United States Government Accountability Office

GAO Report to Congressional Committees

SECURE BORDER 

INITIATIVE 

SBInet Expenditure 

Plan Needs to Better 

Support Oversight and 

Accountability 

February 2007 

 

GAO-07-309 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2007

SECURE BORDER INITIATIVE 

SBInet Expenditure Plan Needs to Better 

Highlights of GAO-07-309, a report to Support Oversight and Accountability 

congressional committees 

In November 2005, the Department 

of Homeland Security (DHS) 

established the Secure Border

Initiative (SBI) program to secure

U.S. borders and reduce illegal 

immigration. One element of SBI is 

SBInet, the program responsible 

for developing a comprehensive 

border protection system. By 

legislative mandate, DHS 

developed a fiscal year 2007 

expenditure plan for SBInet to

address nine legislative conditions, 

including a review by GAO. DHS 

submitted the plan to the 

Appropriations Committees on 

December 4, 2006. To address the 

mandate, GAO assessed the plan 

against federal guidelines and 

industry standards and interviewed

appropriate DHS officials. 

What GAO Recommends

GAO recommends 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) reexamine 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 compliance 

with regulations. 

The SBInet 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. 

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 multi-year 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. 

Satisfying the legislative conditions is important because the expenditure 

plan is intended to provide Congress with the information needed to 

effectively oversee the program and hold DHS accountable for program 

results. Satisfying the legislative conditions is also important to minimize the 

program’s exposure to cost, schedule, and performance 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 a broader 

multiyear initiative. However, the plan and related documentation did not 

include explicit and measurable commitments relative to capabilities, 

schedule, costs, and benefits associated with individual SBInet program 

activities. In addition, the SBInet systems integration contract did not 

contain a specific number of units that may be ordered or a maximum dollar 

value as required by Federal Acquisition Regulation. Further, DHS’s 

approach to SBInet introduces additional risk because the program’s 

schedule entails a high level of concurrency among related planned tasks 

and activities. 

www.gao.gov/cgi-bin/getrpt?GAO-07-309.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Richard M. 

Stana at (202) 512-8816 or stanar@gao.gov. 
Contents 

Letter 1

Compliance with Legislative Conditions 2 

Conclusions 7

Recommendations for Executive Action 7 

Agency Comments 8 

Appendix I Briefing to the Subcommittees on Homeland Security, 

Senate and House Committees on Appropriations 11 

Appendix II Comments from the Department of Homeland Security 62 

Appendix III GAO Contact and Staff Acknowledgments 65 

Abbreviations 

CBP Customs and Border Protection 

CIO Chief Information Officer 

CPO Chief Procurement Officer 

DHS Department of Homeland Security 

EVM earned value management 

FAR Federal Acquisition Regulation 

IRB Investment Review Board 

IV&V independent verification and validation 

OMB Office of Management and Budget 

PMO Program Management Office 

SBI Secure Border Initiative

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page i GAO-07-309 Secure Border Initiative
United States Government Accountability Office

Washington, DC 20548 

 

February 15, 2007 

The Honorable Robert C. Byrd 

Chairman 

The Honorable Thad Cochran 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

United States Senate 

The Honorable Robert C. Byrd 

Chairman 

The Honorable Thad Cochran 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

United States Senate 

The Honorable David E. Price 

Chairman 

The Honorable Harold Rogers 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

House of Representatives 

The Honorable David E. Price 

Chairman 

The Honorable Harold Rogers 

Ranking Minority Member 

Subcommittee on Homeland Security 

Committee on Appropriations 

House of Representatives 

The Secure Border Initiative (SBI) is a comprehensive, multiyear 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 the Department of Homeland 

Security (DHS). One element of SBI is SBInet, the program within U.S. 

Customs and Border Protection (CBP) responsible for developing a 

comprehensive border protection system. SBInet 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. In September 2006, after a full and open competition source 

selection, CBP awarded an indefinite delivery/indefinite quantity systems 

integration contract for 3 years, with three 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. 

