This is the accessible text file for GAO report number GAO-04-190R 
entitled 'Federal Bureau of Investigation's Comments on Recent GAO 
Report on it Enterprise Architecture Efforts' which was released on 
November 14, 2003.

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November 14, 2003:

The Honorable Porter J. Goss:

Chairman, Permanent Select Committee on Intelligence:

House of Representatives:

The Honorable Nancy Pelosi:

House of Representatives:

The Honorable Bob Graham:

United States Senate:

The Honorable Richard C. Shelby:

United States Senate:

Subject: Federal Bureau of Investigation's Comments on Recent GAO 
Report on its Enterprise Architecture Efforts:

On September 25, 2003, we issued our report on efforts by the Federal 
Bureau of Investigation (FBI) to develop a corporate blueprint--
commonly called an enterprise architecture--to guide and constrain its 
information technology (IT) systems modernization.[Footnote 1] (This 
report is available on GAO's Web site at www.gao.gov/cgi-bin/
getrpt?GAO-03-959.) We provided the FBI with a draft of this report on 
August 22, 2003, requesting that comments be provided by September 18. 
On September 23, the FBI provided us with written comments. However, 
the comments were not received in time to be analyzed, incorporated, 
and responded to in the report and still meet our September 25, 2003, 
reporting commitment to you. As discussed with your offices at that 
time, we did not extend the reporting date in order to include the 
FBI's comments and instead are transmitting and responding to them in 
this follow-up correspondence.

In its written comments signed by the Assistant Director, Inspection 
Division (which are reprinted in their entirety in the enclosure), the 
FBI made two primary points. First, it expressed its commitment to 
developing and using an enterprise architecture (EA), including 
(1) agreeing with our conclusion that it needs an architecture to 
effectively manage its IT systems modernization; (2) consistent with 
our recommendations, stating that it recognized the need for immediate 
attention to its architecture efforts; and (3) noting that it was 
managing its architecture effort as an IT modernization enabler and 
priority.

Related to this first point, the FBI also stated that it has efforts 
currently under way to improve its EA posture, and that substantial and 
real progress has already been made in doing so. For example, it stated 
that an executive team had been established to (1) assess the bureau's 
EA status and resource needs using our EA maturity management 
framework[Footnote 2] and (2) formulate recommendations for 
improvement. Although the FBI's comments did not specify when it would 
complete the assessment, it did state that the necessary resources 
would be applied to architecture development, maintenance, and 
implementation following the results of the assessment. To illustrate 
its progress, the FBI stated that it had 
completed and approved what it referred to as an EA foundation document 
which, according to its comments, contains an architecture approach 
based on 55 principles spanning 10 categories of bureau activities and 
operations and acknowledges its largest modernization project (Trilogy) 
as one enabler for moving from its current architectural state to its 
target state; established key IT modernization management structures 
and processes, such as an investment management process that requires 
all proposed investments to address EA, a governance board to review 
investment proposals and architectural decisions, an application 
integration board to ensure that new applications are consistent with 
the bureau's IT environment, and change management and control 
entities to examine and approve changes to its IT infrastructure;

assigned EA resources, including appointing a chief architect, 
assigning staff, and obtaining private-industry expert assistance, to 
support its ongoing architecture assessment and development of 
architecture products;

established a list of existing systems that had completed security 
certification and accreditation;

begun acquiring an automated tool to serve as an architecture 
repository, as well as a risk management tool for determining existing 
system vulnerabilities and cost-effective risk mitigation steps; and:

begun conducting outreach with external parties, such as the Justice 
Department, the federal CIO Council, and its intelligence community 
partners to, among other things, learn from these entities' EA 
experiences.

We support the FBI's stated commitment to architecture development and 
use, including its adoption of our maturity framework. Moreover, we 
believe that the examples of EA-related activities cited in the 
bureau's comments, some of which were subsequent to completion of our 
audit work, are steps in the right direction. However, the examples 
that the FBI cites do not alter our report's findings and conclusions 
about the maturity of the FBI's EA program because they are either 
already recognized in our report or they do not fully address the EA 
management maturity core elements that our report cites as not being 
satisfied. Moreover, the FBI does not currently have a version of an EA 
to guide and constrain its ongoing and planned IT investments. Our 
evaluation and response to each of the FBI's examples of progress are 
provided below.

