time as the grant award
announcement. FEMA has also reported plans to modify its approach for
managing the administrative requirements of the TSGP, including
revising its environmental regulations to be more inclusive of all the
types of projects, including nondisaster homeland security grants.
While FEMA has not reported a time frame for completing this process,
establishing milestones to complete this modification could help FEMA
ensure that revisions to its environmental regulations are conducted in
a timely manner.
We have also previously reported on the importance of performance
monitoring in grant programs. Monitoring the implementation of TSGP
grant projects is vital to ensure that transit agencies are complying
with security specifications set out in the TSGP guidance and in the
agencies' own investment justifications. A monitoring plan that details
how and when monitoring will take place could improve GPD's ability to
plan for this important oversight function and help it ensure that it
is effectively using its limited resources. A monitoring plan, which
includes a method for leveraging TSA resources, would also put GPD in a
better position to monitor grant implementation by working
collaboratively with TSA to leverage the security expertise of TSA's
surface transportation security inspectors which will help FEMA address
its resource limitations related to monitoring. In addition, while
FEMA's consolidated grants management system should allow FEMA to
better manage data collection, the system being developed is not
expected to allow FEMA to collect data on the status of grant
activities throughout the grant process or to provide TSA with access
to this information, both of which are vital to ensuring effective
program management. Moreover, until the system is established and able
to track TSGP grants to allow for effective oversight and management of
TSGP funds, FEMA could benefit from establishing an interim process
that tracks the necessary information and share this information with
TSA, its TSGP partner. Finally, performance measures are fundamental to
the successful management of federal programs. As we have reported,
federal programs contributing to the same or similar results should
collaborate to ensure that goals are consistent and, as appropriate,
program efforts are mutually reinforcing. Until TSA and FEMA
collaborate to develop a plan with related milestones for jointly
measuring the effectiveness of TSGP, it will be difficult for the
agencies to provide reasonable assurance that measures are being
developed to ensure that the program is achieving its stated purpose of
protecting critical surface transportation infrastructure and that
accountability and effective stewardship of public resources exist.
Finally, the absence of information on the expected time frames for
making funds available to transit agencies once projects are approved
can hinder transit agency efforts to design and implement projects
within the designated performance periods of the grant.
Recommendations for Executive Action:
We are making seven recommendations to help strengthen the
implementation and oversight of the TSGP.
To strengthen DHS's methodology for determining risk, we are
recommending that the Secretary of Homeland Security develop a cost-
effective method for incorporating vulnerability information into
future iterations of the TSGP risk model.
To strengthen the administration, oversight, and internal controls of
the TSGP, we are recommending that the Secretary of Homeland Security
direct TSA and FEMA to take the following four actions:
* Define TSA's and FEMA's respective roles and responsibilities for
managing the TSGP in an MOU or similar document.
* Develop a cost-effective plan for monitoring the use of grant funds
once projects have been implemented, including a strategy for
leveraging resources that could allow TSA surface transportation
security inspectors to assist in monitoring the grant projects to
ensure that the projects meet the security requirements set out in TSGP
guidance.
* Develop an interim solution to systematically collect data and track
grant activities until FEMA's grants management system can perform
these functions, and ensure that both agencies have access to these
data.
* Collaborate to develop a plan and milestones for measuring the
effectiveness of the TSGP and its administration.
In addition, we recommend that the Secretary of Homeland Security
direct FEMA to take the following actions:
* Establish a time frame for revising environmental regulations to be
more inclusive of nondisaster homeland security grant programs.
* Establish and communicate time frames for making funds available to
transit agencies once FEMA receives project approvals from TSA.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS and DOT for review and
comment. DOT did not provide comments. DHS provided written comments on
May 15, 2009, which are reprinted in appendix VIII. In commenting on
the report, DHS reported that it concurred with all seven
recommendations and discussed actions it has taken or planned to take
to implement them.
With regard to our first recommendation that DHS strengthen its
methodology for determining risk by developing a cost-effective method
for incorporating vulnerability information into future iterations of
the TSGP risk model, DHS concurred with the recommendation and said
that it would make appropriate adjustments in the fiscal year 2010
grant cycle.
DHS concurred with our second recommendation that TSA and FEMA's
respective roles for the administration and oversight of the TSGP be
defined and documented in an MOU or similar document. DHS reported that
TSA and FEMA will work collaboratively to develop the MOU before the
fiscal year 2010 grant cycle and share it with external stakeholders to
ensure that the responsibilities and relationships between TSA and FEMA
are clear.
DHS also concurred with our third recommendation that it develop a cost-
effective plan for monitoring the use of grant funds and leverage TSA
surface transportation security inspectors to assist in monitoring
these projects. Specifically, DHS reported that FEMA would work toward
developing a cost-effective monitoring plan to include the use of
surface transportation security inspectors in such instances when their
transit security expertise would be appropriate for monitoring grant
program functions. Because FEMA would be utilizing TSA personnel with
numerous other responsibilities to help with this monitoring, it is
especially important that the two agencies work together to coordinate
this effort and conduct the monitoring as efficiently as possible. For
example, TSA's surface transportation security inspectors currently
monitor transit agencies through the BASE reviews and could monitor
grant implementation concurrently with those reviews.
DHS stated that it concurred with our fourth recommendation that TSA
and FEMA develop an interim solution to systematically collect data and
track grant activities until FEMA's grants management system can
perform these functions, and ensure that both agencies have access to
these data. DHS also stated that TSA and FEMA will identify appropriate
channels for data collection and tracking as well as information
sharing so that both agencies have access to all appropriate
information to ensure accurate and consistent record keeping. In
addition, DHS reported that it has taken action to modify FEMA tracking
logs and project spreadsheets to collect additional information to
track projects to improve its collection and tracking of grant
information. However, given that FEMA does not know when the grants
management system will be able to systematically collect data and track
grant activities, it is critical that FEMA develop and implement this
interim solution to collect and track key grant information as quickly
and accurately as possible.
With regard to our fifth recommendation that TSA and FEMA collaborate
to develop a plan and milestones for measuring the effectiveness of the
TSGP and its administration, DHS stated that it concurred with the
recommendation. DHS reported that a collaborative written plan with
established goals and milestones will be designed and implemented as
part of the MOU or other formal agreement between TSA and FEMA.