The Secure Border Initiative (SBI) is a comprehensive, multiyear 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 the Department of Homeland 

Security (DHS). One element of SBI is SBInet, the program within U.S. 

Customs and Border Protection (CBP) responsible for developing a 

comprehensive border protection system. SBInet 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. In September 2006, after a full and open competition source 

selection, CBP awarded an indefinite delivery/indefinite quantity systems 

integration contract for 3 years, with three 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. 

Page 1 GAO-07-309 Secure Border Initiative
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 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 on 

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

December 7 and December 13, 2006, briefed the House and Senate 

Appropriations Subcommittee staff, respectively, on the results. This 

report transmits these results. The full briefing, including our scope and 

methodology, is reprinted in appendix I. 

The 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 below. 

Compliance with 

Legislative Conditions 

• Legislative condition 1: Define activities, milestones, and costs for 

implementing the program (partially satisfied). 

The SBInet expenditure plan included general cost information for 

proposed activities and some associated milestone information, such as 

beginning and ending dates. 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. However, the plan and related 

documentation did not include sufficient details about the activities, 

milestones, or costs for implementing the program. Although the plan 

stated that about $790 million will be spent in the Tucson sector in Arizona 

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 

 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. 

Page 2 GAO-07-309 Secure Border Initiative
implementation. In addition, the plan did not include activities, milestones, 

or costs for the northern border. According to DHS, work on the northern 

border is not to begin before fiscal year 2009. 

• Legislative condition 2: Demonstrate how activities will further the 

goals and objectives of the SBI, as defined in the SBI multiyear 

strategic plan (not satisfied). 

The SBInet expenditure plan included a section that describes SBI and 

SBInet goals; however, the expenditure plan and related documentation 

did not link individual activities with SBI’s goals, as called for by the 

legislative condition. Further, the December 2006 SBI strategic plan 

contained three strategic goals, one of which addresses border control. 

SBI and SBInet senior officials told us all SBInet activities link back to the 

overall goal of controlling the border and that the linkage between 

program goals and activities is intuitive. However, the SBInet expenditure 

plan did not link specific activities to more detailed SBI strategic plan

goals, such as the annual performance goals. 

• Legislative condition 3: Identify funding and organization staffing 

(including full-time equivalents, contractors, and detailees) 

requirements by activity (satisfied). 

The SBInet program is managed by the SBInet Program Management 

Office (PMO). The PMO plans to execute SBInet activities through a series 

of concurrent task orders and to rely on a mix of government and 

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

from approximately 100 to 270 personnel,2

 by September 2007 in order to 

support and oversee this series of concurrent task orders. As of December 

2006, SBInet officials told us that they have assigned lead staff for the task

orders that have been awarded. 

• Legislative condition 4: Report 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). 

 2

As of December 2006, SBInet personnel included 38 government employees and 60

contractor staff. Projected personnel as of September 2007 includes 113 government

employees and 157 contractors. 

Page 3 GAO-07-309 Secure Border Initiative
The SBInet expenditure plan and related documentation discussed how 

approximately $1.5 billion will be allocated to SBInet activities. For 

example, about $790 million is allocated for the Tucson Border Patrol 

sector and $260 million for the Yuma sector in Arizona.3

 However, the 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.4

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. According to the November 

2006 bimonthly report, as of August 2006, 284 miles of the southwest 

border are under control.

• Legislative condition 5: Include a certification by DHS’s Chief 

Procurement Officer (CPO) 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 

(CIO) that an independent verification and validation agent is currently 

under contract for the project (satisfied). 

On November 30, 2006, DHS’s CPO certified that the prime integrator had 

established procedures to prevent conflicts of interest between it and its 

major subcontractors and that DHS is developing a process to monitor and 

oversee implementation of the prime integrator’s procedures. Also, on 

November 30, 2006, DHS’s Deputy CIO certified that the SBInet program 

had contracted with a private company as the interim independent 

verification and validation (IV&V) agent. However, this company is also 

responsible for performing program activities, including requirements 

management and test and evaluation activities and thus is not independent 

of all the program’s products and processes that it could review. 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. 

4

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. 

