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U.S. Department of Homeland Security

Transportation Transportation Security Administration
Security Office of Chief Counsel
Administration 3838 N Sam Houston Pkwy E, Suite 510
Houston, Texas 77032

July 16,2009
Evelyn Njuguna
Assistant City Attorney
City of Houston
Legal Department
PO Box 1562
Houston, TX 77251-1562

Re: Texas Public Information request dated May 26, 2009, from Jennifer
Peoples, for "records indicating how much the Houston Airport System
paid all of its employees between Jan. 1, 2009, and Dec. 21, 2008. These
records should indicate the employees name, the amount of their pay,
their job title or classification and the unit, division or office of the airport
system for which they work."

Dear Ms. Njuguna:

This is in response to your letter, dated June 16, 2009, which requests that the
Transportation Security Administration (TSA) make a determination on the disclosure of
the above referenced records. Included with your correspondence is a representative
sample of the responsive list of information that contains the names, position title and
wages of Houston Airport System (HAS) employees. You note that the responsive
records may constitute Sensitive Security Information (SSI) that must be protected from
unauthorized public disclosure under 49 C.F.R. Part 1520.

On July 2, 2009, we also received a letter in connection with this request from Ms.
Jennifer Peebles of Texas Watchdog. Her tetter sets forth a number of arguments on
why the referenced requested information should not be deemed SSI.

As you know, generally, SSI is information obtained or developed in the conduct of

security activities, including research and development, the disclosure of which TSA has
determined would be detrimental to the security of transportation, reveal trade secrets
or privileged or confidential information, or would constitute an unwarranted invasion of
privacy. More specifically, under 49 C.F.R. § 1520.5(b)(11), SSI includes identifying
information of certain transportation security personnel.

While subsection (A) of 1520.5(b)(11) includes list of the names of persons having
unescorted access to a secure area of an airport or a secure or restricted area of a
maritime facility, port area or vessel, neither the information request nor the City's
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responsive list includes the disclosure of such information. Additionally, unescorted

access information, as it relates to HAS employees, is not public information or
otherwise widely known.

Accordingly, after careful consideration and consultation with our SSI Headquarters
Office, the TSA has determined that the responsive record to the referenced information
request, which consists of a list of HAS employee names, along with job title and pay
does not constitute SSI and therefore may be disclosed.

If you have any questions, please feel free to contact me at (281) 848-2945.

Sincerely,

Dysrtn Whittaker
Supervisory Attorney-Advisor

www.tsa-gov