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45 ground processes, as well as the credentials themselves, would Impetus and Authority. The impetus for policies and/or require certain costs. It is possible that in some cases the act of an organization can come from a variety of sources including consolidation could result in cost savings associated with some federal legislation, rulemaking, executive authority, or local aspect of the overall credential process. This information authority. Congress, through legislative action, can create the should be understood before a definitive decision could be impetus for particular policies and/or the organization itself. made on the best course of action regarding consolidation. As Regulatory impetus refers to those policies that have been is often the case, the costs associated with the various options established by agencies through the rulemaking process. Exec- for consolidation could significantly change the perspective of utive authority indicates the impetus originated with an exec- stakeholders, ultimately changing the ideal option from one to utive order. Local authority refers to those policies established another. by state, local, or regional special authority (for example, the In addition to understanding the costs associated with establishment of a port authority and subsequent port oper- potential consolidation it is important to understand the ating procedures). Table 3-18 provides an overview of the rel- effect that consolidation could have on existing stakehold- evant credential, and its authority. ers, and the likelihood for successful adoption and use. In order to inform this discussion, it was necessary to evaluate Organizational Form. Jensen (44, p. 110) defines orga- policy impetus as it relates to the process of consolidating nizational form as a particular organization type that has a security credentials for persons who transport hazardous specific policy purpose and mission. For example, the DHS materials. implements policies related to homeland security. Jensen also notes that organizations tend to have an institutional basis or a technical basis, while often combining elements of both. Policy Implementation Analysis Organizations with an institutional basis "are derived more The following discussion draws upon organizational change, from values and meanings of society and less on technical organizational learning, and policy implementation research, activities, efficiency, or rationality."(44, p. 114) An example of and presents a multiple-perspective analysis (i.e., organiza- an institution basis is a port when it operates to implement tional, technical, and personal). Multiple-perspective analysis is shipping policies. Institutional-based policy decisions may be designed to deal with ill-structured policy problems employing contentious. As a result, policy changes may require resolution a systematic evaluation of policy solutions.(6) from the political system. Changes may need to be dictated by the legislator, which acts as the moderator of large-scale change (44). Without legislative intervention, proposed policy changes Organizational Perspective may face significant resistance. The characteristics of the organizations in question must be Organizations that have a technical basis tend to focus on taken into account when policy changes are proposed. Organi- efficiency or have a production basis. As Jensen notes, these zational characteristics to be considered are impetus and agencies exist to fulfill a concrete need and to improve effi- authority, organizational form, and competitive isomorphism. ciency.(44) For example, departments of motor vehicles exist Table 3-18. Credentialing agency's impetus and authority. Credential Impetus Authority FAST Congressional Public Law 109-59 (i.e., SAFETEA-LU) Based upon state, local, or regional special Local Ports Local Authority authority (i.e., port authority) MMC Executive 46 CFR Part 10 MMD Executive 33 CFR 101-146 and 46 CFR Parts 10-16 NEXUS Congressional Public Law 109-59 (i.e., SAFETEA-LU) Executive and Passport 8 USC 1185[b] and 22 CFR 53 Congressional SENTRI Congressional Public Law 109-59 (i.e., SAFETEA-LU) SIDA Executive 49 CFR 1542, 1544 Maritime Transportation Security Act of TWIC Congressional 2002, Public Law 107-295 and 46, USC 70195 U.S. Department of Defense Homeland Security Presidential Directive 12 Executive CAC (HSPD-12) Executive and USC 3301-3302; 5 CFR 5, 731, 732, 736; U.S. Postal Service Congressional and Executive Orders 10450 and 105775