Page 4 GAO-07-309 Secure Border Initiative
Deputy CIO certified that a permanent IV&V agent is to be selected by

February 28, 2007, and that CBP is to provide information sufficient to 

determine that this independence issue has been resolved. 

• Legislative condition 6: Comply with all applicable acquisition rules, 

requirements, guidelines, and best systems acquisition management 

practices of the federal government (partially satisfied). 

SBInet is using, at least to some extent, several acquisition best practices. 

The extent to which these practices are in use varies, and outcomes are 

dependent on successful implementation. However, one acquisition 

requirement not followed was that the SBInet systems integration contract 

did not contain a specific number of units that may be ordered or a 

maximum dollar value. According to the Federal Acquisition Regulation 

(FAR),5

 indefinite quantity contracts must specify the maximum quantity 

of supplies or services the agency will acquire. This may be stated as a 

number of units or as a dollar value. SBI and SBInet officials told us that 

the contract already contains a maximum quantity of “6,000 miles of 

secure U.S. border” and that this was sufficient to satisfy the FAR 

requirement. We disagree because the statement in the contract about the 

6,000 miles of secure border merely reflects the agency’s overall outcome 

to be achieved with the supplies or services provided but does not specify 

the maximum quantity of supplies or services the agency may acquire. We

believe that a maximum quantity or dollar value limit should be included 

in the contract in order to ensure that it is consistent with the FAR 

requirement. 

SBInet’s acquisition approach calls for considerable concurrency among 

related planned tasks and activities. 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, they have yet to 

provide evidence that shows they have identified the dependencies among 

their concurrent activities and that they are proactively managing the 

associated risk. 

 5

FAR 16.504(a)(4)(ii). 

Page 5 GAO-07-309 Secure Border Initiative
Further, the program office did not fully define and implement key 

acquisition management processes, such as project planning, requirements 

management, and risk management. According to the SBInet Program 

Manager, this is due to the priority being given to meeting an accelerated 

program implementation schedule. However, the program office has 

begun implementing a risk management process and, according to the 

Program Manager, plans to develop a plan for defining and implementing 

the remaining processes by the spring of 2007. 

• Legislative condition 7: Comply 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). 

As required by OMB, the plan and related documentation provided a brief

description of SBInet and addressed the program’s management structure 

and responsibilities for most of the program office’s directorates. In 

addition, the program office developed a draft privacy impact assessment 

and established an earned value management (EVM) system6

 to manage 

the prime integrator’s progress against cost and schedule goals. However, 

an OMB-required EVM system had not been fully implemented because the 

baselines against which progress can be measured for the two task orders 

that had been issued, as of December 4, 2006, were not yet established. 

Further, the program office had not yet developed a system security plan

or determined SBInet’s compliance with the DHS enterprise architecture.

7

• Legislative condition 8: Include reviews and approvals by DHS’s 

Investment Review Board (IRB), the Secretary of Homeland Security, 

and OMB (satisfied). 

DHS’s IRB approved the plan on November 22, 2006; the Secretary of 

Homeland Security approved the expenditure plan on November 22, 2006; 

and OMB approved the plan on December 4, 2006.

• Legislative condition 9: Include a review by GAO (satisfied). 

 6

EVM is a management tool to help ensure that work performed for a program or project is 

consistent with cost and schedule goals. 

7

An enterprise architecture defines how any organization operates today and how it plans 

to operate in the future, and it includes a road map for transitioning between the two sets 

of operations. 

Page 6 GAO-07-309 Secure Border Initiative
On December 7, 2006, we briefed the House of Representatives Committee 

on Appropriations staff and on December 13, 2006, we briefed the Senate

Committee on Appropriations staff regarding the results of our review. 

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. Because the SBInet expenditure plan lacked sufficient

details on such things as planned activities and milestones, anticipated 

costs and staffing levels, and expected mission outcomes, 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. 

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 achieved or 

expressed as a dollar value limit would help ensure that the contract is 

consistent with this requirement. 

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. 

