ISPS-Staff
The Coast Guard lacks adequate International Port Security Liaison Officers to ensure maritime compliance.
Flynn, 6 (Stephen, Jeane J. Kirkpatrick Chair in National Security Studies at the Council on foreign Relations, “The Continued Vulnerability of the Global Maritime Transportation system,” Testimony before a hearing of the Subcommittee on Coast Guard and Maritime Transportation, Committee on Transportation and Infrastructure, US House of Representatives, March 9, http://www.cfr.org/port-security/continued-vulnerability-global-maritime-transportation-system/p10074)
At the port of loading, a port facility is supposed to operate in compliance with the ISPS code. MTSA requires that the Coast Guard carry out assessments of overseas ports to ensure they are compliant with the code. However, the agency only has a total of 13 International Port Security Liaison Officers (IPSLO) to cover all of Europe, the Middle East, Africa, Latin America and the Caribbean. There are only another half a dozen liaison officers available to do this for Asia. Presumably these inspectors should know something about port security, be familiar with commercial port operations, and understand the local circumstances, but there is no formal training program in place to develop all of these skills. A single country like Brazil may have over 25 ports, but a typical country assessment visit will involve a 2-3 day country trip and include a visit to just one port.
PSGP Inherency
Only 12% of the PSGP grants went to port and maritime infrastructure.
Holdeman, 12 (Eric, Principal for Eric Holdeman and Associates, his areas of expertise include building regional coalitions between agencies, governments, the private sector and non-profits, works professionally in the areas of port security, emergency management and risk management. He has also authored numerous articles for professional journals and opinion pieces for local, regional and national newspapers. He is a writer for Emergency Management Magazine, “2012 Port Security Grant Awards,” Emergency Management, July 2, http://www.emergencymgmt.com/emergency-blogs/disaster-zone/port-security/2012-port-security-grant-awards-070212.html)
The 2012 list of grant organizations that received Port Security Grant Program (PSGP) awards was announced late last week along with other grant program awards. See FEMA Grant Programs Directorate Information Bulletin No. 387. I did a very quick count of number of awards and I came up with 205 total awards. Then I looked for organizations with the word "port" or other such maritime connotation in their name. I came up with 22 awards in that category. That would mean that only about 12% of the PSGP grants actually went to ports! The rest of the list has funding going to cities, police, fire departments, transportation departments, and other such organizations. I figure there are a few marine terminals also included in the mix. I cannot argue the fact that these first responder organizations do provide value added capabilities to port security. I've seen that in action for myself. It is just curious how this all sorts out. I think when the original grant was conceived it was not expected that there would be that great a percentage of non-maritime organizations applying for and receiving grants.
PSGP Budget Slashed
Port Security Grant Program budget cuts and lack of matching funds leave port infrastructure unfinished.
Kimery, 12 (Anthony, Online Editor and Manager of KMD Media, award-winning editor and journalist who has covered national and global security, intelligence, and defense issues for three decades, former Washington correspondent for the Paris-based Intelligence Newsletter, “Counternarcotics, Terrorism, & Intelligence Security, Port Authorities Associations Urge DHS To Reconsider Port Allocations,” Homeland Security Today, March 9, http://www.hstoday.us/focused-topics/counternarcotics-terrorism-intelligence/single-article-page/security-port-authorities-associations-urge-dhs-to-reconsider-port-allocations.html)
The letter was sent in response to DHS grant guidance issued on February 17, 2012 in which DHS slashed the Port Security Grant Program by 59 percent. “Even though Congress reduced the budget for preparedness grants by 40 percent, we are concerned with the allocation decisions made by the department,” SIA and AAPA said in their letter to Napolitano. “The recently announced cuts result in a 59 percent reduction in funding for the Port Security Grant Program and are 75 percent less than authorized by Congress in the SAFE Port Act.”¶ ¶ Continuing, the two organizations stated that “this allocation will not come close to meeting local needs. It will result in continued struggles to bring port security into the 21st century and hamper meeting government mandates, such as the Transportation Worker Identity Card.” The two groups said that, “while we understand that Congress initiated this cut because of what it saw as a backlog of unspent funds, we believe such a drastic reduction of funds will have negative consequences on port security. In addition, we believe that one of the best ways to utilize existing funding is to categorically waive all cost-share requirements for grants that have already been awarded. Requiring short, individual waivers diverts the efforts of those involved from the goal of getting these projects done quickly. Grantees often put projects on hold until they receive a waiver.” “We are certain there are other options available, and we would encourage your office to think through those options to help us as we help secure our ports,” the groups’ joint letter to Napolitano concluded. “Every agency has to do more with less; we understand that,” said Marcus Dunn, Director of Government Relations at SIA. “However, what is difficult to understand is the allocation made by DHS.” Many ports have applied for - and have been granted - funding for critical security components. Unfortunately, those grants have been tied to matching grants, the two organizations noted in a statement. They added that “given the state of the economy, some ports are unable to meet the matching amount, leaving those dollars unclaimed and leaving critical security projects unfinished.”
