USA Today reports that Pistole will make mass transit as high a security priority as air travel. He's quoted as saying: "Given the list of threats on subways and rails over the last six years going on seven years, we know that some terrorist groups see rail and subways as being more vulnerable because there's not the type of screening that you find in aviation. From my perspective, that is an equally important threat area."

Read the full story here.

I would urge him to spend 30 days traveling, without advising anyone he is doing so. Observe the TSA at work in big and small airports and take notes. That’s the only way to get a real sense of what the public sees and experiences.

Then I would urge him to sit down with key staff and ask:

(1) Why aren’t procedures identical at all locations? Why do some want to see boarding passes multiple times while others do not? Why haven’t we implemented a mandatory national standard procedure?

(2) Why aren’t we putting full body scan capability in every airport? What is the purpose of concentrating all the machines in big airports? Why can’t we publish an honest accounting of how long full body screening takes, rather than putting out numbers that are observably incorrect?

(3) Why haven’t we created a Trusted Traveler Program? Congress mandated, years ago, that those willing to undergo professional, in depth background screening and use biometric identifiers should be able to get through security without hassle. We know that security hassles impact business travelers more heavily than others and we know that costs money and slows down the pace of commerce. Why haven’t we fixed it?

(4) Why aren’t we using a risk based system, and why – particularly – are we still giving ordinary travelers the same level of attention as those who have characteristics consistent with those who have threatened the system in the past? Are we really unwilling to use profiling and related observational techniques because of our desire to be politically correct? Is political correctness more important than the public’s safety?

(5) Why are we still doing the work ourselves? Isn’t there a way for us to turn the day to day task over to private enterprise while providing policy guidance and operational supervision? Wouldn’t doing it that way save money and increase efficiency?

I have no doubt that a diligent and intelligent manager would come up with many more questions – the key is that to run something well, you must first understand it thoroughly at the grass roots level.

If Mr. Pistole wants to do well, he will stop listening to senior staff, get familiar with all the details of the system, and run the TSA the way any company should be run – efficiently and for the benefit of the traveling public, which are the TSA’s customers.

We look forward to working with Administrator Pistole and strongly encourage him to prioritize surface transportation security. The TSA has primarily focused on aviation, but its mission, broadly stated, covers all modes of transportation. Surface transportation security, and specifically public transportation, has not received the appropriate attention of the leadership of DHS and TSA. The Administration has asked for amounts well below what was prescribed in the 9/11 Commission Act, and Congress has provided only small increases above those levels. As a result, funding is inadequate.

According to the Department of Transportation, 618 million passengers used the U.S. aviation system in 2009, compared with 10.2 billion trips taken on public transportation. With public transit’s average daily ridership at 20 times the airline average daily domestic ridership, it makes sense to increase resources for public transit security. Decisions on resource allocation at the beginning of the budget process in FY 2012 are among the most important to correcting this inequity.

It is important to acknowledge that much progress has been made at TSA to advance the goal of collaboration with the public transportation industry and it is to be lauded for its work with us on issues such as training, information sharing, and standards development. Administrator Pistole should be sure to get behind his people on issues like these and provide them with the leadership and support they need to do more collaborative work with our industry and the Department of Transportation.

Finally, with regard to the transit security grant program, we recommend that Administrator Pistole streamline the way transit agencies access and implement security funds. The nation’s public transportation systems share the department’s commitment to public safety and security. We are all in this together.

TSA Administrator Pistole should focus on understanding where the greatest security risks lie and truly embed a risk-based approach to channeling the agency’s resources. TSA has dedicated a large amount of human and capital resources to the aviation sector and to the transit sector. Such a focus makes sense considering the clear threats that those sectors face and the potential for mass casualties.

In the highway sector, TSA should work with state highway agencies and other federal partners to ensure that our highway system is protected from potential terrorist threats that could disrupt the supply chain. If damaged or destroyed, important bridges and other key highway nodes could cause serious disruptions.

It is also critical that TSA improves coordination and information sharing between the agency and those with a vested interest in highway transportation. There are already enough security regulations on motor carriers to ensure the security of our operations. However, improvements in information sharing are needed to help build awareness of potential threats. In addition, commercial drivers are presently subjected to redundant background checks to perform various duties (e.g., port work, hauling hazardous materials, etc.). DHS and TSA need to develop a single, comprehensive security threat assessment process that requires one application but has application to many programs.

The TSA is long overdue for a serious re-think. Here are three major changes the new Administrator should make.