:

At the time we completed our audit work, the EA foundation document was 
in draft form, and our review of this draft showed that while it 
contained information that would be useful in developing a plan for 
architecture development, maintenance, and implementation, as well as 
information that would be useful in developing architecture artifacts 
or products, it did not satisfy the basic content requirements for 
either an EA or a plan for developing, implementing, and maintaining 
one. For example, neither the draft nor the recently approved version 
specifies the tasks, time frames, or responsible parties for actually 
developing and completing such architecture products as the business, 
information/data, services/applications, technology, and performance 
reference models, as well as the security views that should be part of 
these models.

At the time we completed our audit work, the bureau's EA governance 
board did not include all relevant internal stakeholders, such as 
representatives from its counterterrorism and counterintelligence 
organizational components. As our framework recognizes, enterprisewide 
representation and accountability on the architecture governance body 
is a critical success factor and a recognized best practice. Since we 
issued our report, FBI officials told us that they now have all 
relevant stakeholders represented on the board.

Our report recognizes that the bureau had appointed a chief architect 
and assigned staff as part of its EA efforts. However, the report also 
points out that it began these efforts over 32 months ago, and the 
level of commitment and resources devoted to them had neither advanced 
the FBI beyond stage 1 of our maturity framework nor produced an EA 
that could effectively support the investment and modernization 
management processes and structures that the FBI cited as having been 
established. Moreover, as we state in the report, the then-chief 
architect characterized the bureau's annual commitment of $1 million in 
resources to these efforts as "limited," and this amount now appears to 
be an overstatement. Specifically, the FBI stated in its comments that 
it is actually investing less than this amount in its EA efforts 
($285,000 and $500,000 in fiscal years 2003 and 2004, respectively), 
but that its fiscal year 2005 budget request includes a substantial, 
but unspecified, increase.

Despite the bureau's progress in establishing a listing of existing 
systems under security certification and accreditation, which we 
believe would be a useful source of information in developing an EA, 
the then-chief architect told us that this listing was incomplete and 
required management approval before it could serve as a basis for 
developing the "as-is" architecture description.

The bureau's comments acknowledge that it is in the process of 
acquiring automated EA tools, and thus does not yet satisfy core 
elements of our framework related to establishing an EA management 
foundation. Further, to augment these tools, the bureau has yet to 
establish a methodology that it will follow to create its architecture 
artifacts, which is another management foundation core element.

We support the efforts that the FBI cited for outreach to relevant 
external stakeholders. Understanding these relationships, and 
ultimately defining them in architecture artifacts, should be part of 
an effectively managed EA program.

The FBI's second primary comment was that our report was too narrowly 
focused and not comprehensive because it was limited to EA and did not 
include an assessment of the FBI's other IT management controls and 
capabilities. Because our report focused on EA, the bureau said that 
the report was premature.

While we agree that the report focuses on the FBI's EA activities, we 
do not agree that this is either inappropriate or makes the report 
premature. As agreed with your offices, we are in the process of 
reviewing a wide range of FBI IT management areas, such as system 
acquisition capabilities, IT human capital management, IT investment 
management practices, and architecture development and use. As further 
agreed, we are to report on these areas incrementally, as appropriate. 
Our report represents an appropriate and timely first increment for two 
principal reasons.

Our experience over the last 10 years in evaluating federal agency IT 
management has shown that providing our congressional clients and the 
subject agency's leadership team with the results of major segments of 
our work as they are available permits more timely corrective action, 
and thus better outcomes.

Reporting first on EA in particular, which can be viewed as an 
essential link between strategic planning and system investment/
implementation, provides the FBI sooner rather than later with a 
comprehensive set of recommendations for effectively making its 
architecture efforts more mature in time to influence its ongoing and 
planned IT investment/implementation efforts. Any delay on our part in 
reporting on this area of strategic importance would only increase the 
agency's exposure to modernization risk and postpone your awareness and 
understanding of this critical issue. This does not, however, mean that 
the FBI should not be pursuing near-term IT upgrades before it 
completes and is positioned to use an architecture, nor is it intended 
to suggest that the bureau's planned and ongoing modernization 
investments to date are completely unjustified and unreasonable. 
Rather, it means that these investments and upgrades are being pursued 
without a blueprint that provides an authoritative, commonly understood 
frame of reference that translates strategy into implemental actions, 
which, in turn, increases modernization risk.