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, we recommend that 

the Secretary of Homeland Security direct the U.S. Customs and Border 

Conclusions 

Recommendations for 

Executive Action 

Page 7 GAO-07-309 Secure Border Initiative
Protection Secure Border Initiative Program Management Office 

Executive Director to take the following three actions: 

• ensure that future expenditure plans include explicit and measurable 

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

associated with individual SBInet program activities; 

• modify the SBInet systems integration contract to include a maximum 

quantity or dollar value; and 

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

acquisition strategy. 

In written comments on a draft of this report, 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. DHS’s written comments are reproduced in 

appendix II.

Agency Comments 

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 added this to the 

program’s risk management database. 

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 

Page 8 GAO-07-309 Secure Border Initiative
secure U.S. border,” is measurable and is therefore the most appropriate 

approach to defining the contract ceiling. We do not agree. Under the 

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. In our view, the purported 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 any 

degree of 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 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. 

We are sending copies of this report to the Chairman and Ranking 

Minority Members of other Senate and House committees that have 

authorization and oversight responsibilities for homeland security. We are 

also sending copies to the Secretary of Homeland Security, the 

Commissioner of Customs and Border Protection, and the Director of the 

Office of Management and Budget. Copies of this report will also be 

available at no charge on the GAO Web site at http://www.gao.gov. 

If you or your staff have any further questions about this report, please 

contact Richard Stana at (202) 512-8816 or StanaR@gao.gov. Contact 

Page 9 GAO-07-309 Secure Border Initiative
points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. Key contributors to this report are 

listed in appendix III. 

Richard M. Stana 

Director, Homeland Security and Justice Issues 

Randolph C. Hite 

Director, Information Technology Architecture and Systems Issues 

William T. Woods 

Director, Acquisition and Sourcing Management 

Page 10 GAO-07-309 Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House Appendix I: Briefing to the Subcommittees on Committees on Appropriations

Homeland Security, Senate and House 

Committees on Appropriations 

1

Briefing on the Secure Border Initiative’s 

SBInet Expenditure Plan

Prepared for the House and Senate

Appropriations Committees

December 7 and December 13, 2006

Page 11 GAO-07-309 Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 12 GAO-07-309

2

Briefing Overview

• Objective, Scope, and Methodology

• Results in Brief

• Background

• Findings

• Conclusions

• Recommendations for Executive Action

• Agency Comments and Our Evaluation

• Attachment 1: Scope and Methodology

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 13 GAO-07-309

3

Objective, Scope, and Methodology

Our objective was to determine whether the Secure Border Initiative’s

(SBI) SBInet December 2006 expenditure plan satisfies nine legislative

conditions as required by the Department of Homeland Security

Appropriations Act, 2007.1

To accomplish our objective, 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 Department of Homeland Security’s (DHS) U.S. 

Customs and Border Protection (CBP) headquarters in the Washington, 

D.C., metropolitan area from October 2006 to December 2006, in

accordance with generally accepted government auditing standards. Details of our scope and methodology are provided in attachment 1.

1Pub. L. No. 109-295, 120 Stat. 1355, 1359-60. The Appropriations Act required an expenditure plan to establish a security barrier along 

the border of the United States of fencing and vehicle barriers and other forms of tactical infrastructure and technology. In response to this

requirement, DHS submitted a plan on December 4, 2006, titled “SBInet Expenditure Plan,” that defines SBInet as “the component of SBI

charged with developing and installing the technology and tactical infrastructure solution for border control.” The Appropriations Act also 

required GAO to review the expenditure plan.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 14 GAO-07-309

4

Results in Brief: 

Satisfaction of legislative conditions

1Satisfied means that the plan, in combination with supporting documentation, either satisfied or provides for satisfying each requirement of

the condition that we reviewed. Partially satisfied means that the plan, in combination with supporting documentation, either satisfied or

provides for satisfying some, but not all, key aspects of the condition that we reviewed. Not satisfied means that the plan, in combination with

supporting documentation, does not satisfy any of the key aspects of the condition that we reviewed.

