United States Government Accountability Office

GAO Testimony before the Subcommittee on 

Homeland Security, Committee on 

Appropriations, House of Representatives

SECURE BORDER 

INITIATIVE 

SBInet Planning and 

Management Improvements 

Needed to Control Risks 

Statement of 

Richard M. Stana, Director 

Homeland Security and Justice Issues 

Randolph C. Hite, Director 

Information Technology Architecture and Systems Issues 

For Release on Delivery

Expected at 3:00 p.m. EST 

Tuesday, February 27, 2007 

 

GAO-07-504T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-07-504T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Rich Stana at 

(202) 512-8816 or stanar@gao.gov, or Randy 

Hite at (202) 512-3439 or hiter@gao.gov. 

Highlights of GAO-07-504T, a testimony 

before the Subcommittee on Homeland 

Security, Committee on Appropriations, 

House of Representatives 

February 27, 2007

SECURE BORDER INITIATIVE 

SBInet Planning and Management 

Improvements Needed to Control Risks 

SBInet’s December 2006 expenditure plan offered a high-level and partial 

outline of a large and complex program that forms an integral component of 

the broader multiyear initiative. However, the SBInet expenditure plan, 

including related documentation and program officials’ statements, lacked 

specificity on such things as planned activities and milestones, anticipated 

costs and staffing levels, and expected mission outcomes. This, coupled with 

the large cost and ambitious time frames, adds risk to the program. Without 

sufficient and reliable information on program goals, status and results, 

Congress and DHS are not in the best position to use the plan as a basis for 

assessing program outcomes, accounting for the use of current and future 

appropriations, and holding program managers accountable for achieving 

effective control of the border. 

As of December 2006, SBInet was using, at least to some extent acquisition 

best practices, but DHS had not fully established the range of capabilities 

needed to effectively mitigate risks and to successfully manage the program. 

To its credit, the SBInet contract was generally competed in accordance 

with federal requirements. However, the SBInet contract does not fully 

satisfy the federal regulatory requirement to specify a maximum dollar value 

or the number of units that may be ordered. We also reported that important 

management controls provided for in Office of Management and Budget 

(OMB) guidance and best practices were not yet in place, although the 

program manager stated that he was committed to doing so. Until they are in 

place, the program is at increased risk of failure. 

DHS’s plan to execute SBInet activities through a series of concurrent task 

orders introduces additional risk. With multiple related and dependent 

projects being undertaken simultaneously, SBInet is exposed to possible 

cost and schedule overruns and performance problems. Without assessing 

this level of concurrency and how it affects project implementation, SBInet

runs the risk of not delivering promised capabilities and benefits on time and 

within budget. SBI and SBInet officials told us that they understand the risks 

inherent in concurrency and are addressing these risks. However, as of 

December 2006, they had not provided evidence that identified the 

dependencies among their concurrent activities and that they were 

proactively managing the associated risk. 

This testimony summarizes GAO’s 

February 2007 report on SBInet, 

one element of the Department of 

Homeland Security’s (DHS) Secure 

Border Initiative (SBI). SBInet is 

responsible for developing a 

comprehensive border protection 

system. By legislative mandate, 

GAO reviewed SBInet’s fiscal year 

2007 expenditure plan. This 

testimony focuses on (1) the extent 

that the plan provided explicit and 

measurable commitments relative 

to schedule and costs, (2) how DHS 

is following federal acquisition 

regulations and management best 

practices, and (3) concurrency in 

SBInet’s schedule. GAO assessed 

the plan against federal guidelines 

and industry standards and 

interviewed program officials. 

What GAO Recommends

GAO recommended that DHS 

(1) ensure that future expenditure 

plans include explicit and 

measurable commitments relative 

to the capabilities, schedule, costs, 

and benefits associated with 

individual SBInet program 

activities; (2) modify the SBInet

contract to include a maximum 

quantity or dollar value; and 

(3) re-examine the level of 

concurrency and appropriately 

adjust the acquisition strategy. DHS 

concurred with the first and third 

recommendations, but not the 

second. DHS stated that the 

contract already contains a 

maximum quantity. GAO disagrees 

and believes DHS needs to modify 

the contract to ensure that it is 

consistent with regulations. 
United States Government Accountability Office

Washington, DC 20548 

 

Mr. Chairman and Members of the Subcommittee: 

We are pleased to be here today to discuss the Secure Border Initiative’s 

SBInet program’s planning and management challenges. 