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46 to implement and enforce motor vehicle policies. Technical of standards and determining responsibility for the new policy. needs may be internal to organizational units and may differ A number of agencies, in response to agential concerns, devel- significantly among organizations. Continuing the state depart- oped the current credentials. As a result, the underlying justi- ments of motor vehicle example, policies and procedures fications for these credentials vary. For the FAST, Local Ports, within each state may vary and may use differing technologies. MMD, NEXUS, U.S. passport, SENTRI, SIDA, TWIC, and Table 3-19 provides an overview of credentials and associated CAC, the underlying justification is security. For the MMC, the organizational forms. underlying justification is to ensure skill, knowledge, and secu- rity. For the USPS credential, the underlying justification is to ensure fitness for duty and security. Technical Perspective Likewise, agency stakeholders hold certain expectations The technical perspective considers the climate in which the in regard to each credential's function and administration. organization exists, financing, risk, and technological trends. Changes to current policy may be viewed as a challenge of an organization's power within the policy subsystem or as a chal- Organizational Climate. Organizational climate requires lenge to the organization's legitimacy. To manage uncertainty, that one account for the intangible feelings of political power, cross-functional teams should be included in the development institutional legitimacy, and social fitness. The competition for of the new policy from the earliest stage possible. These cross- power and legitimacy may be manifest in difficulties in recon- functional teams should represent members of all departments ciling differing requirements of specific policies into a new set (e.g., management, data processing, information technology) Table 3-19. Credential and associated organizational form. Institutional or Technical Credential Organizational Oversight Predominant Basis Canada Border Service Agency and U.S. Customs Technical--charged with enforcing FAST and Border Protection customs and border policies Agency Institutional--develops and implements Local Ports Local Authority policies beneficial to the operation of the local concern Institutional--charged not only with providing for the national defense, but also MMC U.S. Coast Guard with developing operational guidelines that are consistent with institutional norms Institutional--charged not only with providing for the national defense, but also MMD U.S. Coast Guard with developing operational guidelines that are consistent with institutional norms U.S. Customs and Border Technical--charged with enforcing NEXUS Protection Agency customs and border policies Technical--as a unit of the Department of State, CA is charged with protecting the Bureau of Consular Affairs lives and interests of American citizens Passport (CA) abroad and strengthening the security of U.S. borders through the vigilant adjudication of visas and passports U.S. Customs and Border Technical--charged with enforcing SENTRI Protection Agency customs and border policies Technical--as a unit of DHS, charged with Transportation Security protecting the nation's transportation SIDA Administration systems to ensure freedom of movement for people and commerce Technical--as a unit of DHS, charged with Transportation Security protecting the nation's transportation TWIC Administration systems to ensure freedom of movement for people and commerce Institutional--charged not only with U.S. Department of providing for the national defense, but also Defense Common U.S. Department of Defense with developing operational guidelines that Access Card are consistent with institutional norms Independent executive Technical--charged with the task of mail U.S. Postal Service agency established within delivery the U.S. Constitution

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47 Table 3-20. Credential stakeholders. Credentialing Agency and Credential Credential User Stakeholders Affiliated Agencies Canada Border Service Agency and U.S. Customs and Border Supply-chain members including commodity FAST Protection Agency and U.S. shippers, truck drivers Department of Homeland Security Individuals seeking access to ports including longshoremen, truck drivers, port employees, Local Ports Local Authority vessel crews, outer continental shelf facility workers, merchant mariners Crewmembers of U.S. ships with a GRT of MMC U.S. Coast Guard more than 100 tons Crewmembers of U.S. ships with a GRT of MMD U.S. Coast Guard more than 100 tons Canada Border Service Agency Supply-chain members including commodity NEXUS and U.S. Customs and Border shippers, truck drivers, crews of shipping Protection Agency and U.S. vessels and airplanes, facility managers Department of Homeland Security Bureau of Consular Affairs (CA) Individuals attempting to depart from or Passport and U.S. Department of State enter the United States Canada Border Service Agency and U.S. Customs and Border Supply-chain members including commodity SENTRI Protection Agency and U.S. shippers, truck drivers Department of Homeland Security Transportation Security Individuals who need unescorted access to Administration and U.S. SIDA secure areas of airports and aircrafts, airport Department of Homeland management, airlines and other shippers Security Transportation Security Individuals seeking access to ports including Administration and U.S. longshoremen, truck drivers, port employees, TWIC Department of Homeland vessel crews, outer continental shelf facility Security workers, merchant mariners U.S. Department of Defense and U.S. Department of Members of the armed services, civilian