5. Includes a certification by DHS’s Chief Procurement Officer (CPO) that Satisfied

procedures to prevent conflicts of interest between the prime integrator 

and major subcontractors are established and a certification by DHS’s

Chief Information Officer (CIO) that an independent verification and

validation agent is currently under contract for the project.

Partially 

satisfied

Satisfied

Not

satisfied

Partially 

satisfied

Status1

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.

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

equivalents, contractors, and detailees) requirements by activity.

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

Secure Border Initiative, as defined in the SBI multi-year strategic plan.

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

Legislative conditions

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 15 GAO-07-309

5

Results in Brief: 

Satisfaction of legislative conditions

Partially 

satisfied

6. Complies with all applicable acquisition rules, requirements, guidelines,

and best systems acquisition management practices of the federal

government.

9. Is reviewed by GAO. Satisfied

Satisfied

Partially 

satisfied

Status1

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

2 the

Secretary of Homeland Security, and OMB.

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.

Legislative conditions

1Satisfied means that the plan, in combination with supporting documentation, either satisfied or provides for satisfying each requirement of 

the condition that we reviewed. Partially satisfied means that the plan, in combination with supporting documentation, either satisfied or

provides for satisfying some, but not all, key aspects of the condition that we reviewed. Not satisfied means that the plan, in combination with

supporting documentation, does not satisfy any of the key aspects of the condition that we reviewed. 2The purpose of the Investment Review Board is to integrate capital planning and investment control, budgeting, acquisition and management

of investments. It is also to ensure that spending on investments directly supports and furthers the mission and that this spending provides

optimal benefits and capabilities to stakeholders and customers.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 16 GAO-07-309

6

Background

• SBI is a comprehensive, multi-year program sponsored 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 protect against and prevent terrorist attacks and 

other transnational crimes.

• Elements of SBI will be carried out by several organizations within

DHS. Under SBI is SBInet, the program within CBP responsible for

developing a comprehensive border protection system (see fig. 1).

SBInet will lead the effort to ensure the proper mix of personnel

(e.g., program staff and Border Patrol agents), tactical

infrastructure, rapid response capability, and technology are 

deployed along the border.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 17 GAO-07-309

7

Background

Figure #1: SBI Organizational Chart

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 18 GAO-07-309

8

Background

• DHS defines control of U.S. borders as the ability to:

1. detect illegal entries into the United States; 

2. identify and classify these entries to determine the level of 

threat involved; 

3. efficiently and effectively respond to these entries; and

4. bring events to a satisfactory law enforcement resolution. 

• The initial focus of SBInet will be on southwest border investments

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

having the highest need for enhanced border security due to 

serious vulnerabilities. Figure 2 shows the topography, interstate 

highways, and some major secondary roads along the southwest 

border.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 19 GAO-07-309

9

Background

Figure 2: Topography and Road Systems along the Southwest Border

Note: The U.S.-Mexican border is denoted by the black line that starts at the far left in San Diego, California, and that moves to the far right, 

ending at Brownsville, Texas.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 20 GAO-07-309

10

Background

• In September 2006, after a full and open competition source

selection, Boeing was awarded an Indefinite Delivery/Indefinite 

Quantity (IDIQ) contract for 3 years, with three 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.”

• Boeing’s solution will 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 (see fig. 

3.) The solution will also include the development of a common 

operating picture (COP) that will provide uniform data, through a 

command center environment, to all DHS agencies and be 

interoperable with stakeholders external to DHS.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 21 GAO-07-309

11

Background

Figure 3: Existing Technology along the Border

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 22 GAO-07-309

12

Background

DHS’s acquisition process for major investments consists of 5 decision

milestones and requires Investment Review Board approval at key decision 

points (see fig. 4).

Figure 4: DHS’s Acquisition Process

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 23 GAO-07-309

13

Legislative condition #1: Defines Activities,

Milestones, and Costs (Partially Satisfied)

The expenditure plan, including related documentation

and program officials’ statements, partially satisfied the 

condition to define activities, milestones, and costs for 

implementing the program.