In November 2005, the Department of Homeland Security (DHS) 

established the Secure Border Initiative (SBI), a multiyear, multibillion 

dollar program aimed at securing U.S. borders and reducing illegal 

immigration. One element of SBI is SBInet, the program responsible for 

developing a comprehensive border protection system. DHS estimates that 

the total cost for completing the acquisition phase for the southwest 

border is $7.6 billion from fiscal years 2007 through 2011. Of this total, 

approximately $5.1 billion is for the design, development, integration, and 

deployment of fencing, roads, vehicle barriers, sensors, radar units, and 

command, control, and communications and other equipment, and 

$2.5 billion is for integrated logistics and operations support during the 

acquisition phase for the southwest border. According to DHS, work on 

the northern border is not projected to begin before fiscal year 2009. 

The Department of Homeland Security Appropriations Act, 2007, required 

DHS to submit to Congress an expenditure plan to establish a security 

barrier along the border of the United States composed of fencing and 

vehicle barriers and other forms of tactical infrastructure and technology.1

This plan was to address nine legislative conditions and was submitted to 

Congress on December 4, 2006. As required by the act, we reviewed the 

expenditure plan, and found that the plan, including related

documentation and program officials’ statements, satisfied four legislative 

conditions, partially satisfied four legislative conditions, and did not 

satisfy one legislative condition.2

 See appendix I for a summary of the 

legislative conditions and to what extent they were satisfied. 

The legislatively mandated expenditure plan for SBInet is a congressional 

oversight mechanism aimed at ensuring that planned expenditures are 

 1

Pub. L. No. 109-295, 120 Stat. 1355, 1359-60. The Appropriations Act required that the

expenditure plan be submitted within 60 days after the enactment of the act. 

2

On December 7 and December 13, 2006, we briefed the House and Senate Appropriations 

Subcommittees staff, respectively, on the results of our work. In February 2007, we issued 

a report on our work. See GAO, Secure Border Initiative: SBInet Expenditure Plan Needs 

to Better Support Oversight and Accountability, GAO-07-309 (Washington, D.C.: Feb. 15, 

2007). 

Page 1 GAO-07-504T 
justified, performance against plans is measured, and accountability for 

results is ensured. Although the program is in its early stages, a 

comprehensive expenditure plan is intended to provide Congress with the 

information needed to effectively oversee the program and hold DHS 

accountable for program results. Effective program planning and 

execution require a range of management controls. These controls, which 

are carved out in federal requirements and best practices, are instrumental 

in minimizing a program’s exposure to cost, schedule, and performance 

risks. Without adequate management controls, there is increased risk that 

SBInet will not produce the right solution, not be managed the right way, 

and not be implemented within cost estimates. 

Our testimony today is based on our recent report for the House and 

Senate Appropriations Committees on the fiscal year 2007 SBInet

expenditure plan. It focuses on the following issues: 

• the extent to which the expenditure plan and related documentation 

provided explicit and measurable commitments relative to schedule 

and costs, 

• how DHS defined and is following federal acquisition requirements and 

program management best practices, and 

• the concurrency in SBInet’s program schedule. 

To accomplish our objectives, we analyzed the SBInet December 2006 

expenditure plan and supporting documentation. We also interviewed 

cognizant program officials and contractors. We did not review the 

justification for cost estimates included in the expenditure plan. We 

conducted our work at DHS’s U.S. Customs and Border Protection (CBP) 

headquarters in the Washington, D.C., metropolitan area from October 

2006 through December 2006, in accordance with generally accepted

government auditing standards. 