DHS concurred with our sixth recommendation that FEMA establish a time
frame for revising environmental regulations that consider nondisaster
homeland security grant programs. However, in its comments on this
recommendation, DHS stated that FEMA's environmental regulations apply
to nondisaster grants. We did not intend to suggest that the
regulations did not currently apply to nondisaster grants. Rather, we
are recommending that FEMA establish a time frame for completing its
plans to revise regulations that are currently focused on emergency
management program issues to be more inclusive of the types of issues
associated with nondisaster grant programs. In response to this
comment, and to clarify our point, we revised the recommendation to
reflect that the environmental regulations apply to all FEMA grant
programs, but that FEMA should establish time frames for revising the
regulations to be more inclusive of nondisaster grants. DHS also stated
that FEMA is currently working with DHS to update these procedures and
is targeting completion of this effort for the end of calendar year
2009. However, DHS noted that these efforts could be extended if delays
occur because of additional time needed to complete procedural changes.
With regard to our seventh recommendation that FEMA establish and
communicate time frames for making funds available to transit agencies
once FEMA receives project approvals from TSA, DHS concurred.
Specifically, DHS also reported that FEMA will make every reasonable
effort to establish and communicate time frames for releasing funds to
TSGP grantees once FEMA receives approval of grant projects from TSA.
However, DHS noted that the release of funds often depends on the
responsiveness of grantees in submitting required documents and thus
FEMA would work proactively to obtain required information. DHS also
reported that FEMA would release grant funds within 3 to 5 days, if all
required EHP and budget information is received from grantees, and
appropriate clearances are provided by OEHP and the FEMA financial
analyst. However, our recommendation also intended that FEMA establish
timeframes for when its internal reviews would be completed once it
receives all of the required documents to facilitate a timely
distribution of TSGP awards. FEMA's OEHP already has time frames for
completing its EHP review process and a related performance metric to
assess its effectiveness in meeting these time frames. Establishing
such time frames for its other internal reviews and communicating those
to transit agencies could help improve transit agency efforts to
implement projects within the designated performance periods of the
grant.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretary of Homeland Security, the Secretary of Transportation, the
Director of the Office of Management and Budget, and interested
congressional committees. The report also is available at no charge on
the GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions concerning this report, please
contact me at (202) 512-8777 or lords@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 are
listed in appendix VIII.
Sincerely yours,
Signed by:
Stephen M. Lord:
Director, Homeland Security and Justice Issues:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report were to determine the extent to which (1)
Transit Security Grant Program (TSGP) funds are allocated and awarded
based on risk, and grant requirements have changed since 2006; (2) the
Department of Homeland Security (DHS) has allocated, awarded, and
distributed TSGP grants in accordance with statutory deadlines and
leading practices for collaborating agencies; and (3) DHS has evaluated
the effectiveness of the TSGP as well as investments made using funds
awarded through the TSGP.
To determine the extent to which TSGP funds are allocated and awarded
based on risk, we analyzed guidance documents outlining best practices
for effectively implementing a risk management framework, including the
DHS National Infrastructure Protection Plan (NIPP), the Transportation
Security Sector Specific Plan (TS-SSP), and GAO's risk management
framework. We obtained the Transportation Security Administration (TSA)
and the Federal Emergency Management Agency's (FEMA) risk analysis
model for the TSGP for fiscal years 2007 and 2008. We analyzed the
model for these fiscal years to determine the process by which DHS used
the model to estimate risk--by incorporating threat, vulnerability, and
consequence information--as well as how the model was used to divide
regions into Tier I (higher risk) and Tier II (lower risk), and make
allocations to tiers and regions and the extent to which these
allocations were tied to the region's or transit agency's share of
risk. We also interviewed officials from TSA and FEMA as well as FEMA's
contractor, Digital Sandbox, to understand what information was
included in the model and how the model was managed between the two
agencies. We did not evaluate the quality of the information or data
included in the model, but instead evaluated the model for how it
incorporated the required elements of risk. We determined the
reliability of the model by discussing methods of entering and
maintaining data with agency officials. On the basis of these
discussions, and our review of the processes used to collect the data,
we determined that the data were sufficiently reliable for the purposes
of this report.
To determine the extent to which grant requirements have changed since
fiscal year 2006, we analyzed TSA's grant guidance and grant priorities
for fiscal years 2006 through 2009, and attended TSA and FEMA
presentations to transit agencies prior to the release of the grant
guidance as well as after-action conferences for the fiscal year 2008
grant cycle. Additionally, we interviewed TSA and FEMA officials about
the TSGP grant determination process used in fiscal years 2006, 2007,
and 2008--including TSA's scoring methodology for Tier I and II and the
national review panel criteria used for Tier II--and about the changes
made to the process for fiscal year 2009. We also interviewed 30 mass
transit and passenger rail operators that have applied for, received
grant funding, or both to gain their perspectives on how the grant
requirements have changed since fiscal year 2006 and the impact that
these changes have had on the grant process. The agencies we
interviewed represent 75 percent of the nation's total mass transit and
passenger rail ridership based on information we obtained from the
Federal Transit Administration's National Transit Database and the
American Public Transportation Association. We selected this
nonprobability sample of transit agencies based on (1) varying levels
of ridership, (2) eligibility to receive TSGP grants, (3) varying
levels of risk (Tier I versus Tier II), (4) expert recommendation, and
(5) geographic dispersion. Because we selected a non-probability sample
of mass transit and passenger rail agencies, the information obtained
from these site visits cannot be generalized to all transit agencies
nationwide. Table 2 lists the mass transit and passenger rail agencies
we included in our interviews.
Table 2: Thirty Domestic Mass Transit and Passenger Rail Agencies
Interviewed:
Transit agency: Bay Area Rapid Transit (BART);
Urban area served: San Francisco-Oakland, California.
Transit agency: Broward County Office of Transportation (BCT);
Urban area served: Pompano Beach, Florida.
Transit agency: CALTRAIN;
Urban area served: San Francisco and San Jose, California.
Transit agency: Chicago Transit Authority (CTA);
Urban area served: Chicago, Illinois.
Transit agency: Dallas Area Rapid Transit/Trinity Railway Express
(DART);
Urban area served: Dallas, Texas.
Transit agency: Delaware River Port Authority (PATCO);
Urban area served: New Jersey, and Philadelphia, Pennsylvania.
Transit agency: Fort Worth Transportation Authority (The T);
Urban area served: Fort Worth, Texas.
Transit agency: King County Department of Transportation - Metro
Transit Division (King County Metro);
Urban area served: Seattle, Washington.
Transit agency: Los Angeles County Metropolitan Transportation
Authority (LACMTA); Urban area served: Los Angeles, California.
Transit agency: Maryland Transit Administration (MTA);
Urban area served: Greater Washington. D.C., and Maryland.
Transit agency: Massachusetts Bay Transportation Authority (MBTA);
Urban area served: Boston, Massachusetts.