The SBInet expenditure plan should include sufficient

details of planned activities, milestones, and costs for

Congress and DHS to be assured that planned use of

current and future appropriations offer a reasonable 

expectation of achieving operational control of the U.S 

border, and to provide a basis for measuring program 

success and holding program managers accountable.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 24 GAO-07-309

14

Legislative condition #1 continued

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

the southwest border is $7.6 billion from FY2007 through FY2011.

• $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. 

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

the acquisition phase for the southwest border.

• DHS expects to have control of the southwest border by October 2011. 

DHS officials have yet to provide draft implementation plans by southwest

border sectors and years for FY2007-FY2011.

• The expenditure plan does not include activities, milestones, or costs for 

the northern border. According to DHS, work on the northern border is not 

projected to begin before FY2009.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 25 GAO-07-309

15

Legislative condition #1 continued

The expenditure plan provides a general breakdown of how funds will be 

allocated to SBInet’s activities.1 (See table 1.)

Table 1: SBInet Funding Allocations FY2005-FY2007 (in thousands) 

Source: GAO analysis of SBInet Expenditure Plan.

1According to DHS officials, no FY2006 funds were allocated to SBInet activities. 2Other includes activities related to test and evaluation, deployment and installation, and integrated logistics support.

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

Other 59,742 59,742 2

Environmental Requirements 61,000 61,000

Program Management Office Support 55,000 55,000

Systems Engineering Support 6,000 6,000 12,000

Advanced Technology Development 10,000 10,000

San Diego Fence 30,500 30,500

Texas Mobile System 20,000 20,000

Tactical Infrastructure Western Arizona 57,823 57,823

Yuma and Tucson Tactical Infrastructure 24,391 24,391

Yuma Sector 204,609 55,075 259,684

Tucson Sector 60,000 729,359 789,359

Common Operating Picture 100,000 100,000

Project 28 $20,000 20,000

Management Task Order $36,800 $13,066 $49,866

Activity FY2005 FY2006 Supplemental FY2007 Total

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 26 GAO-07-309

16

Legislative condition #1 continued

• The expenditure plan includes certain milestones, such as starting 

and ending dates, for some but not all activities. 

• For Project 28, the task order has been issued and the milestones

are defined.

• In other cases, such as the Tucson and Yuma sector activities, milestones and costs are preliminary and more likely to change 

because they are in the early stages of planning and requirement

setting. According to SBInet officials, factors such as technological, environmental, and eminent domain constraints can affect the 

timetables and costs of these activities. 

• Figure 5 illustrates some key milestones defined by SBInet officials

for selected activities.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 27 GAO-07-309

17

Legislative condition #1 continued

Figure 5: Timeline by selected project

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 28 GAO-07-309

18

Legislative Condition #2: Demonstrates How Activities will 

Further the Goals of SBI’s Strategic Plan (Not Satisfied)

The expenditure plan, including related documentation

and program officials’ statements, did not satisfy the

condition to demonstrate how activities will further the 

goals and objectives of the SBI, as defined in the SBI

multi-year strategic plan.

As one component of a larger initiative, the SBInet 

expenditure plan needs to demonstrate the linkage 

between its individual activities and the objectives of SBI.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 29 GAO-07-309

19

Legislative Condition #2 continued

• The expenditure plan discusses the goals and 

objectives of four strategic plans: DHS, SBI, CBP, and 

SBInet. (See table 2.)

• However, the plan does not directly link the SBInet

activities to these goals and objectives. As a result, 

Congress is not in a position to understand how

SBInet’s activities contribute to SBI’s goals and 

objectives.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 30 GAO-07-309

20

Legislative Condition #2 continued

Source: SBInet Expenditure Plan.

Table 2: SBInet Strategic Alignment of Goals

Provide Responsible Acquisition 

Management.

Improve asset acquisition and

management methods and

procedures, ensuring the

effective procurement of

supplies, services, and

equipment in alignment with the

CBP mission, goals, and

priorities.

Strengthen DHS Management 

efforts.

Improve the efficiency and

effectiveness of the Department,

ensuring taxpayers get value for

their tax dollars.