SBInet’s December 2006 expenditure plan offered a high-level and partial 

outline of a large and complex program that is to form an integral 

component of the broader multiyear initiative. However, the SBInet

expenditure plan, including related documentation and program officials’ 

statements, lacked specificity on such key things as planned activities and 

milestones, anticipated costs and staffing levels, and expected mission 

outcomes. This, coupled with the large cost and ambitious time frames, 

adds considerable risk to the program. Without sufficient and reliable 

Summary 

Page 2 GAO-07-504T 
information on program goals, status and results, Congress and DHS are 

not in the best position to use the plan as a basis for assessing program 

outcomes, accounting for the use of current and future appropriations, 

and holding program managers accountable for achieving effective control 

of the border. 

As of December 2006, SBInet was using, at least to some extent acquisition 

best practices, but DHS had not fully established the range of capabilities 

needed to effectively mitigate risks and to successfully manage the 

program, as defined by federal acquisition requirements and associated 

best practices, and in legislative requirements relative to the Office of 

Management and Budget (OMB) Circular A-11 guidance. The SBInet

contract was generally competed in accordance with federal requirements; 

however, the contract does not fully satisfy the federal regulatory 

requirement to specify a maximum dollar value or the number of units that 

may be ordered. We also reported that important management controls 

provided for in OMB guidance and best practices were not yet in place, 

although the program manager stated that he was committed to doing so. 

Until they are in place, the program is at increased risk of failure. 

DHS’s plan to execute SBInet activities through a series of concurrent task 

orders introduces additional risk. With multiple related and dependent 

projects being undertaken simultaneously, SBInet is exposed to possible 

cost and schedule overruns and performance problems. Without assessing

this level of concurrency and how it affects project implementation, 

SBInet runs the risk of not delivering promised capabilities and benefits on 

time and within budget. SBI and SBInet officials told us that they 

understand the risks inherent in concurrency and are addressing them. 

However, as of December 2006, they had not provided evidence that 

identified the dependencies among their concurrent activities and that 

they were proactively managing the associated risk. 

We made three recommendations to help ensure that Congress has the 

information necessary to effectively oversee SBInet and hold DHS 

accountable for program results, and to help DHS manage the SBInet

program and ensure that future SBInet expenditure plans meet the 

legislative requirements. Specifically, we recommended that DHS 

(1) ensure that future expenditure plans include explicit and measurable 

commitments relative to the capabilities, schedule, costs, and benefits 

associated with individual SBInet program activities; (2) modify the SBInet

systems integration contract to include a maximum quantity or dollar 

value; and (3) re-examine the level of concurrency and appropriately 

adjust the acquisition strategy. DHS concurred with the first and third 

Page 3 GAO-07-504T 
recommendations, but not the second. DHS stated that the contract 

language discussed above is sufficient to meet regulation requirements. 

We disagree and believe DHS needs to modify the contract to ensure that 

it is consistent with regulations. 

SBI is a comprehensive, multiyear, multibillion dollar program established 

in November 2005 by the Secretary of Homeland Security to secure U.S. 

borders and reduce illegal immigration. SBI’s mission is to promote border 

security strategies that help protect against and prevent terrorist attacks 

and other transnational crimes. Elements of SBI will be carried out by 

several organizations within DHS. One element of SBI is SBInet, the 

program within CBP that is responsible for developing a comprehensive 

border protection system. The SBInet program is managed by the SBInet

Program Management Office (PMO). The PMO reports to the CBP SBI 

Program Executive Director. 

Background 

SBInet is a large and complex program that is responsible for leading the 

effort to ensure that the proper mix of personnel, tactical infrastructure, 

rapid response capability, and technology is deployed along the border. 

DHS defines control of the U.S. border as the ability to detect illegal 

entries into the United States, identify and classify these entries to 

determine the level of threat involved, efficiently and effectively respond 

to these entries, and bring events to a satisfactory law enforcement 

resolution. SBInet’s initial focus will be on the southwest border 

investments and areas between ports of entry that CBP has designated as 

having the highest need for enhanced border security due to serious 

vulnerabilities. 

In September 2006, CBP awarded an indefinite delivery/indefinite quantity

systems integration contract for 3 years, with three additional 1-year 

options. The minimum dollar amount is $2 million; the maximum is stated 

as “the full panoply of supplies and services to provide 6,000 miles of 

secure U.S. border.” According to DHS, the SBInet solution is to include a 

variety of sensors, communications systems, information technology, 

tactical infrastructure (roads, barriers, and fencing), and command and 

control capabilities to enhance situational awareness of the responding 

officers. The solution is also to include the development of a common 

operating picture that provides uniform data, through a command center

environment, to all DHS agencies and is interoperable with stakeholders 

external to DHS. See figure 1 for examples of existing technology along 

the border. 