Transit agency: METRA Commuter Rail;
Urban area served: Chicago, Illinois.
Transit agency: Metropolitan Atlanta Rapid Transit Authority (MARTA);
Urban area served: Atlanta, Georgia.
Transit agency: Metro Transit;
Urban area served: Minneapolis, Minnesota.
Transit agency: Metropolitan Transit Authority of Harris County
(Houston Metro);
Urban area served: Houston, Texas.
Transit agency: Miami Dade Transit;
Urban area served: Miami, Florida.
Transit agency: New Jersey Transit;
Urban area served: Newark, New Jersey - New York, New York.
Transit agency: New York Metropolitan Transit Authority (NY-MTA);
Urban area served: New York, New York.
Transit agency: Orange County Transportation Authority (OCTA); Urban
area served: Orange, California.
Transit agency: Pierce County Transportation Benefit Area Authority
(Pierce Transit);
Urban area served: Tacoma, Washington.
Transit agency: Port Authority Trans-Hudson (PATH);
Urban area served: Jersey City, New Jersey.
Transit agency: Santa Clara Valley Transportation Authority (VTA);
Urban area served: San Jose, California.
Transit agency: South Florida Regional Transportation Authority (Tri-
Rail);
Urban area served: Pompano Beach, Florida.
Transit agency: Southern California Regional Rail Authority
(Metrolink);
Urban area served: Greater Los Angeles, California.
Transit agency: San Francisco Municipal Railway (MUNI);
Urban area served: San Francisco, California.
Transit agency: Sound Transit (Sounder);
Urban area served: Seattle, Washington.
Transit agency: Southeastern Pennsylvania Transportation Authority
(SEPTA);
Urban area served: Philadelphia, Pennsylvania.
Transit agency: TRIMET;
Urban area served: Portland, Oregon.
Transit agency: Virginia Railway Express (VRE);
Urban area served: Northern Virginia, Greater Washington D.C.
Transit agency: Washington Metropolitan Area Transit Authority (WMATA);
Urban area served: Washington, D.C.
Source: GAO.
[End of table]
During site visits to mass transit and passenger rail agencies, we
interviewed grant managers and transit agency security officials
responsible for developing TSGP grant applications. Further, we
interviewed state administration agency officials directly involved in
the TSGP to determine how the administration of the program worked
between the state administration agencies and TSA and FEMA. We
discussed the TSGP, either in person or by teleconference, with the
SAA's in Washington, D.C., and the following states: Washington,
Illinois, Minnesota, California, Texas, Georgia, Florida,
Massachusetts, and New York.
To determine the extent to which DHS has allocated, awarded, and
distributed TSGP grants in accordance with statutory deadlines and
leading practices for collaborating agencies, we reviewed a variety of
applicable laws, guidelines, and best practices. To determine DHS's
compliance with statutory deadlines, we analyzed TSGP requirements in
the DHS appropriations acts for fiscal years 2007, 2008, and 2009
against DHS's TSGP actions to release grant guidance and act upon grant
applications. Additionally, we interviewed officials from FEMA's Grants
Preparedness Directorate (GPD) and the Office of Environmental and
Historical Preservation (OEHP) to determine what actions were being
taken to meet the requirements of the National Environmental Policy
Act. To determine DHS's compliance with federal guidance, we compared
FEMA controls for the TSGP, including how grant monies are monitored
through FEMA's financial systems and spreadsheets, with criteria in
Standards for Internal Controls in the Federal Government.[Footnote 63]
To determine the extent to which DHS followed leading practices for
collaborating agencies, we compared plans and procedures in place
between TSA and FEMA to manage the program with criteria in our October
2005 report.[Footnote 64]
To determine the status of grant funding since 2006, we reviewed the
length of time between grant allocation and grant distribution. This
required reviews of extensive grant documentation, including reviewing
original grant award dates for fiscal years 2006 through 2008,
analyzing grant project approval dates from TSA, reviewing grant
adjustment notice (GAN) and release of funds memos from FEMA, as well
as grant distribution and drawdown information from FEMA's financial
system and internal spreadsheets. We compared this information against
the records of three state administrative agencies for states with
large Tier I transit agencies to determine the accuracy of the dates
and financial information we gathered and returned to FEMA for
explanations when we found discrepancies. We also reviewed grant
guidance and grant requirements to determine the performance period
during which agencies had to spend grant funding. Additionally, we
interviewed TSA grant management officials and FEMA GPD and OEHP
officials to gain additional information on how the grant process works
at each stage--allocation, award, and distribution. Our analysis also
included interviews with officials from the transit agencies listed in
table 2 to gain additional information on how grants are allocated and
awarded as well as the length of time involved to complete the grant
process.
To determine the extent to which DHS has evaluated the effectiveness of
the TSGP as well as investments made using funds awarded through the
TSGP, we reviewed the following documents for guidance on performance
measures for infrastructure protection grant programs as well as for
any measures related to the TSGP: the National Preparedness Guidelines,
the NIPP, the TS-SSP-mass transit modal annex, and the TSGP grant
guidance. Additionally, we reviewed the guidance on leading practices
for collaborating agencies as well as best practices for project
management. To determine whether TSA or FEMA had implemented any
measures for the administration of the TSGP, we interviewed TSA grant
management officials as well as officials in FEMA's GPD and OEHP.
Finally, to identify the extent to which TSA and FEMA are measuring
TSGP investments, we reviewed the Office of Management and Budget's
Program Assessment Rating Tool, which identified baselines and targets
for measures for the infrastructure protection grants.
We conducted this performance audit from September 2007 to June 2009 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.
[End of section]
Appendix II: Fiscal Year 2008 Project Effectiveness Groupings:
Project effectiveness group score: 4;
Description: Training, operational deterrence, drills, public awareness
activities;
Project type:
* Developing security plans;
* Training:
- Security awareness;
- DHS-approved behavior recognition detection courses;
- Countersurveillance;
- Immediate actions for security threats/incidents;
* Employee security threat assessments (e.g., background checks);
* Operational deterrence:
- Canine teams;
- Mobile explosives screening teams;
- Visible intermodal protection response teams;
* Crowd assessment;
* Public awareness.
Project effectiveness group score: 3;
Description: Multi-user high-density key infrastructure protection;
Project type: Antiterrorism security enhancement measures, such; as
intrusion detection, visual surveillance with live; monitoring, alarms
tied to visual surveillance system, recognition software, tunnel
ventilation and drainage; system protection, flood gates and plugs,
portal; lighting, and similar hardening actions for:
* Tunnel hardening;
* High-density elevated operations, and;
* Multi-user high-density stations.