Limited resources in new security allocations only fund current projects not new security initiatives.
SDN, 12 (Security Director News, “DHS allocates $1.3 in security grant,” July 2, http://www.securitydirectornews.com/public-sector/dhs-allocates-13b-security-grants)
WASHINGTON—The Department of Homeland Security has announced final allocations of more than $1.3 billion in fiscal year 2012 funding to seven of its security grant programs.¶ In FY 2012, DHS preparedness grants were reduced by nearly $1 billion from the FY 2011-enacted level and $1.5 billion below the President’s FY 2012 request, according to DHS.¶ Because of limited resources, organizations receiving funds are encouraged to utilize grant funding to maintain current capabilities through investments in training and exercises, updates to current planning and procedures, and lifecycle replacement of equipment. New capabilities that are built using homeland security grant funding must be deployable if needed to support regional and national efforts.
The DHS slashed funding for preparedness grants, which includes port security.
Security Info Watch, 12 (“A Guide to 2012 DHS Preparedness Grants,” July 3, http://www.securityinfowatch.com/news/10737616/a-guide-to-2012-dhs-preparedness-grants)
The U.S. Department of Homeland Security announced last week that its Preparedness Grants - which help states, cities, tribal and territorial governments, non-profit agencies, as well as the private sector prevent, respond to and recover from potential terror attacks, major disasters and other emergencies - were reduced by nearly $1 billion in the 2012 fiscal year and $1.5 billion below President Obama’s request for the year.
Port Security Grants are grossly underfunded at less than 75% of what was authorized.
American Association of Port Authorities, 12 (“Maritime Security,” Government Relations Priorities, March, http://aapa.files.cms-plus.com/Maritime%20Security%202012.pdf)
The Port Security Grant program continues to be a very valuable program for ports, which serve as partners with the Department of Homeland Security (DHS) to harden security at U.S. ports and protect our homeland. Funding/Eligibility – AAPA urges Congress to continue to authorize and appropriate $400 million for the program. AAPA is concerned that last year’s drastic cuts to state homeland security grants, including the port security grant program, will threaten the ability of our nation to maintain our current capacity or expand it. For FY 2012, Congress combined all grants, cut them by 40 percent and gave DHS the authority to determine the final funding level. DHS subsequently cut the Port Security Grants further by decreasing the level of funding by 59 percent from last year’s funding level. It is currently at a level that is less than 75 percent of the authorized amount. DHS is also considering a move to merge all grant programs into one program to fund all critical infrastructure segments and transfer distribution to the states, a move which AAPA strongly opposes. Port Security is a federal responsibility and it should remain at the federal level.
Recent cuts in the Grant Program and the cost sharing mechanism are both bad for port securtiy
Erickson and Nagle 12 (Don Erickson and Kurt Nagle, Chief Executive officer of Security Industry Association, President and Chief Executive Officer of American Association of Port Authorities, Letter to Homeland Security Secretary Janet Napolitano, AAPA, March 6, http://aapa.files.cms-plus.com/Ports%20Letter%20Final.pdf , JCC1)
As organizations that represent local ports, as well as the companies that provide solutions to support port operations, we are writing you today to raise concerns about the recent cuts to the Port Security Grant Program. Safe and secure seaport facilities are critical to protecting our borders and to moving goods.
Even though Congress reduced the budget for preparedness grants by 40 percent, we are concerned with the allocation decisions made by the department. The recently announced cuts result in a 59 percent reduction in funding for the Port Security Grant Program and are 75 percent less than authorized by Congress in the SAFE Port Act. This allocation will not come close to meeting local needs. It will result in continued struggles to bring port security into the 21st century and hamper meeting government mandates, such as the Transportation Worker Identity Card. While we understand that Congress initiated this cut because of what it saw as a backlog of unspent funds, we believe such a drastic reduction of funds will have negative consequences on port security. In addition, we believe that one of the best ways to utilize existing funding is to categorically waive all cost-share requirements for grants that have already been awarded. Requiring short, individual waivers diverts the efforts of those involved from the goal of getting these projects done quickly. Grantees often put projects on hold until they receive a waiver.
Inherency – PSGP Matching Funds Requirement
The Port Security Grant matching funds requirement means there isn’t enough funding available for all security needs.
Straw, (Joseph, assistant editor at Security Management, “Port funding shows potential,” Security Management, http://www.securitymanagement.com/article/port-financing-shows-potential-004690?page=0%2C0)
Despite the region’s foresight and collaboration, Houston encountered a problem familiar to other beneficiaries of PSGP funding: how to produce DHS ’s 25 percent matching requirement. Typical DHS grants to states are matched just like federal highway funding—from state treasuries. Different PSGP recipients, usually port authorities, have satisfied the program’s matching requirements using various public revenue sources at the city, county, and state level, officials say. But there is not enough public money to meet the needs for matching funds in every case.