Page 4 GAO-07-504T 
Figure 1: Existing Technology along the Border

Source: CBP.

Our statement will now focus on what type of information DHS has 

provided on explicit and measurable commitments relative to schedule 

and costs. 

SBInet

Documentation 

Includes General 

Program Information 

but Lacks Detailed 

Implementation Plans 

The SBInet expenditure plan included general cost information for 

proposed activities and some associated milestone information. DHS 

estimates that the total cost for completing the acquisition phase for the 

southwest border is $7.6 billion for fiscal years 2007 through 2011. Of this 

total, approximately $5.1 billion is for the design, development, 

integration, and deployment of fencing, roads, vehicle barriers, sensors, 

radar units, and command, control, and communications and other 

equipment, and $2.5 billion is for integrated logistics and operations 

support during the acquisition phase for the southwest border. In addition, 

Page 5 GAO-07-504T 
the SBInet expenditure plan and related documentation discussed 

generally how approximately $1.5 billion already appropriated will be 

allocated to SBInet activities (see table 1). For example, about 

$790 million is allocated for the Tucson Border Patrol sector and 

$260 million for the Yuma sector in Arizona.3

 

Table: 1 SBInet Funding Allocations Fiscal Years, 2005-2007 (dollars in thousands)

Activity 2005

2006 

supplemental

a

2007 Total

Management task order $36,800 $13,066 $49,866

Project 28 $20,000 20,000

Common operating picture 100,000 100,000

Tucson sector 60,000 729,359 789,359

Yuma sector 204,609 55,075 259,684

Yuma and Tucson tactical 

infrastructure 

24,391 24,391

Tactical infrastructure western Arizona 57,823 57,823

Texas mobile system 20,000 20,000

San Diego fence 30,500 30,500

Advanced technology development 10,000 10,000

Systems engineering support 6,000 6,000 12,000

Program Management Office support 55,000 55,000

Environmental requirements 61,000 61,000

Otherb 59,742 59,742

Total $36,800 $325,000 $1,187,565 $1,549,365

Source: GAO analysis of SBInet December 2006 Expenditure Plan. 

a

According to DHS officials, no fiscal year 2006 funds were allocated to SBInet activities. 

b

Other includes activities related to test and evaluation, deployment and installation, and integrated 

logistics support.

The expenditure plan also includes certain milestones, such as starting 

and ending dates, for some but not all activities. For example, consistent 

with DHS’s task order approach to managing SBInet’s implementation, the 

 3

The U.S. Border Patrol has 20 sectors responsible for detecting, interdicting, and 

apprehending those who attempt to illegally enter or smuggle people, including terrorists, 

or contraband, including weapons of mass destruction, across U.S. borders between 

official ports of entry. 

Page 6 GAO-07-504T 
task order for Project 28 includes detailed milestones.4

 In other cases, such

as the Tucson and Yuma sector activities, milestones and costs are 

preliminary and highly likely to change because they are still in the 

planning and requirement setting stage. According to SBInet officials, 

factors such as technological, environmental, and eminent domain 

constraints can affect the timetables and costs of these activities. Figure 2

illustrates the extent to which milestones were defined for selected 

activities. 

Figure 2: Timeline by Selected Project, as of December 2006 

Startup phase

Barry M. Goldwater range

Initial operational capability

Preliminary design review

BMGR

IOC

PDR

Awarded October 2006 IOC complete June 2007

IOC complete September 2007

IOC Mobile IOC fixed October 2008

IOC mobile IOC fixed October 2008

February 2008

BMGR IOC

October 2007

Start January 2007

Start January 2007

Start January 2007

Start March 2007

Southwest border installations December 2008

Spiral delivery 2, June 2008

Spiral delivery 1, December 2007

PDR April 2007

O ND J F MA MJ J A S O ND J F MA MJ J A O ND J F M A S

Project 28

Task Name

Texas mobile

system

Tucson

sector

Yuma

(includes BMGR)

Common

operating

picture

(COP)

2006 2007 2008 2009

Source: SBInet supporting documentation.