We are sending copies of this correspondence to the Chairman and Vice 
Chairman of the Senate Select Committee on Intelligence and the Ranking 
Minority Member of the House Permanent Select Committee on 
Intelligence. We are also sending copies to the Attorney General; the 
Director, FBI; the Director, Office of Management and Budget; and other 
interested parties. In addition, this correspondence will be available 
without charge on GAO's Web site at www.gao.gov.

Should you or your offices have any questions on matters discussed in 
this correspondence, please contact me at (202) 512-3439 or by e-mail 
at hiter@gao.gov. Key contributors to this response included Katherine 
I. Chu-Hickman, Barbara Collier, Gregory Donnellon, Michael P. 
Fruitman, Paula A. Moore, Gary N. Mountjoy, and Megan M. Secrest.

Signed by: 

Randolph C. Hite:

Director, Information Technology Architecture and Systems Issues:

Enclosure:

U.S. Department of Justice: 
Federal Bureau of Investigation:

Washington, D.C. 20535-0001:

September 22, 2003:

Mr. Gary Mountjoy: 
Assistant Director: 
Information Technology: 
U.S. General Accounting Office:
441 G Street, N. W. Washington, DC 20548:

Dear Sir:

I would like to thank you for affording the FBI the opportunity to 
respond to the General Accounting Office (GAO) report entitled "FBI 
Needs an Enterprise Architecture to Guide its Modernization 
Activities.":

The FBI agrees with the report's conclusion that the FBI should have an 
enterprise architecture. In fact, as noted in the enclosed response, 
substantial progress has been made in establishing the FBI Enterprise 
Architecture.

However, because this report is limited in its scope, it does not 
incorporate the tremendous progress the FBI has made in the 
modernization of its Information Technology (IT) systems. Moreover, we 
suggest that this report is premature and should be a part of a 
comprehensive assessment of the FBI's IT progress, as has been the 
practice in previous GAO studies that assess IT systems.

Again, thank-you for the opportunity to respond to the report, and if 
you or your staff have any questions regarding our enclosed response, 
please contact me any time.

Sincerely yours,

Signed by: 

Steven C. McCraw: 
Assistant Director:
Inspection Division:

Comments on GAO Draft "FBI Needs an Enterprise Architecture to Guide 
its Modernization Activities":

Comment in response to "Results in Brief" (Pg. 3) and "Conclusions" 
(Pg. 20):

The FBI recognizes that several information technology management and 
technical control mechanisms, needed to most effectively guide our 
modernization efforts, are not as well developed as we need them to be. 
In February 2003, FBI executive management directed an initiative to: 
(1) consolidate FBI technology upgrade efforts into a comprehensive 
enterprise system managed and sourced by a single prime contractor; and 
(2) obtain an interim System Engineering, Integration and Test 
contractor to blend the Trilogy VCF, SCOPE and IDW projects, and 
several smaller efforts into a unified and functioning whole. The first 
element is known as Aurora and a FY2005 budget enhancement request, 
which includes very substantial funding for Enterprise Architecture 
(EA) related activities, has been prepared and is under consideration 
at DOJ and OMB at this time. Further, in April 2003, FBI executive 
management recognized the need for more immediate attention to EA and 
assigned an executive team to assess current status and formulate 
recommendations to improve our EA posture. When that assessment is 
complete the FBI will commit the necessary personnel and fiscal 
resources to correct EA shortfalls. The FBI, as mentioned elsewhere in 
the draft report, has selected the CIO Council's "Federal Enterprise 
Architecture Framework" as the basis for defining the FBI EA. The FBI 
acknowledges the validity of the GAO EA Management Maturity Framework 
and is using the GAO framework as part of its internal assessment. FBI 
executive management has determined to treat EA as an IT modernization 
priority and to manage EA as such.

