Last fall Congress enacted the 9/11 Commission Act of 2007. Among its provisions was the requirement that TSA implement a system to physically screen cargo carried on passenger planes: 50% of such cargo by February 2009 and 100% by August 2010. At the time, I pointed out that while this mandate sounded costly and cumbersome to those in the cargo supply chains, it did promise to fix a glaring inconsistency in the original Aviation & Transportation Security Act of 2001. That measure mandates 100% explosives screening only for checked luggage on planes, ignoring not only belly cargo but also carry-ons (much less rigorous screening than checked bags) and passengers themselves (the vast majority of whom are checked only for metallic objects). A lot has happened in the past year. Despite some initial complaints from the New York Times editorial page and cargo-screening advocate Rep. Ed Markey (D, MA), TSA is proceeding with its plan to distribute the screening to various points in the cargo supply chain, rather than concentrating it all at the airport (which would cause huge bottlenecks). The program is called Certified Cargo Screening Program (CCSP), and under it, both shippers and freight forwarders may opt to become Certified Cargo Screening Facilities (CCSFs), where actual screening and sealing of shipping crates, pallets, or containers would take place. Sealed boxes would then be transported to the airport by certified personnel, where they would be turned over to airlines for loading onto planes. The advantage to shippers and forwarders is that their cargo will likely get onto planes sooner than what ends up getting screened at the airport. Last year the Congressional Research Service made an initial estimate that the belly-cargo screening mandate would cost $3.7 billion over its first 10 years. The only number I’ve seen since then is in GAO’s July 15, 2008 testimony on TSA’s progress in this area (GAO-08-959T). GAO’s Cathleen Berrick reported that although CCSFs will be required to purchase their own screening equipment, TSA will reimburse them up to $375,000 per facility. There are about 12,000 freight forwarders, not all of whom will volunteer for this role, but a number of manufacturers probably will, so let’s use 12,000 as an estimate of the number of CCSFs. At $375K apiece, the equipment cost alone would be $4.5 billion. To that one-time cost must be added the annual staff and paperwork cost at each CCSF, plus the annual cost of TSA inspectors to oversee the whole process. It’s clear this is going to cost a lot more than CRS estimated. Lest you think this is just about small packages and other mundane stuff, belly cargo consists of about 250 million individual packages (boxes, crates, pallets, containers) per year. And at $4.4 billion, it’s a non-trivial portion of airline revenue. (Domestic passenger revenue in 2005 was $71.2 billion.) Stuff shipped this way includes laptop computers, auto parts, human organs, fresh flowersââ?¬â??an incredible array of things. That makes physical screening quite complicated. GAO says TSA is making progress, but still faces four major challenges in implementing the system. First, it’s still testing various technologies, to decide which ones work well enough for it to certify. Second, there are a number of long-standing exemptions from physical screening, and TSA has to review them all to see which ones might still be justified under the new law; that work is still under way. Third, TSA has a lot of work to do to expand its staff that does compliance inspections of freight forwarders, since it will also have to inspect shippers that become CCSFs. In a 2005 report, GAO found that TSA had inspected only 49% of forwarders, and had found violations at more than 40% of those inspected. Finally, GAO pointed out that TSA does not plan to include “inbound” cargo in this programââ?¬â??although Customs & Border Protection already screens inbound cargo upon its arrival here. TSA says it will meet the February 2009 deadline for screening 50% of belly cargo. I’m not holding my breath, given all it has left to do. And I still question whether this new mandate from Congress is a wise use of resourcesââ?¬â??as opposed to devoting much of that money to better intelligence work to identify potentially high-risk cargo.