Project effectiveness group score: 2;
Description: Single-user high-density key; infrastructure protection;
Project type:
* Hardening of supervisory control and data acquisition systems;
* Antiterrorism security enhancement measures for;
* High-density stations and;
* High-density bridges.
Project effectiveness group score: 1;
Description: Key operating asset protection;
Project type:
* Physical hardening of control centers:
- Bollards;
- Stand off;
- Access control;
* Secure parked trains, engines, and buses for bus/rail yards;
* Maintenance facilities.
Source: DHS.
Note: In fiscal year 2009, DHS added an additional project
effectiveness grouping, "other mitigation activities," which included
the following project types: evacuation plans, interoperable
communication, and antiterrorism security enhancement measures for low-
density stations.
[End of table]
[End of section]
Appendix III: TSGP Risk Analysis Model:
The TSGP risk model accounts for risk to both intracity rail (subway
and commuter rail) and bus systems. The rail and bus scores are
combined to determine the total transit risk for the region. Within
each mode, the threat index accounts for 20 percent of the total risk
score while the vulnerability and consequence indexes account for 80
percent. DHS's measurement of vulnerability and consequence is mainly a
function of the consequences of a successful terrorist attack,
represented by a population index, the total number of trips made on a
system in a given year, and a national infrastructure index, which
focuses on critical assets that if attacked would cause severe losses
of life because of their particular vulnerabilities and damage
mechanisms.[Footnote 65] Figure 5 shows the TSGP risk model.
Figure 5: TSGP Risk Model:
[Refer to PDF for image: illustration]
Total transit risk (Rail/Bus):
1) Rail risk [Threat times Vulnerability and consequence]:
* Threat (20%);
Data: Threat tier score (classified);
Sources: DHS and OI&A.
* Vulnerability and consequence (80%) [Population index plus National
infrastructure index]:
- Population index (40%):
Data: Passenger trips (rail);
Source: American Public Transportation Association (APTA), unlinked
passenger trips, as provided by DHS, TSA.
- National infrastructure index (40%):
Data: Underground track miles;
Source: TSA;
Data: Underwater structures formula;
Source: TSA.
2) Bus risk [Threat times Vulnerability and consequence]:
* Threat (20%);
Data: Threat tier score (classified);
Sources: DHS and OI&A.
* Vulnerability and consequence (80%):
- Population index (40%):
Data: Passenger trips (bus);
Source: APTA, unlinked passenger trips, as provided by TSA.
Source: DHS.
[End of figure]
[End of section]
Appendix IV: TSGP Tier I and II Regions:
Table 3 shows the Tier I regions for 2009, and table 4 shows the Tier
II regions for 2009.
Table 3: TSGP Tier I Regions for 2009:
State: California;
Urban Area: San Francisco Bay Area.
State: California;
Urban Area: Greater Los Angeles.
State: Washington, D.C./Maryland/Virginia;
Urban Area: Greater National Capital Region.
State: Georgia;
Urban Area: Atlanta area.
State: Illinois/Indiana;
Urban Area: Chicago area.
State: Massachusetts;
Urban Area: Boston area.
State: New York/New Jersey/Connecticut;
Urban Area: New York City/Northern New Jersey.
State: Pennsylvania/New Jersey;
Urban Area: Philadelphia area.
Source: DHS.
[End of table]
Table 4: TSGP Tier II Regions for 2009:
State: Arizona;
Region: Phoenix area.
State: Arizona;
Region: Tucson area.
State: California;
Region: Fresno area.
State: California;
Region: Sacramento area.
State: California;
Region: San Diego area.
State: Colorado;
Region: Denver area.
State: Florida;
Region: Jacksonville area.
State: Florida;
Region: Miami/Fort Lauderdale area.
State: Florida;
Region: Orlando area.
State: Florida;
Region: Tampa area.
State: Hawaii;
Region: Honolulu area.
State: Illinois;
Region: Urbana-Champaign area.
State: Indiana;
Region: Indianapolis area.
State: Kentucky;
Region: Louisville area.
State: Louisiana;
Region: New Orleans area.
State: Massachusetts;
Region: Springfield area.
State: Michigan;
Region: Detroit area.
State: Michigan;
Region: Lansing area.
State: Minnesota;
Region: Twin Cities area.
State: Missouri;
Region: Kansas City area.
State: Missouri;
Region: St. Louis area.
State: Nevada;
Region: Las Vegas area.
State: Nevada;
Region: Reno area.
State: New Mexico;
Region: Albuquerque area.
State: New York;
Region: Albany area.
State: New York;
Region: Buffalo area.
State: New York;
Region: Rochester area.
State: North Carolina;
Region: Charlotte area.
State: Ohio;
Region: Cincinnati area.
State: Ohio;
Region: Cleveland area.
State: Ohio;
Region: Columbus area.
State: Ohio;
Region: Dayton area.
State: Oregon;
Region: Portland area.
State: Oregon;
Region: Eugene area.
State: Pennsylvania;
Region: Pittsburgh area.
State: Puerto Rico;
Region: San Juan area.
State: Rhode Island;
Region: Providence area.
State: Tennessee;
Region: Memphis area.
State: Tennessee;
Region: Nashville area.
State: Texas;
Region: Austin area.
State: Texas;
Region: Dallas/Fort Worth/Arlington area.
State: Texas;
Region: Houston area.
State: Texas;
Region: El Paso area.
State: Texas;
Region: San Antonio area.
State: Utah; Region:
Salt Lake City area.
State: Virginia;
Region: Norfolk area.
State: Virginia;
Region: Richmond area.
State: Washington;
Region: Seattle area.
State: Washington;
Region: Spokane area.
State: Wisconsin;
Region: Madison area.
State: Wisconsin;
Region: Milwaukee area.
Source: DHS.
[End of table]
[End of section]
Appendix V: Tier II National Review Panel Criteria, 2006 through 2008:
2006:
1. Rail and bus specific project types and priorities[A];
2. Cost-effectiveness;
3. Ability to reduce risk of catastrophic events;
4. Sustainability;
5. Relevance to national preparedness goal and National Strategy for
Transportation Security;
6. Relevance to Regional Transportation Security Strategy, Urban Area
Homeland Security Strategy, and State Homeland Security Strategy;
7. Timelines;
8. Innovativeness.
2007:
1. Transit security fundamentals;
2. Cost-effectiveness;
3. Risk reduction;
4. Sustainability;
5. Timelines;
6. Use of section 5307 grants[B].
2008:
1. Project Effectiveness Grouping[C];
2. Cost effectiveness;
3. Risk score grouping;
4. Sustainability;
5. Timelines;
6. Feasibility.
Source: DHS.