Despite including general cost information for proposed activities and 

some associated milestone information, the expenditure plan and related

documentation did not include sufficient details about what will be done, 

the milestones involved, the performance capability expected, and the

 4

Project 28 is an effort across 28 miles of the Tucson sector that will deploy SBInet tactics. 

Page 7 GAO-07-504T 
costs for implementing the program. For example, although the plan stated

that about $790 million will be spent in the Tucson sector for such 

elements as fencing, ground sensors, radars, cameras, and fixed and 

mobile towers, the plan did not specify how the funds will be allocated by 

element and did not provide specific dates for implementation. According

to DHS, each task order will define what will be done, when, the 

performance capability, and the total cost. 

The expenditure plan did not include costs incurred to date mainly 

because SBInet activities are in the early stages of implementation and 

costs had not yet been captured by DHS’s accounting system (e.g., the 

SBInet systems integration contract was awarded in September 2006 and

the first two task orders were awarded in September and October 2006). 

Moreover, the expenditure plan did not include a baseline measure of 

miles under control of the border.5

 While the plan did not discuss progress 

made to date by the program to obtain control of the border, related 

program documents, such as the bimonthly SBI reports to Congress, 

included information on the number of miles under control in the 

southwest border.6

 

Our statement will now focus on DHS’s use of federal acquisition 

requirements and related program management best practices. 

As of December 2006, SBInet was using several acquisition best practices. 

The extent to which these practices were in use varied, and outcomes 

were dependent on successful implementation. Specifically, SBInet was 

using several of the best practices or “Guiding Principles” in DHS 

Management Directive 1400, such as conducting a competition open to all

qualified suppliers to award the systems integration contract, and using a 

performance-based approach where the agency identified the outcome it 

was seeking to achieve and allowed the competing companies to propose 

their specific solutions. SBInet plans to use a system for comparing costs 

incurred with progress achieved known as earned value management 

(EVM). 

SBInet Has Followed 

Some but Not All 

Federal Acquisition 

Requirements and 

Related Best 

Practices 

 5

DHS defines control of U.S. borders as the ability to: detect illegal entries, identify and 

classify entries and determine their respective level of threat, efficiently and effectively 

respond, and bring events to a satisfactory law enforcement action. 

6

According to the November 2006 bimonthly report, as of August 2006, 284 miles of the 

southwest border were under control. 

Page 8 GAO-07-504T 
However, we reported that the SBInet systems integration contract did 

fully satisfy an acquisition requirement to contain a specific number of 

units that may be ordered or a maximum dollar value. According to the 

Federal Acquisition Regulation (FAR), an agency may use an indefinite 

delivery/indefinite quantity contract, such as that used for SBInet, when it 

is not possible to determine in advance the precise quantities of goods or 

services that may be required during performance of the contract. Though

these types of contracts are indefinite, they are not open-ended. The FAR

requires that indefinite quantity contracts contain a limit on the supplies or 

services that may be ordered, stated in terms of either units or dollars. 

This limit serves a variety of purposes, including establishing the 

maximum financial obligation of the parties. According to DHS, the 

quantity stated in the contract, “6,000 miles of secure U.S. border,” is 

measurable and is therefore the most appropriate approach to defining the 

contract ceiling. We do not agree because the contract maximum used in 

the SBInet contract, “the full panoply of supplies and services to provide 

6,000 miles of secure U.S. border,” does not allow anyone to calculate with 

certainty what the maximum financial obligation of the parties might turn 

out to be since the contract does not make clear the total amount of 

supplies or services that would be required to secure even 1 mile of U.S. 

border. In order to ensure that the contract is consistent with the FAR 

requirement, a maximum quantity or dollar value limit needs to be 

included in the contract.

Managing major programs like SBInet also requires applying discipline and 

rigor when acquiring and accounting for systems and services, such as 

those requirements and practices embodied in OMB and related guidance. 