While the assessment of FBI EA is still underway, real progress has 
already been achieved as follows:

EA Foundation Document:

* An FBI Enterprise Architecture "Foundation Document" has been 
completed and approved. The Document bases its EA approach on 55 
principles in 10 categories of FBI activities or operations. These 
reflect the Director's 10 Priorities through three mission areas 
and several prescribed functions of the FBI's information 
enterprise. This document acknowledges the de facto Trilogy 
Architecture as one of the infrastructure enablers from the "As-Is" to 
the "To-Be" FBI IT environments.

Boards and Processes:

* An Investment Management Process (IMP) has been established in the 
FBI consistent with the Clinger-Cohen Act to ensure IT and other 
investments are aligned to meet mission needs and priorities. A 
Business Plan template requires all investments to address 10 areas 
including Enterprise Architecture. The IMP ensures management of 
investments during the Select, Control and Evaluate phases.

* An FBI wide Enterprise Architecture Board (EAB) has been established, 
comprised of FBI executives in Senior Executive Service (SES) and the 
Senior Level (SL) positions, and is already reviewing architecture 
decisions. This Board reviews IT proposals to ensure that they are 
consistent with the de facto Trilogy Architecture, Standards and the 
new emerging EA Vision as delineated in the EA Foundation Document.

* In March 2003, the FBI Information Resources Division (IRD) initiated 
an interim Change Management Process that includes an Executive Change 
Management Board (CMB) and a Technical Change Control Board (TCCB), 
both of which are comprised of qualified executives, senior level and 
management staff at GS-15 level with sufficient experience and 
expertise. These boards regularly record, track, and approve all 
changes to the IT Operational infrastructure (networks, systems, 
applications, and computing).

* IRD has initiated an Application Integration Board to ensure all new 
Applications are consistent with FBI's IT environment.

* Resources:

* A Chief Architect has been appointed, with staff provided on a 
matrixed basis while the assessment is ongoing.

* Expert assistance from private industry has been obtained and is 
supporting the assessment and will be developing elements of the 
architecture.

List of Systems:

* A definitive list of current FBI systems under Certification and 
Accreditation (C&A) has been established for the Sensitive-But-
Unclassified, Classified Secret and Classified Top Secret Enclaves.

Tools:

* A commercial tool (Popkin) for managing EA is in process of being 
purchased. This tool is exactly the same as the one used by the 
Department of Justice (DOJ). The tool will first be populated with the 
current "As-Is" systems baseline information and will rely on 
Configuration Management (CM) Information from the Trilogy-provided 
Enterprise Management Systems and new CM tools.

* The FBI is in process of acquiring a Risk Management Tool that has 
been successfully deployed in the IC (e.g. National Security Agency). 
This tool will assist the FBI in determining where IT vulnerabilities 
should be mitigated through risk/cost trade-offs, thereby ensuring IT 
Continuity of Operations (COOP). The FBI will interface this tool with 
the EA Tool.

External Efforts:

* The FBI is actively participating in the DOJ architecture effort.

* The FBI has met with members of the Chief Information Officer (CIO) 
Council's Architecture Integration Committee to understand the 
requirements of the Federal Enterprise Architecture Reference Model.

* The FBI has actively participated with the IC partners to determine 
status of their EA efforts and lessons learned in implementation of EA. 
This will assist the FBI in our Information Sharing efforts with the IC 
and also assist the FBI in determining the resources and processes 
required to tailor the FBI's EA effort. For example, the FBI is a 
voting member of the IC-CIO Communications Board, Intelligence 
Implementation Board (IIB) and keeps abreast of IC architecture 
efforts.

Comment in Response to "Recommendations" (Pg. 21):

The FBI will designate EA as an IT modernization enabler and will 
manage it as such. FBI executive management assigned an executive team, 
in April 2003, to assess current EA status and formulate 
recommendations to improve our EA posture. When this assessment is 
complete the necessary personnel and fiscal resources will be applied 
and the FBI EA will be implemented in a manner consistent with the GAO 
EA Management Maturity Framework.