[A] Bus project types included inventory control improvements,
increased perimeter security, training and awareness, emergency
response and preparedness, and implementation of technology-driven
surveillance. Rail project type included use of passive measures,
development and enhancement of improvised explosive devices, mitigation
capabilities, and mitigation of high consequence risks.
[B] Federal Transit Administration section 5307 grant program
distributes funds to urbanized areas and to governors for transit
capital and operating assistance in urbanized areas and for
transportation-related planning. Eligible purposes include planning,
engineering design and evaluation of transit projects, and other
technical transportation-related planning.
[C] See appendix II for project effectiveness groupings.
[End of table]
[End of section]
Appendix VI: TSGP Priorities 2006 through 2009:
Fiscal year: 2006;
Rail:
* Protection of underwater and other deep-bore tunnels and associated
track mileage from attacks;
* Development and enhancement of capabilities to prevent, detect, and
respond to terrorist attacks employing improvised explosive devices;
* Mitigation of other high-consequence risks identified through
individual transit system risk assessments;
Bus:
* Development and enhancement of capabilities to improve inventory
control;
* Increased perimeter security at intracity bus depots and yards;
* Development of training and awareness among intracity bus operators
and employees;
* Development of emergency response and preparedness capabilities;
Implementation of technology-driven surveillance;
* Suspicious activity detection and behavior pattern recognition.
Fiscal year: 2007;
Rail:
* Protection of high-risk/high-consequence underwater and underground
rail assets;
* Protection of other high-risk/high-consequence assets and systems
that have been identified through system-wide assessments;
* Use of visible, unpredictable deterrence;
* Targeted counterterrorism training for key frontline staff;
* Emergency preparedness drills and exercises;
* Public awareness and preparedness campaigns;
* Efforts in support of the national preparedness architecture;
Bus:
* Same as Rail.
Fiscal year: 2008;
Rail:
* Training, operational deterrence, drills, public awareness
activities[A];
* Multi-user high-density key infrastructure protection[B];
* Single-user high-density key infrastructure protection[C];
* Key operating asset protection[D];
Bus:
* Same as Rail.
Fiscal year: 2009;
Rail:
* Training, operational deterrence, drills, and public awareness
activities;
* Multi-user high-density key infrastructure protection;
* Single-user high-density key infrastructure protection;
* Key operating asset protection;
* Other mitigation activities[E];
Bus:
* Same as Rail.
Source: DHS.
[A] Operational deterrence activities include canine teams, mobile
explosive screening teams, and Visible Intermodal Protection Response
teams.
[B] Projects include intrusion detection, visual surveillance with live
monitoring, alarms tied to visual surveillance system, recognition
software, tunnel ventilation and drainage system protection, flood
gates and plugs and portal lighting.
[C] Projects include antiterrorism security enhancement measures for:
high-density stations and high-density bridges.
[D] Projects include: physical hardening/security of control centers;
securing stored/parked trains, engines, and buses; and securing bus/
rail yards, and maintenance facilities.
[E] Projects include interoperable communications, evacuation plans,
and antiterrorism security enhancement measures for low-density
stations.
[End of table]
[End of section]
Appendix VII: FEMA's Environmental and Historic Preservation Review
Project Types:
Category A projects:
* Purchases such as vehicles, patrol boats, ID cards, handheld or
portable equipment, and navigation or communication equipment for
vehicles, boats, or other mobile units;
* Classroom and Web-based training, conferences, and workshops;
* Personnel, administrative, fiscal, and management activities;
* Development and distribution of information bulletins;
* Technical assistance activities;
* Installation of security measures on mobile units (buses, train cars,
ferries, etc.) as long as these mobile units are less than 50 years
old;
* Placement of floating barriers.
Category B projects:
* Security and surveillance equipment, including but not limited to
closed-circuit television cameras, motion detection systems, and ID
card readers;
* Physical security enhancements, including but not limited to
lighting, barriers, fencing, and gates;
* Installation of generators;
* Field exercises.
Category C projects:
* Communication towers;
* New construction and renovation;
* Physical security enhancements that directly or indirectly involve
ground-disturbing activities beyond areas previously disturbed;
* Modification to or renovation/alteration of existing facilities that
are 50 years old or greater.
Source: FEMA.
[End of table]
[End of section]
Appendix VIII: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
May 15, 2009:
Mr. Stephen M. Lord:
Director, Homeland Security and Justice Issues:
Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Lord:
The Department of Homeland Security (DHS) appreciates the opportunity
to review and comment on the Government Accountability Office's (GAO)
draft report GAO-09-491 titled, Transit Security Grant Program: DHS
Allocates Grants Based on Risk but its Risk Methodology, Management
Controls, and Grant Oversight Can Be Strengthened. The findings in the
report will be useful in strengthening the effectiveness and efficiency
in how we execute and measure a risk-based approach to allocating
transit security grants.
The Transit Security Grant Program (TSGP) has evolved greatly since
fiscal year 2006 based on internal and external stakeholder feedback,
lessons learned and streamlined processes. While several improvements
have been made, we recognize the need to continue to improve the
process, including addressing the recommendations raised in this
report.
DHS concurs with the GAO's recommendations to strengthen the Transit
Security Grant Program. Following are our recommendation-specific
responses; technical comments have been provided under separate cover.
Recommendation 1: Develop a cost-effective method for incorporating
vulnerability information into future iterations of the Transit
Security Grant Program risk model
DHS Concurs: DHS recognizes the value of including agency and asset
vulnerability information to support all decisions based on risk
considerations such as allocation of funds and project selections. We
will make appropriate adjustments in the Fiscal Year (FY) 2010 grant
cycle.
Recommendation 2: Define TSA and FEMA's respective roles and
responsibilities for managing the TSGP in a memorandum of understanding
or similar document.
DES Concurs: The Transportation Security Administration (TSA) and the
Federal Emergency Management Agency (FEMA) will collaboratively develop
the Memorandum of Understanding (MOU) before the FY 2010 grants cycle,
and share it with external stakeholders to ensure the responsibilities
and relationship between TSA and FEMA are clear in the management of
the Transit Security Grant Program.
Recommendation 3: Develop a cost-effective plan for monitoring the use
of grant funds once projects have been implemented, which includes a
strategy for leveraging resources that could allow TSA surface
transportation security inspectors to assist in monitoring the grant
projects to ensure that the projects meet the security requirements set
out in the TSGP guidance.
DES Concurs: FEMA will work towards development of a cost effective
monitoring plan to include the use of TSA surface transportation
security inspectors in such instances when their expertise in transit
security would be appropriate in monitoring grant program functions.
