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September 28, 2004
The Honorable Harold Rogers
Chairman
Subcommittee on Homeland Security
House Committee on Appropriations
B-307 Rayburn House Office Building
Washington, DC 20515-6028
Dear Chairman:
I write on behalf of the American Public Transportation Association (APTA)
regarding the conference on the FY 2005 Department of Homeland Security (DHS)
Appropriations bill, H.R.4567. APTA appreciates and supports the initiatives
of the Appropriations Subcommittee on Homeland Security and its strong leadership
in addressing the public transportation security needs of our nation. Our
Association represents over 1,500 public and private member organizations
including transit systems and commuter rail operators; planning, design, construction
and finance firms; procurement and service providers; and academic institutions
and state departments of transportation.
Funding Levels
We think it important to note at the outset that a recent APTA survey identified
some $6 billion in transit security needs. We are profoundly grateful for
the way in which Congress has begun to provide critical investments for transit
systems following the terrible events of 9/11, and we trust that the bill
will reflect that commitment going forward. In particular, we appreciate Senate
bill language that would provide $278 million for "rail and transit security
grants" under the DHS Office of State and Local Government Coordination
and Preparedness. The House bill includes $100 million in funding under this
program. We urge the conferees to agree to the Senate funding level on this
issue. We also note that funds under this program may be available for a range
of rail services, including transit, freight and intercity, and thus would
appreciate language directing DHS to allocate sufficient resources to transit
rail; as noted, we have identified significant transit security needs.
Further, we believe that such DHS grant funding should go directly to the
transit agencies rather than through the State Administering Agencies (SAAs),
as is now the case. In addition, transit authorities should receive the full
amount of funding; currently, states can take up to 20% of the grant funding
for security purposes. Requiring the funds to go directly from DHS to transit
authorities means they will be made available in a more efficient and timely
manner.
Allocation of Resources
While APTA is pleased to see the support being provided to enhance transit
security with $15 million in funding to the Transportation Security Administration
(TSA) in the Senate bill language for rail security, we are concerned that
$10 million of that amount is directed to be made available for 100 DHS inspectors
for rail compliance purposes. We believe that funding to enhance actual program
and resource development should precede any such inspection and compliance
monitoring, and thus urge that such funds be made available to transit systems
for a variety of security measures. We also believe that existing Federal
Transit Administration and Federal Railroad Administration staff, given their
considerable expertise in rail and transit matters, would be a useful resource
for any compliance or monitoring purposes.
We also appreciate that House bill language provides $11 million in funding
for rail security to the TSA for evaluation and testing of specific technologies.
However, we believe this funding may be more appropriately expanded to include
the testing of a range of technologies suitable to the open environments of
public transportation.
Public Transit ISAC - Need For Funding
The federal government recognizes public transit to be one of our nation's
13 critical infrastructures due to our role in emergency evacuations and the
vital role we play in transporting Americans 32 million times each day. As
the designated Transit Sector Coordinator, APTA serves as the primary contact
to bring the public transportation community together. Accordingly, a Public
Transit Information Sharing and Analysis Center (ISAC) was created in February
2003, through an initial grant from the Federal Transit Administration. The
Public Transit ISAC provides, 24/7, a secure two-way reporting and analysis
structure for the transmission of security alerts and the sharing of critical
information. Over 130 transit systems participate in the Public Transit ISAC.
The continuation of the Public Transit ISAC is now in jeopardy, however, as
the Department of Homeland Security has not responded to our request for funding
to continue its operation. Unlike other ISACs that have been created for private
sector entities, the Public Transit ISAC supports public agencies that are
dependent upon taxpayers dollars funding support. Consequently, there is an
immediate and pressing need for federal support to maintain this critical
security intelligence information sharing. We ask that Congress direct DHS
to provide no less than $600,000 in funding to keep the Public Transit ISAC
up and running in FY 2005. A recent GAO report has recommended that the Public
Transit ISAC be funded by the Federal Government.
MOU Between DOT and DHS
Finally, we urge Congress to direct DHS to enter into a Memorandum of Understanding
(MOU) with the Department of Transportation that would specify the roles and
responsibilities of each agency with respect to public transit security. Each
agency has an important role to play in that regard, but in the absence of
an MOU those roles are blurred.
If you have any questions about these issues, please have your staff contact
Tom Yedinak of APTA's Government Affairs staff at (202) 496-4865 or email
tyedinak@apta.com.
Sincerely yours,
William W. Millar
President
WWM/amm
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