Our work and other best practice research have shown that applying such

rigorous management practices improves the likelihood of delivering 

expected capabilities on time and within budget. In other words, the 

quality of information technology (IT) systems and services is largely 

governed by the quality of the management processes involved in 

acquiring and managing them. Some of these processes and practices are 

embodied in the Software Engineering Institute’s (SEI) Capability Maturity 

Models®

, which define, among other things, acquisition process 

management controls that, if implemented effectively, can greatly increase

the chances of acquiring systems that provide promised capabilities on 

time and within budget. Other practices are captured in OMB guidance, 

which establishes requirements for planning, budgeting, acquisition, and 

management of federal capital assets. 

As of December 2006, the SBInet program office had not fully defined and

implemented critical acquisition processes, such as project planning, 

Page 9 GAO-07-504T 
process and product quality assurance, measurement and analysis, and 

requirements management.7

 To its credit, the program office has 

developed and begun implementing a draft risk management plan, dated

September 29, 2006. The draft plan addresses, among other things, a 

process for identifying, analyzing, mitigating, tracking, and controlling 

risks. As part of this process, the program office developed a risk 

management database that identifies for each risk, among other things, the 

status, priority, probability of occurrence, the overall impact,

consequence, and a mitigation strategy. The program office also 

established a governance structure, which includes a Risk Review Board 

(RRB) that is chaired by the SBInet Program Manager. According to the 

SBInet Risk Manager, a draft RRB charter has been developed. 

SBInet had not yet implemented other key management practices, such as

developing and implementing a system security plan, employing an EVM 

system to help manage and control program cost and schedule, and 

following capital planning and investment control review requirements to 

help ensure that agencies investments achieve a maximum return on 

investment. According to a SBInet program office security specialist, as of

December 2006, the program office had not developed a system security 

plan because it was too early in the system development life cycle. He 

stated that a plan is to be developed as part of the system certification and

accreditation process. Regarding EVM, the program office is relying on the 

prime integrator’s EVM system to manage the prime contractor’s progress 

against cost and schedule goals. The prime integrator’s system has been 

independently certified as meeting established standards. However, the

EVM system had not been fully implemented because, as of December 

2006, the baselines against which progress can be measured for the two 

task orders that had been issued, as of early December (program 

management and Project 28) had not yet been established. According to 

program officials, these baselines were to be established for the program 

management task order and the Project 28 task order in mid-December 

2006 and mid-January 2007, respectively. Further, it is unclear where 

SBInet is in the DHS capital planning and investment control review 

 7

Project planning processes help to establish and maintain plans and define project 

activities. Process and product quality assurance processes provide staff and management

with objective insight into processes and associated work products. Measurement and 

analysis processes are used to develop and sustain a measurement capability that is used to

support management information needs. Requirements management processes are used to

manage the requirements of the project’s products and product components and to identify 

inconsistencies between those requirements and the project’s plans and work products. 

Page 10 GAO-07-504T 
process. The SBInet expenditure plan did not describe the status of the 

program in the review process, but indicated that it is being managed

using the DHS framework. However, a SBInet DHS Joint Requirements 

Council and Investment Review Board briefing document for fiscal year 

2007, dated November 22, 2006, indicates that the program office plans to

implement the review process on an annual basis. According to the SBInet

Program Manager, SBInet projects are at various stages in the acquisition 

life cycle. As a result, the program office plans to combine multiple 

projects into a single decision milestone for purposes of investment review 

that is to occur on, at least, an annual basis. 

According to the SBInet Program Manager, the program had not fully 

defined and implemented critical management practices because priority 

was given to meeting an accelerated program implementation schedule. 

However, he stated that he was committed to putting these processes in 

place and further stated that the program plans to develop a plan for 

defining and implementing critical acquisition planning processes by the 

spring of 2007. Until the program office fully defines and implements these 

key program management practices, its efforts to acquire, deploy, operate,

and maintain program capabilities will be at a higher risk of not producing 

promised performance levels and associated benefits on time and within 

budget. 