GAO Comment: Page 7 - "Department of Justice Inspector General reported 
that, as of September 2000, the FBI had over 13,000 desktop computers 
that were 4 to 8 years old and could not run basic software packages. 
Moreover, it reported that some communications networks were 12 years 
old and were obsolete.":

FBI Response: It should be noted that under the Trilogy program the FBI 
has successfully deployed over 20,000 new desktop computers and 
peripherals which have been upgraded to current Industry standards, 
reused more than 7,500 older desktops, replaced the obsolete 
communications networks with Industry-standard, robust Local and Wide 
Area Networks with redundancy and standard NSA-approved secure 
encryption.

The enterprise servers and operating systems will be upgraded in fiscal 
year 2004. Enterprise Mainframes have been upgraded to requisite 
computing capacity. Therefore, the major deficiencies cited in the 
classified IT infrastructure are no longer a problem for the FBI.

Although, several older applications have already been web-enabled, the 
five most significant investigative and counterterrorism applications 
are nearing replacement under the auspices of the Trilogy Program. 
Migration of the remaining applications will require further effort and 
funding. The problems cited were very significant, but they no longer 
represent the FBI's "Existing IT Environment" from a networking and 
computing perspective.

GAO Comment: Page 13 - "They added that they are currently in the 
process of developing an inventory of the FBI's existing (legacy) 
systems.":

FBI Response: The inventory of legacy systems has been completed and is 
now part of the basis for managing the FBI C&A program. This inventory 
will be entered into the recently purchased Popkin EA management tool 
as part of the current systems baseline information.

GAO Comment: Page 13 - "resources allocated to this effort have been 
limited to about $1 million annually and four staff.":

FBI Response: The FBI has not committed $1 million annually to EA. 
During FY2003 the FBI has devoted approximately $285,000 to EA. Base 
funding of $500,000 has been identified that can be applied to EA 
during FY2004. An executive assessment of EA status and needs is 
underway after which the necessary FY2004 funding will be determined 
and identified. Substantial EA funding, of approximately $6.5 million, 
that addresses EA, technical planning and systems engineering issues 
has been requested for FY2005 as part of the Aurora budget enhancement 
request. Substantial EA funding requests are also projected for FY2006 
and for a steady-state commencing in FY2007. The dedicated architecture 
staff was previously at four. While the FBI is assessing EA needs, a 
matrixed staff is being provided to the Chief Architect.

GAO Comment: Page 15 - "Establish an architecture steering committee 
representing the enterprise and make the committee responsible for 
directing, overseeing, or approving the EA.":

FBI Response: During April 2003, FBI management assigned an executive 
team to address EA. An FBI wide EAB has been established, comprised of 
FBI executives in SES and the SL positions, and is already reviewing 
architecture decisions. The EAB charter and Policy has been prepared 
and is nearing approval by the Deputy Director and will be promulgated 
throughout the enterprise.

GAO Comment: Page 15 - "Appoint a chief architect who is responsible 
and accountable for the EA, and who is supported by the EA program 
office and overseen by the architecture steering committee.":

FBI Response: A chief architect has been appointed. The chief architect 
currently reports directly to the chair of the EAB. Appropriate 
staffing and other resources to support the chief architect have not 
yet been determined.

Staff is currently being provided on a matrixed basis. The charter for 
the chief architect and staff has not yet been prepared.

GAO Comment: Page 15 - "Use an architecture development framework, 
methodology, and automated tool to develop and maintain the EA.":

FBI Response: An FBI Enterprise Architecture "Foundation Document" has 
been completed and approved. The FBI has selected the CIO Council's 
"Federal Enterprise Architecture Framework" as the basis for defining 
the FBI EA. The Popkin automated tool has recently been purchased. The 
methodology for EA development has not yet been selected.

(310268):

FOOTNOTES

[1] U.S. General Accounting Office, Information Technology: FBI Needs 
an Enterprise Architecture to Guide Its Modernization Activities, GAO-
03-959 (Washington, D.C.: Sept. 25, 2003).

[2] U.S. General Accounting Office, Information Technology: A Framework 
for Assessing and Improving Enterprise Architecture Management (Version 
1.1), GAO-03-584G (Washington, D.C.: April 2003).