Before the Secretary decided that collective bargaining was incompatible with TSA's mission, the agency surveyed the managers who run its checkpoints.
TSA sent a questionnaire to its Federal Security Directors, the senior officials responsible for security screening operations at the nation's airports. Fifty of them responded. Their answers make up Tab 2 of the administrative record, and they are the closest thing in the record to direct testimony from the people who supervise the workforce day to day.
This survey matters because of how the determination uses it. The determination states that management identified strengths of the 2024 agreement, and that upon review, those strengths "were either not substantiated, were not actually the result of collective bargaining, or were so minor as to be certainly outweighed by the administrative costs." That is the determination's account of what its own survey found. The full survey is now public, and it can be read against that account.
The comparison cuts in more than one direction, and an honest reading has to take both. The managers identified real strengths in the agreement. They also identified real problems with it.
What Managers Said Was Working
The agency asked its Federal Security Directors to identify the agreement's strengths. Of the fifty who responded, seven said it had none, with answers like "none" or "I do not see any strengths with the current CBA." Most of the rest named strengths, and many did so in specific operational terms.
They named scheduling. One director wrote that shift and schedule trades give officers "the flexibility to modify their schedules and days off, even when leave is not available." Another wrote, "Shift trades are great for employee and operational flexibility."
They named standardization. One wrote that the agreement "provides a sense of uniformity and consistency across the workforce" and "promotes fairness." Another cited "the standardization of processes across all airports such as transfers, rights to representation, and shift/leave bidding."
They named accountability, and here the responses are notable, because they come from managers describing a constraint on management. One wrote that the agreement "ensures less than superior leaders are kept in check" and keeps "management in bounds with appropriate treatment of officers and their rights." Another wrote that it "adds a layer of accountability as AFGE helps monitor our performance."
On the determination's specific claim that these strengths merely restate existing policy, some managers agreed, and some directly disagreed. One wrote that the agreement added rules "for which no equivalent management directive exists." Another credited it with creating "policy/guidance for areas not addressed in TSA Policy." Those are management's own words, identifying protections the agreement created that policy did not already provide.
What Managers Said Was Not Working
The same survey asked managers for their concerns, and asked specifically about the impact of official time. On these questions, management delivered detailed and specific criticism, and an analysis that quoted only the strengths would be doing exactly what this series faults the determination for doing.
On attendance, managers were pointed. Several named the three-day self-certification provision, and more specifically the enforcement process around it. Under TSA's directive, a manager could place an officer showing excessive unscheduled absence on leave restriction with little required process. The agreement replaced that with a structured regime: a documented pattern over six months, a meeting before restriction, and review every three months. Managers felt the difference. One wrote that the agreement "does not allow management to address excessive absences unless there is a pattern." Another wrote that on three-day call-offs, "TSA policy is more enforceable."
On official time, the picture was uneven but included serious complaints. Some managers reported little or no impact, answering "none" or "minimal." Others described real operational cost and attributed it to representatives pulled from screening duties, in one case amounting to "10.5 FTE for 100% and 50% union employees." These are concrete operational concerns, and they corroborate that official time carries a cost, the subject Part Four examines in detail.
What the Survey Actually Shows
Read in full, the survey does not show a management corps that welcomed the agreement, and this analysis does not claim it does. It shows managers who identified genuine value in the agreement and genuine friction with it. That is what an honest survey of supervisors usually produces, and it is what this one produced.
The problem is not that management had no complaints. It is what the determination did with the survey it received. The determination characterized the strengths its managers identified as unsubstantiated, not the product of bargaining, or too minor to matter. That is not an accurate account of what the managers wrote. They identified concrete strengths, including protections they said have no counterpart in policy, and a large majority named at least one.
An agency is entitled to weigh a mixed record and reach a conclusion. What it is not entitled to do, under the standard a reviewing court applies, is describe a mixed record as a one-sided one. The survey the determination commissioned found strengths and weaknesses. The determination reported the weaknesses and cast the strengths as essentially not real. The record shows they were real.
Part four turns to the numbers, the official time and arbitration figures the determination uses to cast collective bargaining as a drain on resources, and how those figures were built.
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