Cost sharing requirements for PSGP gut security investments.
Richardson, 11 (Whit, managing editor at Security Director News, “Report cites flaws in DHS port security grant program,” Security Director News, December 29, http://www.securitydirectornews.com/public-sector/report-cites-flaws-dhs-port-security-grant-program)
One thing to remember is that the PSGP is a draw-down program, meaning ports have to put up the money first before they can actually go out and get paid back for their expenses, Aaron Ellis, spokesman for the American Association of Port Authorities, told SDN. "A lot of times the permitting process can take a couple years," he said.¶ One of the issues contributing to the amount of unused funds, according to the report, has been the inconsistent cost-share requirement of grantees. While cost-share requirements were waved for fiscal years 2010 and 2011, previous years required a match. In the economic downturn, many grantees chose not to pursue the funds, especially once they knew that future monies would not carry the requirement, according to the report. The AAPA has consistently lobbied for the elimination of the cost-share requirements, which Ellis points out do not exist for the transit security and state homeland security grant programs. "Particularly in these tight economic times, the cost share is a challenge for ports that are cutting back in all areas to address economic shortfalls," Ellis said.
Cost share requirements are hard to meet which results in unused funding
GAO, 11
(Port Security Grant Program: Risk Model, Grant Management, and Effectiveness Measures Could Be Strengthened, http://www.gao.gov/assets/590/587153.txt, ME)
Fiduciary agents in 8 of 11 port areas in our review reported a lessened demand for grant funds in grant years where there was a costshare requirement, particularly for fiscal years 2008 and 2009. Fiduciary agents cited a variety of challenges with the cost-share requirement, including: (1) applicants were aware of long delays in the distribution of grant funds and faced difficulty preserving the cost-share obligation in their entity's budget while pending receipt of awarded grant funds, (2) facility owners who were compliant with security requirements under MTSA were hesitant to invest their own money for additional security projects beyond the requirements, and (3) applicants were unable to afford the cost-share requirement due to the economic downturn. For example, one fiduciary agent reported that while she generally supports a cost-share requirement because it ensures stakeholder buy-in, the cost-share requirement has been challenging due to the poor economic environment. As a result of the cost-share, this fiduciary agent reported conducting three distinct rounds of project solicitations in the fiscal year 2008 grant round in order to generate enough demand to spend the port area's entire allocation. We reported in October 2010 that a cost-share requirement is a key factor for effective federal grants because it ensures that federal grants supplement--rather than substitute for--stakeholder spending. We further reported that a cost-share requirement is reasonable given that grant benefits can be highly localized.[Footnote 39] As a result of the inconsistent cost-share requirement, several fiduciary agents told us that applicants were more likely to request funding under the grant rounds with the most lenient cost-share requirement or delay project submission while waiting to learn whether or not the next round of grants would include the cost-share requirement. This uncertainty about the cost-share requirement created a disincentive for grant applicants to request funding during costshare years. For example, the fiduciary agent in one port area told us that the port area received project proposals totaling twice the port area's total allocation for fiscal year 2011. Thus, projects had to be denied for fiscal year 2011 funding during the field-level review, even though more than $9 million in fiscal year 2008 and 2009 grant money remained unused. As shown in table 8 below, a greater portion of money from cost-share years remains unused as compared to money from non-cost-share years, even though cost-share grant years preceded the non-cost-share grant year. For example, about 22 percent of grant funding awarded to Group 1 port areas during cost-share years remains unused, as compared to less than 4 percent during fiscal year 2010, when the cost-share requirement was waived.
Cost share requirements are hard to fulfill and take too long to waiver
Richardson, 11
(Whit, managing editor of Security Director News, Report cites flaws in DHS port security grant program, Security Director News, 12-29-2011, http://www.securitydirectornews.com/public-sector/report-cites-flaws-dhs-port-security-grant-program, ME)
One of the issues contributing to the amount of unused funds, according to the report, has been the inconsistent cost-share requirement of grantees. While cost-share requirements were waved for fiscal years 2010 and 2011, previous years required a match. In the economic downturn, many grantees chose not to pursue the funds, especially once they knew that future monies would not carry the requirement, according to the report. The AAPA has consistently lobbied for the elimination of the cost-share requirements, which Ellis points out do not exist for the transit security and state homeland security grant programs. "Particularly in these tight economic times, the cost share is a challenge for ports that are cutting back in all areas to address economic shortfalls," Ellis said.¶ Grantees can submit waivers to avoid the cost-share requirement, but the "lengthy" process has 22 steps, according to the report. FEMA in November 2009 said a response to cost-share waivers could be expected approximately 30 days after submission. However, the GAO determined that on average FEMA's response time was 126 days and noted that one decision took seven months. Ghouse said a waiver the Port of Seattle submitted to FEMA took "in the magnitude of months" to be decided. As a result, ports have avoided the process, the report concluded. It recommends that FEMA review its cost-share waiver process in order to speed up the allocation of grant funds.¶
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