U.S. Department of Homeland Defense CAC employees, government contractors Security U.S. Postal Service USPS Postal employees and vendors and organizations affected by the new policy. Consolidated Risk. Risk refers to the balancing of policy details with credentialing efforts will require a number of agencies and financial constraints. Trust is also a consideration. Trust issues departmental units to work together to address the needs of can manifest in the lack of trust between participating organi- a variety of stakeholders. A brief summary is presented in zations or a lack of trust in the policy results. To address trust Table 3-20. This list of stakeholders is meant to provide a issues, the development and implementation of a consolidated macro-level view of the stakeholders that should be involved in credential will require that stakeholders work together to ensure credential consolidation discussions and efforts. that program needs are addressed, guidelines are established, and outcomes are met. Financing. Waldron notes that cost of change is a major barrier to the implementation of new policies.(45) Cost and Technology Trends. Technology trends require that one financing concerns include the more tangible costs associ- accounts for the testing of new systems, the continued useful- ated with competition over scarce resources and customers. ness of current systems, and potential problems relating to the Examples of financial considerations include current and timing of the change to a new system and general coordination future policy revenue streams (or lack thereof); cost of equip- of that change. It is critical that policy change activities be coor- ment and technologies; cost of time to develop, test, and dinated in the overall policy network. There must be a clearly implement new policies; and training costs associated with communicated understanding of the new operation system if new policies. Looking at only the cost of each credential, it implementations are to be limited. Additionally, organiza- can be seen that the consolidation of credentials may have a tional units must demonstrate cooperation and a willingness significant impact on the agency's revenue generation stream to work together in order to facilitate a systemwide policy (see Table 3-21). change. When making software and hardware decisions, users

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48 Table 3-21. Credential stakeholders and associated costs. Credentialing Agency and Stated Credential Affiliated Agencies Credential Cost Canada Border Service Agency and FAST U.S. Customs and Border $50.00 Protection Agency MMC U.S. Coast Guard $100.00 MMD U.S. Coast Guard $ 1 0 0 .0 0 U.S. Customs and Border NEXUS $50.00 Protection Agency Bureau of Consular Affairs (CA) Passport $100.00 and U.S. Department of State U.S. Customs and Border SENTRI $122.25 Protection Agency American Association of Airport SIDA $91.33* Executives Transportation Security TWIC $132.50 Administration U.S. Department of U.S. Department of Defense Unavailable Defense CAC U.S. Postal Service USPS Unavailable *Note: Arithmetic mean, see Appendix F. should compare packages, obtain feedback from current users, Personal Perspective and work closely with the support personnel and line workers who will be the end-users of the technologies. Just as organizations may be resistant to change, individuals The implementation of a consolidated credential will require within those organizations may also be resistant to change. the adoption of new hardware and software. As noted in the Resistance to change can be seen at all layers of the hierarchy-- attribute overview, credentials may include bar codes, RFID, from management to front-line employees. When dealing with dual interface integrated circuit chips (ICC), and magnetic the consolidation of programs, the need to address the sources strips. The information contained in these technologies pro- of resistance is paramount. Waldron identifies several sources vides not only a redundancy of visible information on the cre- of resistance including the fear of change, difficulty in chang- dential, but also may incorporate biometrics not included ing, fear of new technology, lack of belief in the changes, lack anywhere else on the credential (e.g., the TWIC credential- of patience for the benefits of change, concern for job security, holder's fingerprint, which is available by accessing the ICC). and opposition to new tasks.(45) Waldron also identifies sev- Agencies have dedicated funding to establish the current tech- eral methods for overcoming change. These methods include nologies to make and process the credentials and to maintain obtaining assistance from outside parties, formalizing proce- the data associated with the credentials. Each facility also incurs dures, initiating quality assurance policies, embracing a model costs to accommodate the credentials. These costs not only conducive to continual modifications and supplemental include infrastructure costs, but also the costs associated with changes, and training regarding the benefits of the change as training employees on the new technologies. well as for new tasks.(45)