This Dec. 3, 2010 Government Accountability Office Report concerns ferry security. Specifically, the GAO looked at how the USCG assesses risk to ferries and what particular threats were identified. The report also looks at the actions that port security stakeholders such as federal agencies, law enforcement, and ferry operators have taken to protect ferry systems. In putting together the report, the GAO reviewed three years’ of security operations data (2006-2009) and went into the field at five domestic and one international ferry systems of varying sizes. This report is the open-source version of a sensitive document.
Ferry systems are huge contributors to the nation’s transportations system and to the economy. According to respondents to the 2008 National Census of Ferry Operators, ferry systems carried more than 82 million passengers and over 25 million vehicles. As such, they are considered prime targets for terrorism. The report states that although “in April 2010, Coast Guard intelligence officials stated that there have been no credible terrorist threats identified against ferries and their facilities in at least the last 12 months, maritime intelligence officials have identified the presence of terrorist groups with the capability of attacking a ferry. Many of the Coast Guard, ferry system and law enforcement officials GAO spoke with generally believe ferries are vulnerable to passenger- or vehicle-borne improvised explosive devices, although not all ferry systems transport vehicles. “ The report also states, “Ferries are also potential targets for terrorism in the United States and have been terrorist targets overseas.”
The issues in the report that most concern the wider MTSA community are found in the discussion of security concerns. The report states, “Maritime security stakeholders reported various ferry-related security concerns with the greatest concerns being improvised explosive device attacks delivered via vehicles, passengers or small boats… According to the Coast Guard’s Strategy for Maritime Safety, Security, and Stewardship, one of the greatest risks associated with maritime scenarios is a direct attack using a waterborne improvised explosive device, and a recurring attack mode has been the use of small boats to carry out an attack.” There is a good discussion of the ripple effect of an attack on a ferry, using the SUPERFERRY 14 as a case study. The method of attack and death toll of that incident are widely known. What is less recognized are the long-term economic consequences of that attack: the decision to deploy sea marshals, which are composite teams of the Armed Forces, National Police and Philippine Coast Guard personnel together with guards from the shipping companies, on board major passengers vessels to provide security while the ships are underway, as well as the cost of “heightened surveillance, investigation, arrest, and detention powers for the police and intelligence services.”
In the risk mitigation section, the GAO looks at Coast Guard actions. The USCG conducts quarterly inspections and “conducts operational activities to secure ferries, including conducting boat escorts of ferries, implementing positive control measures—that is, stationing armed Coast Guard personnel in key locations aboard a vessel to ensure that the operator maintains control—and providing a security presence through various actions.” TSA also supports ferry security by demonstrating a security presence through the VIPRE teams, providing training such as the excellent products produced from its Port and Intermodal Division, and implementing pilot programs involving security technologies. CBP also has a role in securing vessels on international voyages, through deployment of radiation detection technology and through inspection of passengers, bags, vehicles, and crew disembarking at international ferry crossings. Of course owner/operators are responsible for implementation of security assessments and plans and required security measures through MTSA. Discussing observation of screening, GAO observers stated that they encountered a ferry system that did not appear to be screening according to its standards, although the report goes on to state “but we did not determine any failure to meet minimum screening requirements.”
The report notes that ferries are very MTSA-compliant in comparison to other types of vessels (notably excursion tour vessels) and “Coast Guard officials stated that ferry security deficiencies were commonly found in the following areas: security plan audits and amendments; drills and exercises; records and documentation; and access control procedures, including monitoring of secure and restricted areas. “ Access control procedures also include screening, as per 33 CFR 104.265.
For those of us who have attempted without success to speak to the USCG (at the local as well as the HQ level) about the issue of screening, there is interesting information under the headings “The Coast Guard May Be Missing Opportunities to Enhance Ferry Security “ and “The Coast Guard Has Not Evaluated and, if Determined Warranted, Acted on Report Findings and Recommendations .” The report states that the USCG spent $1.5 million on studies of ferry security in 2005 and 2006, and “these studies were aimed at establishing a new benchmark for ferry screening and enhancing the agency’s ability to focus on improving security practices, screening technology, and identification of explosive hazards.” The USCG, however, has “not evaluated and, if determined warranted, taken actions on the ferry security reports.” Results of the studies were communicated to the Commandant, some AMSC’s, and the ports of the 6 systems observed, but there was no general distribution throughout the Sectors. “In May 2010, Coast Guard program officials stated that there were no current actions being taken to address the findings and recommendations from the National Ferry Security Study. Coast Guard officials explained that the ferry security reports were released when the agency was undergoing an internal reorganization and as a result the reports were not sent to the appropriate unit after the reorganization—which they also believe is the likely reason for why no further actions were taken to evaluate or address the reports’ findings and recommendations. “
They also stated that security training, including that if screening personnel, was being addressed in the re-write of Subchapter H, which was begun in late 2006 but delayed by the TWIC program. “In addition, Coast Guard officials stated that they have been developing a Navigation and Vessel Inspection Circular for about 2 years to provide updated guidance for ferry screening… Although the officials reported these efforts initially began in about 2005 or 2006, they did not expect the Navigation and Vessel Inspection Circular to be published until fall 2010.” The GAO observes, “Although these ongoing efforts may address some of the findings and recommendations from the 2005 and 2006 reports, it is not evident that the Coast Guard utilized the reports or their recommendations to inform the agency’s decision making, as officials could not confirm whether the 2005 and 2006 reports were the catalyst for the agency’s actions. In addition, Coast Guard officials confirmed that the ongoing actions will not address all of the findings and recommendations from the reports. As a result of our work on ferry security, in August 2010, Coast Guard officials stated that they believe the ferry security reports can still provide valuable information and they plan to begin evaluating the reports in fall 2010. “ The report also states that the USCG informed the GAO that the results of the 2005 and 2006 studies will not be taken into account in the re-write of Subchapter H.
The report has a similar negative conclusion when it addresses vehicle screening requirements for ferry operators. The USCG has not updated these requirements since 2004, a situation familiar to the maritime security training community. “Despite Coast Guard documents from 2004 stating that a reassessment of the screening requirements should be conducted when the ferry security studies were completed or if the threat were to change—both of which have occurred—as of May 2010, Coast Guard officials stated that they had not taken action to reassess and update the requirements since the 2004 security directive. “
GAO’s recommendations were to #1, review these 2005 and 2006 studies and take appropriate actions to address the findings and recommendations identified in these reports; and #2, “upon review of the reports, ensure that vehicle screening requirements are set at an appropriate level that considers both the risks to and operating requirements of ferry systems, and when warranted, reassess screening requirements for ferries and make changes as appropriate.”
For persons new to MTSA, on pages 8 – 10 there is an excellent set of tables that lays out roles and responsibilities of the many stakeholders involved in maritime security, and the legal and regulatory framework that direct the security actions of vessel and facility operators.
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