(Download
in Adobe PDF Format)
The Honorable Tom Ridge
Secretary
U.S. Department of Homeland Security
3801 Nebraska Avenue
Washington, DC 20528
Dear Secretary Ridge:
I write on behalf of the American Public Transportation Association (APTA)
and its 1,500 member organizations regarding the FY 2005 Department of Homeland
Security (DHS) Appropriations bill that was signed into law by President Bush
on October 18, 2004 (P.L. 108-334). APTA appreciates and supports the initiatives
of the Department of Homeland Security and your strong leadership in addressing
the security needs of our nation. We also appreciate the fact that DHS Under
Secretary Asa Hutchinson was able to speak at our Annual Meeting in Atlanta
earlier this month, where his positive and encouraging message was well received
by our members.
APTA 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.
Congressional Directives in P.L. 108-334
We think it important to note at the outset that a recent APTA survey identified
some $6 billion in transit security needs. We are grateful for the way in
which DHS and now Congress are beginning to provide critical investments for
public transit systems following the terrible events of 9/11. In particular,
we appreciate bill language in P.L 108-334 that provides $150 million for
"rail and transit security grants" under the DHS Office of State
and Local Government Coordination and Preparedness. We note that funds under
this program may be available for a range of rail modes, including transit,
freight and intercity. Given the number of daily passengers served by the
transit industry, identified transit security needs, and the fact that public
transit provides a public service that relies on public funding, we urge DHS
to allocate no less than $100 million of this $150 million resource for transit
security needs. We appreciate the fact that we had an opportunity to communicate
this recommendation to Elizabeth Dorfman at the Office for Domestic Preparedness
(ODP), and we would be pleased to provide any additional information DHS may
need in this regard.
We also note that there is $885 million available in P.L. 108-334 for the
Urban Areas Security Initiative (UASI). We urge DHS again to earmark resources
within that amount for transit as was the case with FY 2003 and FY 2004 UASI
funds, though we urge that more resources be made available in that regard.
Again, our survey demonstrates there are real transit security unmet needs,
and we urge DHS to make as much funding available as possible to begin to
meet these critical needs.
Further, we believe that such DHS grant funding should go directly to 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 $12 million in funding to the Transportation Security Administration
(TSA) 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 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 such compliance or
monitoring purposes. We also 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 rail security needs.
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, no
federal department has responded to our request for subsequent funding of
the Public Transit ISAC.
Unlike other ISACs that have been created for private sector entities, the
Public Transit ISAC supports public agencies that are dependent upon public
funding support. A recent GAO report has recommended that the Public Transit
ISAC be funded by the Federal Government. Consequently, there is an immediate
and pressing need for federal support to maintain this critical security intelligence
information sharing, and we urge DHS to provide no less than $600,000 in funding
to keep the Public Transit ISAC up and running in FY 2005.
MOU Between DOT and DHS
Finally, we urge 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.
Thank you for your consideration of our position on these issues.
Sincerely yours,
William W. Millar
President
WWM/amm
Some of these pages may include links to documents in the Adobe PDF format. Please download the Adobe PDF reader if you have not already done so.
