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In this six-part series focusing on transforming the aviation security system, I’ve focused on fundamental reforms needed to bring about a better, more effective Transportation Security Administration, or TSA 2.0. These reforms can provide the American public with an organization that thinks, acts, and has an employee culture that brings out the best within itself and the industry. Internationally, TSA 2.0 can foster collaborative and innovative partnerships that support raising the bar on practices and technologies across the integrated whole of the global aviation system.

This final installment tackles whether TSA has the ability and will to transform itself. My sense is that it does not, and the time has come to merge it with Customs and Border Protection (CBP). All of the evidence suggests that TSA 2.0, as a component of CBP, will be more effective, more cost efficient, and more innovative than it has been as a stand-alone agency. Let’s review this move through the lens of the preceding five articles.

In Part 1 of this series, I discussed the need for accountability in the execution and oversight of screening operations. As discussed, an organization that writes the screening rules, implements the procedures, and monitors itself for compliance loses sight of quality control and quality assurance. Firewalling screening oversight from screening operations can be provided by a congressionally chartered corporation. Absent this function, TSA will not need the administrative legions required to support more than 42,000 screening officers. CBP has great depth and more than 200 years of experience with oversight functions. Merging TSA’s talent with that of CB, would produce a more uniform and lean regulatory oversight function.

Part 2 and Part 4 focused on transforming the culture of TSA from that of a tactical organization to a strategic one. Such an organization would be data-driven and outcome-focused when developing security frameworks. Most importantly, it would continually ask when developing a new regulation or technology the order of magnitude that an identifiable risk is brought down and the order of magnitude a hole is plugged in the existing system. Such paradigm shifts have been batted around TSA for a decade or more and have never taken root. This was probably too big of an expectation for a young and immature agency. CBP owns data-driven, risk-based security management across trade and border control functions. They get it and have the mindset.

Leadership in innovation as a core component of TSA 2.0 was discussed in Part 3. Currently, we seem to keep pace with the bad guys, or stay a bit ahead, but TSA’s model for innovation hasn’t produced much in the way of game changing advances. Additionally, the agency’s entire contracting process nearly duplicates CBP’s. It makes no sense to have two security service providers managing passengers in airports employing two bureaucracies trying to solve the same technology problems. A “merger” not only will result in better screening equipment purchases but will bring sanity back to how the volumes of passenger data are collected and used. Advantage CBP.

In Part 5, I stressed the importance of setting a new customer service mindset for all newly hired screening officers and the bureaucracy that oversees the workforce. Coupling this with proper infrastructure investment, renewed emphasis on pre-screening, and an enhanced customer experience at checkpoints can create a sustainable model where customer service and tight security can coexist. Every day, CBP screens nearly one million visitors to this country. They do so without generating the headlines that TSA does. While not perfect, the history and maturity of CBP’s operational processes can provide lessons and leadership to the airport security screening function.

So what does TSA look like after a merger with CBP? Here are some thoughts:

  • Move TSA’s 42,000 screeners and Office of Security Operations to a congressionally chartered Screening Services Corporation with a presidentially appointed Board of Directors.
  • Create an Assistant Commissioner for Passenger Screening within CBP’s Office of Field Operations and transfer all remaining TSA staff to CBP. Eliminate all duplication and consolidate functions.
  • Move the Federal Air Marshall program to the U.S. Border Patrol. Consolidate training facilities and training programs, and allow current CBP officers to cross train to an aviation role.
  • Merge TSA’s Global Strategies Office with CBPs Office of International Affairs. Consolidate all functions and policy.
  • Move TSA’s Office of Acquisition, Office of Information Technology, and Office of Security Capabilities to CBP’s new Office of Acquisition.
  • Merge the intelligence and analysis functions of both agencies.
  • Merge TSA’s Office of Security Policy and Industry Engagement with CBP’s Office of Trade Relations.

TSA has served us well since 9/11, and we owe a debt of gratitude to the women and men who built it as they tried to write a new chapter in aviation security, surveying the horrors of the World Trade Center, the Pentagon, and Shanksville. My argument across these six articles is not that they failed us, but that the world has moved quickly over these past 15 years. As we tighten border security and aviation security, the two have become so intractably intertwined, that it no longer makes sense to talk about the two independently or administer them independently.

Certainly, there is the money issue. Both CBP and TSA share a plethora of identical functions. But the strongest argument is that we have outgrown TSA and the singular focus on checkpoint, land, and pipeline security as written after 9/11. Passenger and cargo security need to be integrated regardless of the method and direction by which one crosses the U.S. border.

Ken Dunlap is managing partner for the Dorado Consulting Group, which specializes in transportation policy. He is also a Senior Fellow at the George Washington University Center for Cyber and Homeland Security. Read More