Since FEMA has the statutory grant management responsibility for the
TSGP including monitoring and oversight, monitoring of grant program
activity will remain a FEMA function. Also, FEMA has and will continue
to increase its staffing levels to aid in accomplishing robust
monitoring of grant programs. As an example, the addition of five (5)
new Full-Time Employees (FTE's) in the Grant Programs Directorate's
Transportation Infrastructure Security Branch will allow for an
improved programmatic monitoring capability in FY 2009-2010.
Recommendation 4: Develop an interim solution to systematically collect
data and track grant activities until FEMA's grants management system
can perform these functions and ensure that both agencies have access
to this data.
DES concurs: Proactive, documented, and continual information sharing
and communication are essential to the successful implementation and
management of a grant program. Methods of information sharing and data
tracking, such as transmitting formal approval letters and release of
funds memos between TSA and FEMA, not only strengthen the management
and oversight of the grant program, but also increase accountability
and responsiveness when questions arise about any part of the process.
TSA and FEMA will identify appropriate channels for data collection,
information sharing and tracking, and reconciliation so both agencies
have access to all appropriate information to ensure accurate and
consistent record keeping. Examples that are already being implemented
by FEMA include updating tracking logs and project spreadsheets to
include applications, awards, Environmental and Historic Preservation
processes, Release of Funds memos, and grant monitoring reports; all of
which is to be shared by FEMA with TSA. Likewise, TSA will provide FEMA
with data it collects on grant funded projects and activities from TSA
outreach efforts to TSGP grantees and stakeholders.
Recommendation 5: Collaborate to develop a plan and milestones for
measuring the effectiveness of the TSGP and its administration.
DHS Concurs: DHS concurs that a collaborative written plan with
established goals and milestones will be designed and implemented as
part of the MOU or other formal agreement between TSA and FEMA.
Recommendation 6: Establish a timeframe for revising environmental
regulations that consider non-disaster homeland security grant
programs.
DHS Concurs: FEMA's environmental regulations currently apply to non-
disaster grants. FEMA is currently working with DHS Headquarters (HQ)
to update these procedures and is targeting completion for the end of
the calendar year contingent on any delay which may result from the
time necessary to complete identified procedural changes.
Recommendation 7: Establish and communicate timeframes for making funds
available to transit agencies once FEMA receives project approvals from
TSA.
DHS Concurs: FEMA will make every reasonable effort to establish and
communicate timeframes for releasing funds to TSGP grantees once FEMA
receives approval of grant projects from TSA. However, release of funds
is often dependent upon the responsiveness of grantees in submitting
required documents (e.g. Environmental and Historic Preservation (EHP)
and detailed budgets) and questions related thereto. Given this, FEMA
will work proactively to follow up with grantees on requests for
information. Once all required EHP and budget information is received
from grantees, and appropriate clearances are provided by the Office of
Environmental and Historic Preservation and the financial analyst, FEMA
will release funds within 3-5 days.
The Department of Homeland Security appreciates the work done by GAO to
review our Transit Security Grant Program; we look forward to working
with you on future homeland security issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix IX: GAO Contact and Staff Acknowledgments:
GAO Contact:
Stephen M. Lord, (202) 512-8777 or lords@gao.gov:
Acknowledgments:
In addition to the contact named above, Dawn Hoff, Assistant Director;
Daniel Klabunde, Analyst-in-Charge; and Martene Bryan, Senior Analyst,
managed this assignment. Jason Berman, Charlotte Gamble, and Su Jin Yon
made significant contributions to the work. Chuck Bausell and William
Chatlos assisted with design, methodology, and data analysis. Linda
Miller and Lara Kaskie provided assistance in report preparation, and
Tracey King provided legal support.
[End of section]
Footnotes:
[1] Mass transit and passenger rail systems consist of various bus and
passenger rail transit systems. Transit bus systems include inter-city
bus or trolleybus systems. Transit rail includes heavy, commuter, light
and intercity rail systems. Heavy rail is an electric railway that can
carry a heavy volume of traffic. Heavy rail is characterized by high
speed and rapid acceleration, passenger rail cars operating singly or
in multicar trains on fixed rails, separate rights-of-way from which
all other vehicular and foot traffic is excluded, sophisticated
signaling, and high-platform loading. Most subway systems are
considered heavy rail. Commuter rail is characterized by passenger
trains operating on railroad tracks and providing regional service,
such as between a central city and its adjacent suburbs. Light rail
systems typically operate passenger rail cars singly (or in short,
usually two-car, trains) and are driven electrically with power being
drawn from an overhead electric line. Amtrak operates the nation's
primary intercity rail system.
[2] DHS began providing grant funding specifically for transit security
in 2003 through the Urban Area Security Initiative (UASI) grant
program. In 2003 and 2004, the UASI program distributed $65 million and
$50 million, respectively, in grant monies to mass transit and
passenger rail agencies. The UASI program is designed to provide
funding to enhance urban areas overall security and preparedness levels
to prevent, respond to, and recover from acts of terrorism. UASI
funding is available to urban areas for a variety of activities,
including planning, organization, equipment, training, exercises, and
management and administration. The program is not limited to providing
money to transportation systems. In 2005, the TSGP program was
introduced and has since been the primary source of federal grant
funding for transit security.
[3] Pub. L. No. 111-5, 123 Stat. 115, 164 (2009). The $150 million was
appropriated for both the TSGP and the Freight Rail Security Grant
Program which provides a separate funding stream for freight rail
security.
[4] Amtrak, the largest passenger rail service in the United States,
has its own dedicated funding stream through the Intercity Passenger
Rail Security Grant Program. Additionally, there is also a separate
funding stream for freight rail security through the Freight Rail
Security Grant Program, which received $15 million in fiscal year 2009.
Ferry systems may apply for funding either through the TSGP or through
DHS's Port Security Grant Program, which allocated $5 million to ferry
systems in fiscal year 2009.
[5] Department of Homeland Security National Infrastructure Protection
Plan (NIPP) (Washington, D.C.: June 30, 2006, and February 2009 update)
and GAO, Risk Management: Further Refinements Needed to Assess Risks
and Prioritize Protective Measures at Ports and Other Critical
Infrastructure, [hyperlink, http://www.gao.gov/products/GAO-06-91]
(Washington, D.C.: Dec. 15, 2005). The overarching goal of the NIPP is
to build a safer, more secure, and more resilient America by
preventing, deterring, neutralizing, or mitigating the effects of
deliberate efforts by terrorists to destroy, incapacitate, or exploit
elements of our nation's critical infrastructure and key resources and
to strengthen national preparedness, timely response, and rapid
recovery of critical infrastructure and key resources in the event of
an attack, natural disaster, or other emergency.