The SBInet PMO plans to execute SBInet activities through a series of 

concurrent task orders that will be managed by a mix of government and 

contractor staff. The PMO plans to nearly triple its current workforce, 

from about 100 to 270 personnel, by September 2007 in order to support 

and oversee this series of concurrent task orders. As of December 2006, 

SBInet personnel included 38 government employees and 60 contractor 

staff. By September 2007, personnel levels are projected to reach 

113 government employees and 157 contractors. As of December 2006, 

SBInet officials told us that they have assigned lead staff for the task 

orders that have been awarded. However, SBI and SBInet officials 

expressed concerns about difficulties in finding an adequate number of 

staff with the required expertise to support planned activities. Staffing 

shortfalls could limit government oversight efforts. 

SBInet’s Acquisition 

Approach Calls for 

Considerable

Concurrency that 

Introduces Additional 

Risk 

As shown in figure 2, SBInet’s acquisition approach calls for considerable

concurrency among related planned tasks and activities. For example, 

according to DHS, lessons learned from the Project 28 task order are to be 

incorporated in the sector task orders. However, the task orders for the 

other sectors will be awarded prior to the completion and evaluation of 

Page 11 GAO-07-504T 
Project 28. The program management task order is also to establish the 

capabilities to manage and oversee all of the other task orders. The risk of 

concurrency is further increased because, as discussed earlier, DHS does 

not have all the management processes in place to mitigate the risk and 

successfully manage the program. The greater the degree of concurrency 

among related and dependent program tasks and activities, the greater a 

program’s exposure to cost, schedule, and performance risks. SBI and 

SBInet officials told us that they understand the risks inherent in 

concurrency and are addressing these risks. However, as of December 

2006, they had not provided evidence that identified the dependencies 

among their concurrent activities and that they were proactively managing 

the associated risk. 

The legislatively mandated expenditure plan for SBInet is a congressional 

oversight mechanism aimed at ensuring that planned expenditures are 

justified, performance against plans is measured, and accountability for 

results is ensured. We found that Congress and DHS are not in the best 

position to use the plan as a basis for measuring program success, 

accounting for the use of current and future appropriations, and holding 

program managers accountable for achieving effective control of the 

southwest border because the plan has not provided information on 

explicit and measurable commitments relative to the capabilities, 

schedule, costs, and benefits associated with individual SBInet program 

activities. Specifically, DHS needs to provide sufficient details on such 

things as planned activities and milestones, anticipated costs and staffing 

levels, and expected mission outcomes. DHS also needs to document that 

planned SBInet expenditures are justified, performance against plans is 

measured, and accountability for results is ensured. We recommended that 

DHS ensure that future expenditure plans include explicit and measurable 

commitments relative to the capabilities, schedule, costs, and benefits 

associated with individual SBInet program activities. 

Conclusions, 

Recommendations for 

Executive Action, and 

Agency Response 

DHS has not fully established the capabilities needed to effectively 

mitigate risks and to successfully manage the program. We reported that 

although the SBInet contract was generally competed in accordance with 

federal requirements, the contract does not fully satisfy federal 

regulations. Under the FAR, indefinite quantity contracts such as the 

SBInet contract must contain the specific number of units that may be 

ordered or a maximum dollar value. However, the SBInet contract merely 

contains the maximum number of miles to be secured. While SBInet

officials consider this sufficient to satisfy the FAR requirement, a 

maximum quantity expressed in units other than the overall outcome to be 

Page 12 GAO-07-504T 
achieved or expressed as a dollar value limit would help ensure that the 

contract is consistent with this requirement. We recommended that DHS 

modify the SBInet systems integration contract to include a maximum 

quantity or dollar value. 

DHS’s approach to SBInet introduces additional risk because the 

program’s schedule entails a high level of concurrency. With multiple 

related and dependent projects being undertaken simultaneously, SBInet

is exposed to possible cost and schedule overruns and performance 

problems. Without assessing this level of concurrency and how it affects 

project implementation, SBInet runs the risk of not delivering promised 

capabilities and benefits on time and within budget. We recommended that 

DHS re-examine the level of concurrency and appropriately adjust the 

acquisition strategy. 

DHS generally agreed with our findings and conclusions, but did not agree 

with our assessment that the SBInet contract does not contain specific 

numbers of units that may be ordered or a maximum dollar value. In

addition, DHS stated that CBP intends to fully satisfy each of the 

legislative conditions in the near future to help minimize the program’s 

exposure to cost, schedule, and performance risks. 