First, instead of just giving lip-service to risk-based security policymaking, the TSA should apply this concept seriously, across the board. Other DHS agencies already do this. For example, cargo entering the United States across land borders by truck and train and at seaports is not 100% screened or scanned. Instead, various programs (such as CT-PAT) certify those supply-chain providers willing to go the extra mile in security; they become a kind of trusted shipper whose goods need less-stringent attention on an everyday basis. Likewise, Customs & Border Protection has a rapidly growing international registered traveler program called Global Entry that lets pre-vetted frequent travelers bypass Immigration formalities when they re-enter the country. These policies make both economic and security sense. They save shippers and travelers valuable time and they permit DHS to focus its always-limited resources on people and cargo that is more likely to need scrutiny.

Thus, my second recommendation is that TSA proceed with all deliberate speed to set up a real trusted traveler program for domestic frequent flyers. By real, I mean a security program, not just an identification program. Under the original trusted traveler program called for by Congress in the 2001 ATSA legislation, applicants would be required to pass a criminal history background check and get a biometric ID card. Because they would then have been pre-cleared (just as in Global Entry), they should be enabled to bypass not only the long checkpoint lines but also the post-9/11 additions to checkpoint screening—shoes, overcoats, laptops, liquids. Estimates are that current airport screening costs US air travelers $15-30 billion per year in wasted time. Since frequent flyers constitute such a large fraction of each day’s travelers, a trusted traveler program might save half that annual sum. And it would permit TSA to focus its screening resources on travelers more likely to present a security problem.

Third, and obviously longer-term, TSA should rethink the agency’s dual role as both the aviation policymaker/regulator and the operator of a significant portion of airport security, namely passenger and baggage screening. This dual role is an obvious conflict of interest, since TSA cannot be an arm’s-length regulator of the quality and cost-effectiveness of screening in the same way it is the arm’s-length regulator of those portions of airport security carried out directly by airports. And the current approach results in fragmented airport security, as we saw in the incident at Newark when no single party was clearly in charge of video surveillance of the checkpoint exit area. Making TSA just the policymaker and regulator would mean devolving the screening role to airports, as is common practice just about everywhere in Europe. And as in Europe, airports would be free to “make or buy” screening services—in either case, under the regulatory oversight of TSA.

These changes would strengthen aviation security, by better focusing TSA’s always-limited resources and by integrating security at the airport level. A worthy goal would be to have these changes in place by the 10th anniversary of 9/11, next year.

It is safe to say that there are few more challenging jobs in government than running the Transportation Security Administration (TSA). That is what I told John Pistole when we talked last week and I commend him for reaching out to airports. Over the years, as TSA evolved, the relationship and coordination with industry has improved significantly. Recent events have proven that government and industry must continue to work together to combat the threat of terrorism. Below are some opportunities to further enhance our very positive relationship:

1. Coordinate security initiatives, including new security requirements, with airports. This is critically important as the lion’s share of aviation security is conducted at airports. In so doing, we can increase the chance of success of new efforts. When we have a good level of coordination – such when we collectively responded to the August 2006 explosives plot – it helps prevent further problems down the line. Although the issuance of security directives in that instance was appropriate, it was done with ample industry coordination. However, that has not always been the case and security directives have been used when a rulemaking or another proposed regulatory change would have been more appropriate, and ensured more industry input. These incidents have declined in recent months, which is a good thing and for which I commend TSA.

2. Routinely evaluate security measures for currency/applicability. The aviation sector has been at Orange Alert for almost four years now and some of security measures have become stale. ACI-NA proactively commenced what we call an In-Depth Security Review to examine all of the security measures and identify those that are duplicative, stale, in need of improvement or no longer make sense given the evolution of the threat and/or implementation of countermeasures. TSA has partnered with us in this endeavor. To be effective security programs must remain fresh and current, with an element of randomness.

3. Provide the industry with timely intelligence updates and information. There is a tendency to overlook a significant resource available in the airport law enforcement officers. These airport representatives are the eyes and ears and can provide critical information through the coordination centers at airports about events unfolding locally. It is better when airports have an understanding of the threat and the rationale for particular security initiatives.

4. There is a need to develop internationally recognized security technology standards. These cannot be imposed by the U.S.; they must be harmonized in true partnership with the international community. This should result in more effective screening technology at a lower cost, and something that could allow passengers and baggage crossing international borders to be screened once. Again, it is critical that airports be involved in the development of any such standards. As a practical example, the development of technology standards could help to resolve the longstanding issue of TSA having to use limited resources to re-screen checked baggage arriving on flights from Canada prior to it being loaded on connecting flights in the U.S., something that poses operational challenges for airports and airlines. Again, it is critical that airports be involved in the development of any such standards.

5. We must fully embrace and implement a risk management approach. To some in the political world, this may be misinterpreted as a "reduction" in security, but the truth is that it is just the opposite. This is how we enhance security. If TSA or some other agency is engaged in activities that do not truly address the risks we face, then I would argue security is reduced, even if “more” is being done. TSA must be focused on addressing true risks. "More" is not the issue. "Better" is.