[6] Because of changes in FEMA's financial recording procedures for
fiscal year 2006, we computed total time from TSA award date to FEMA's
funding release date for 2006 grants differently than for fiscal year
2007 and 2008 grants. However, we still concluded that FEMA data were
reliable for the purposes of this audit.
[7] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, GAO-06-15
(Washington, D.C.: Oct. 21, 2005) and 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).
[8] State administrative agency responsibilities included submitting
grant applications, disbursing funds to the transit agencies, and
submitting required financial and administrative paperwork.
[9] GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing
Season Performance Measures, [hyperlink,
http://www.gao.gov/products/GAO-03-143] (Washington, DC.: Nov. 22 2002)
and Agency Performance Plans: Examples of Practices That Can Improve
Usefulness to Decisionmakers, [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-99-69] (Washington, DC.: Feb.
26, 1999).
[10] Mass transit systems also include passenger ferry boats,
trolleybuses, cable cars, monorail, and demand response services.
However, for this report, mass transit will refer only to four
components: heavy rail, commuter rail, light rail, and bus.
[11] This program makes federal resources available to urbanized areas
and to governors for transit capital and operating assistance in
urbanized areas and for transportation related planning. Eligible uses
for funds include planning, engineering design and evaluation of
transit projects and other technical transportation-related studies;
capital investments in bus and bus-related activities, crime prevention
and security equipment and construction of maintenance and passenger
facilities; and capital investments in new and existing fixed guideway
systems.
[12] American Public Transportation Association, Survey of United
States Transit System Security Needs and Funding Priorities
(Washington, D.C.: April 2004).
[13] Pub. L. No. 108-334, 118 Stat. 1298, 1309 (2004); Pub. L. No. 109-
90, 119 Stat. 2064, 2076 (2005); Pub. L. No. 109-295, 120 Stat. 1355,
1369 (2006); Pub. L. No. 110-28, 121 Stat. 112, 142 (2007); Pub. L. No.
110-161, 121 Stat. 1844, 2062 (2007); Pub. L. No. 110-329, 122 Stat.
3574, 3671 (2008).
[14] The fiscal year 2005 TSGP provided $150 million for intercity
passenger rail transportation, freight rail, and transit security
grants.
[15] Pub. L. No. 110-53, § 1406, 121 Stat. 266, 405-08 (2007).
[16] TSA has been given the legal mandate pursuant to the Aviation and
Transportation Security Act of 2001 and the Homeland Security Act of
2002 to manage the Department's transportation security programs and
ensure the security of the transit industry. Pub. L. No. 107-71, 115
Stat. 597 (2001); Pub. L. No. 107-296, 116 Stat. 2135 (2002).
[17] The Post-Katrina Emergency Management Reform Act of 2006 was
enacted as Title VI of the Department of Homeland Security
Appropriations Act, 2007, Pub. L. No. 109-295, 120 Stat. 1355, 1394
(2006).
[18] HSPD-7 directed the Secretary of Homeland Security to establish
uniform policies, approaches, guidelines, and methodologies for
integrating federal infrastructure protection and risk management
activities.
[19] TSA's transit security fundamentals are: (1) protection of high
risk underwater/underground assets and systems; (2) protection of other
high-risk assets that have been identified through systemwide risk
assessments; (3) use of visible, unpredictable deterrence; (4) targeted
counterterrorism training for key frontline staff; (5) emergency
preparedness drills and exercises; and (6) public awareness and
preparedness campaigns.
[20] See appendix IV for a listing of Tier I and Tier II regions.
[21] Eligible Tier II transit agencies are determined by using FTA's
National Transit Database, which identifies transit agencies by
ridership. Transit agencies that are not in the top 100 for unlinked
transit passenger trips are not eligible for funding. (An unlinked
transit passenger trip is a trip on one transit vehicle regardless of
the type of fare paid or transfer presented).
[22] An overview of allocations for fiscal years 2006 through 2009 was
discussed earlier in this report (see table 1).
[23] The DHS appropriations acts for fiscal years 2007 through 2009
established these deadlines for the respective grant cycles. Pub. L.
No. 109-295, 120 Stat. 1355, 1369 (2006); Pub. L. No. 110-161, 121
Stat. 1844, 2062 (2007); and Pub. L No. 110-329, 122 Stat. 3574, 3671
(2008).
[24] DHS has encouraged all TSGP applications to have a regional
coordination component that demonstrates an investment strategy based
on a regional security strategy. Many Tier I and Tier II regions have
more than one transit agency operating, so coordination of federal TSGP
investments is encouraged and is reflected in the regional
collaboration component of the overall project score.
[25] Prior to fiscal year 2008, DHS's Office of Grants and Training was
responsible for conducting these reviews.
[26] FEMA's EHP review ensures that all FEMA-funded activities comply
with various federal laws, including the National Environmental Policy
Act, National Historic Preservation Act, Endangered Species Act and
executive orders on floodplains, wetlands, and environmental justice.
[27] FEMA has established three project categories--A, B, and C--to
help distribute project reviews between GPD and OEHP. Type A and B
projects are considered the least likely to have an environmental
impact and are not reviewed by OEHP. For example, the training of
employees is considered to have no environmental impact and, therefore,
would be labeled as a Type A project. Type B projects--involving
buildings less than 50 years old or that break no new ground--are
reviewed and approved by GPD. Type C projects--such as physical
security enhancements that directly or indirectly involve ground-
disturbing activities beyond areas previously disturbed--are viewed as
more likely to have an environmental impact, and GPD submits them to
OEHP for review.
[28] GAO, Homeland Security: DHS Risk-Based Grant Methodology Is
Reasonable, But Current Version's Measure of Vulnerability is Limited,
[hyperlink, http://www.gao.gov/products/GAO-08-852] (Washington, D.C.:
June 27, 2008).
[29] A countermeasure is any action taken or physical equipment used
principally to reduce or eliminate one or more vulnerabilities.
[30] Under the BASE program, TSA's transportation security inspectors
gather vulnerability data by reviewing a transit agency's
implementation of its security programs to help identify shortfalls in
security. Since 2006, TSA has conducted BASE reviews at most of the 100
largest mass transit agencies in the nation and has initiated follow-on
BASE reviews to determine if previously identified security shortfalls
have been corrected.
[31] We analyzed the model for fiscal years 2007 and 2008.