With respect to our recommendations, DHS concurred with two of our 

recommendations and disagreed with one. Specifically, DHS concurred 

with our recommendation for future expenditure plans to include explicit 

and measurable commitments relative to capabilities, schedule, costs, and 

benefits associated with individual SBInet program activities. According to

DHS, future SBInet expenditure plans will include actual and planned 

progress, report against commitments contained in prior expenditure 

plans, and include a section that addresses and tracks milestones. DHS 

also concurred with our recommendation to re-examine the level of 

concurrency and appropriately adjust the acquisition strategy. In its 

written comments, DHS stated that CBP is constantly assessing the overall

program as it unfolds, and adjusting it to reflect progress, resource 

constraints, refinements and changes in requirements, and insight gained 

from ongoing system engineering activities. DHS also stated that CBP 

recognizes the risk inherent in concurrency and has plans to address this 

risk. 

DHS did not agree with our recommendation to modify the SBInet

integration contract to include a maximum quantity or dollar value. 

According to DHS, the quantity stated in the contract, “6,000 miles of 

secure U.S. border,” is measurable and is therefore the most appropriate 

Page 13 GAO-07-504T 
approach to defining the contract ceiling. We do not agree. In order to 

ensure that the SBInet contract is consistent with the FAR, we continue to 

believe that it should be modified to include a maximum quantity, either 

units or a dollar value, rather than the total amount of miles to be secured.

This concludes our prepared testimony. We would be happy to respond to 

any questions that members of the subcommittee may have. 

For questions regarding this testimony, please call Richard M. Stana at 

(202) 512-8816 or StanaR@gao.gov or Randolph C. Hite at (202) 512-3439 

or HiteR@gao.gov. Other key contributors to this statement were William 

T. Woods, Director; Robert E. White, Assistant Director; Deborah Davis, 

Assistant Director; Richard Hung, Assistant Director; E. Jeanette Espínola; 

Frances Cook; Katherine Davis; Gary Delaney; Joseph K. Keener; Sandra 

Kerr; Raul Quintero; and Sushmita Srikanth. 

Contacts and 

Acknowledgments 

Page 14 GAO-07-504T 
Appendix

C

 I: Satisfaction of Legislative 

onditions

Page 15 GAO-07-504T 

Appendix I: Satisfaction of Legislative 

Conditions 

The SBInet December 2006 expenditure plan, including related 

documentation and program officials’ statements, satisfied four legislative 

conditions, partially satisfied four legislative conditions, and did not 

satisfy one legislative condition. The nine legislative conditions and the 

level of satisfaction are summarized in the table below. 

Satisfaction of Legislative Conditions

Legislative condition Status

1. Defines activities, milestones, and costs for implementing the 

program

Partially 

satisfied 

2. Demonstrates how activities will further the goals and objectives of 

the Secure Border Initiative, as defined in the SBI multiyear strategic 

plan 

Not 

satisfied 

3. Identifies funding and the organization staffing (including full-time 

equivalents, contractors, and detailees) requirements by activity Satisfied 

4. Reports on costs incurred, the activities completed, and the

progress made by the program in terms of obtaining operational 

control of the entire border of the United States 

Partially 

satisfied 

5. Includes a certification by DHS’s Chief Procurement Officer that 

procedures to prevent conflicts of interest between the prime 

integrator and major subcontractors are established and a 

certification by DHS’s Chief Information Officer that an independent 

verification and validation agent is currently under contract for the 

project Satisfied 

6. Complies with all applicable acquisition rules, requirements, 

guidelines, and best systems acquisition management practices of 

the federal government 

Partially 

satisfied 

7. Complies with the capital planning and investment control review 

requirements established by the Office of Management and Budget 

(OMB), including Circular A–11, part 7 

Partially 

satisfied 

8. Is reviewed and approved by DHS’s Investment Review Board, the 

Secretary of Homeland Security, and OMB Satisfied 

9. Is reviewed by GAO Satisfied 

Source: GAO analysis of DHS data. 

(440564) 
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