[32] In addition to Tier I and II agencies, the risk model calculates a
risk score for Amtrak; however, the DHS appropriations acts have
generally provided a minimum threshold of funding for Amtrak grants.
[33] The risk scores used in the formula were unclassified scores
derived from the risk model.
[34] Project quality consists of an evaluation of the investment
justification against the following criteria: cost effectiveness,
feasibility, timelines, and sustainability.
[35] The remaining $13.7 million allocated to Tier II agencies was
transferred to Tier I regions that requested additional funding for
their top-priority projects.
[36] TSA held two after-action conferences in 2008 for the TSGP. The
first was in Seattle, Washington on September 29 and the second was in
Arlington, Virginia on October 15. GAO staff attended both conferences
as did representatives from 35 agencies, including stakeholders from
transit agencies, state administrative agencies, law enforcement
agencies, and city and county departments of transportation.
[37] According to the 9/11 Commission Act, frontline transit employees
include employees of public transportation agencies who are transit
vehicle drivers or operators, dispatchers, maintenance and maintenance
support employees, station attendants, customer service employees,
security employees, or transit police, or any other employees who have
direct contact with riders on a regular basis, and any other employees
of public transportation agencies that the Secretary of Homeland
Security determines should receive security training. Pub. L. No. 110-
53, § 1402(4), 121 Stat. 266, 401 (2007).
[38] Several transit agencies began installing chemical and biological
detection systems using federal grant funds after September 11, 2001,
such as the PROTECT system at Washington Metropolitan Area Transit
Agency in Washington, D.C. The PROTECT system is aimed at providing an
early warning crisis management capability in the event of a chemical
agent attack in a subway system (and potentially in other transit
modes).
[39] The Mass Transit Security Government Coordinating Council/Sector
Coordinating Council (GCC/SCC) includes TSA, DHS, DOT and mass transit
and passenger rail stakeholders. According to the Transportation
Systems-Sector Specific Plan (TS-SSP) Mass Transit Modal Annex--the
sector-specific plan for mass transit that outlines the unique
characteristics of the mass transit sector and provides the means by
which the NIPP is implemented in a mass transit environment--this
council facilitates coordination on developing security strategies,
programs, and initiatives and allows for more effective execution of
the executive order on surface transportation security.
[40] In fiscal year 2005, DHS required transit agencies to develop risk-
based security and emergency preparedness plans and regional transit
security strategies to be eligible for grant funding. These plans must
address the prevention, detection, and response to incidents involving
IEDs and chemical, biological, radiological, and nuclear devices.
[41] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[42] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[43] For fiscal year 2007, DHS had 75 days to release the grant
guidance once the appropriations act had passed, and for fiscal years
2008 and 2009, DHS had 30 days to release the grant guidance once the
appropriations act had passed.
[44] TSA data also show that during the fiscal year 2006 grant cycle,
71 percent of Tier I projects were approved within 7 months of the
award; during the initial grant cycle in fiscal year 2007, 65 percent
of projects were approved within 5.4 months; and during the
supplemental grant cycle in fiscal year 2007, 61 percent of projects
were approved within 3.6 months.
[45] The guidance identified three project types, A, B, and C. Type A
and B projects are considered the least likely to have an environmental
impact and are not reviewed by OEHP. For example, training projects
have no environmental impact and, therefore, would be labeled as a Type
A project. Type B projects--involving buildings less than 50 years old
or that break no new ground--are reviewed and approved by GPD's EHP
liaison before funds are released. Type C projects--such as physical
security enhancements that directly or indirectly involve ground-
disturbing activities beyond areas previously disturbed--are viewed as
more likely to have an environmental impact, and GPD submits them to
OEHP for review.
[46] The total number of grant projects that have been approved by TSA
for FEMA review for fiscal year 2006 and fiscal year 2007 is 325
projects.
[47] The Project Management Institute, The Standard for Program
Management © (2006).
[48] Expend refers to the actual spending of money; unexpend refers to
the amount of obligated and un-obligated balances.
[49] Grant performance period refers to the amount of time agencies
have to complete grant projects.
[50] Obligations occurs when an agency places an order, signs a
contract, awards a grant, purchases a service, or takes other actions
that require the government to make payments to the public or from one
government account to another. Drawdown refers to the amount of money
agencies have had paid to them from their grant award.
[51] GAO, National Emergency Grants: Labor Is Instituting Changes to
Improve Award Process but Further Actions Are Required to Expedite
Grant Awards and Improve Data, GAO-04-496 (Washington, D.C.: Apr. 16,
2004).
[52] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[53] Project Management Institute, The Standard for Program Management
© (2006).
[54] The PART was developed to assess and improve program performance
so that the Federal government can achieve better results. A PART
review helps identify a program's strengths and weaknesses to inform
funding and management decisions aimed at making the program more
effective. The PART therefore looks at all factors that affect and
reflect program performance including program purpose and design;
performance measurement, evaluations, and strategic planning; program
management; and program results. Because the PART includes a consistent
series of analytical questions, it allows programs to show improvements
over time and allows comparisons between similar programs.
[55] According to FEMA, the cost-to-capability assessment is to provide
the means to obtain a relevant measure of dollars for capability
improvement and to analyze and improve the performance of GPD's
portfolio of grants. It will allow FEMA to better manage its portfolio
of federal preparedness grant programs by (1) quantifying the benefits
of preparedness grant programs, (2) streamlining grant application and
reporting processes across grant programs, and (3) identifying
investment efficiencies across the preparedness grant portfolio.
[56] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[57] A FEMA official reported that there were multiple phases for the
new grants management system, and when completed it will cover the full
grant lifecycle.
[58] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[59] Domestic Working Group, Guide to Opportunities for Improving Grant
Accountability (Washington, D.C.: October 2005).
[60] GAO, Low-Income and Minority Serving Institutions: Department of
Education Could Improve Its Monitoring and Assistance, [hyperlink,
http://www.gao.gov/products/GAO-04-961] (Washington, D.C.: Sept. 21,
2004).
[61] GAO, Grants Management: Enhancing Performance Accountability
Provisions Could Lead to Better Results, [hyperlink,
http://www.gao.gov/products/GAO-06-1046] (Washington, D.C.: Sept. 29
2006).
[62] [hyperlink, http://www.gao.gov/products/GAO-06-15].
[63] 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).
[64] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington D.C.: Oct 21, 2005).
[65] A trip represents the entire end-to-end ride by a passenger. These
data are collected from the American Public Transportation Association
and, for the fiscal year 2008 model, represent 2006 data. The national
infrastructure index primarily accounts for the toll on human life
caused by an attack on these critical transit system assets.
[End of section]
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