Objective 7.4 Core Enabler Objective 6.2 Strategic Goal #3

Lead Development and

Deployment of a COP.

Develop and implement policy,

management, operations,

infrastructure and training 

initiatives to integrate frontline

border enforcement personnel.

Develop and deploy the optimal 

mix of personnel, infrastructure,

technology and response

capabilities to identify, classify

and interdict cross-border

violators.

Provide operational end users

with the technology and

capabilities to detect and prevent

terrorist attacks, means of

terrorism and other illegal 

activities.

Objective 2.3 Goal 1.1 Objective 3.2 Strategic Goal #2

Ensure border security by

providing resources and 

capabilities to gain and maintain 

control of the nation's borders at

and between Ports of Entry.

Maximize border security, along

the northern, southern and

coastal borders, through an

appropriate balance of

personnel, equipment,

technology, communications

capabilities and tactical

infrastructure.

Gain effective control of the

borders.

Secure our borders against

terrorists, means of terrorism,

illegal drugs, and other illegal 

activity.

Objective 2.1 Goal 1 Objective 2.2 Strategic Goal #1

CBP Strategic Plan SBInet Strategic Plan

DHS Secure Border

DHS Strategic Plan Strategic Plan

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 31 GAO-07-309

21

Legislative Condition #3: Identifies Funding and 

Staffing Requirements by Activity (Satisfied)

The expenditure plan, including related documentation

and program officials’ statements, satisfied the condition

to identify funding and the organization staffing (including 

full-time equivalents, contractors, and detailees) 

requirements by activity.

The expenditure plan should identify funding1 and staffing 

requirements with sufficient detail to provide reasonable 

assurance to Congress that government oversight of

planned major expenditures will be adequate to minimize 

the risk of inefficient or wasteful spending.

1See discussion of legislative condition #1 for a review of planned activities and costs.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 32 GAO-07-309

22

Legislative Condition #3 continued

• SBInet activities will be executed through a series of task orders. The SBInet

program plans to rely on a mix of government and contractor staff to manage the 

program.

• As of December 2006, SBInet officials told us that they have assigned lead staff for 

the task orders that have been awarded. In addition, SBInet officials told us that

their human capital strategy, scheduled to be finalized in December, will provide 

more details on staffing and expertise needed for the program.

• The SBInet program is managed by the SBInet Program Management Office

(PMO). The PMO reports to the CBP SBI Program Executive Director. The PMO 

plans to nearly triple its current workforce by September 2007 in order to support

and oversee a planned series of concurrent task orders. (See fig. 6.)

• 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.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 33 GAO-07-309

23

Legislative Condition #3 continued

Figure 6: CBP SBI and SBInet Current and Projected Personnel

Notes:

Current Staff is as of December 2006.

Projected Staff is as of September 30, 2007.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 34 GAO-07-309

24

Legislative Condition #4: Reports on Costs Incurred, Activities 

Completed and Progress to Date (Partially Satisfied)

The expenditure plan, including related documentation

and program officials’ statements, partially satisfied the 

condition to report 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.

The expenditure plan should include a baseline measure 

of operational control of the border in order to inform

Congress on the level of progress already achieved. 

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 35 GAO-07-309

25

Legislative Condition #4 continued

• The plan and supporting documentation discusses allocations but 

not costs incurred.

• Examples of activities completed to date:

1. Systems integration contract was awarded in September

2006.

2. Two task orders have been awarded

• Program Management/Systems Engineering - $36.5 

million (September 2006)

• Project 28 - $20 million (October 2006)

• The plan does not discuss progress to date made by the program 

to obtain operational control of the border. The bi-monthly SBI 

reports to Congress include baseline information.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 36 GAO-07-309

26

Legislative Condition #5: Includes Certifications by

CPO and CIO (Satisfied)

• On November 30, 2006, DHS’s Chief Procurement Officer

certified that the prime integrator has established procedures to 

prevent conflicts of interest between it and its major

subcontractors and that DHS is developing a process to 

monitor and oversee implementation of the prime integrator’s 

procedures.

The expenditure plan, including related documentation and program 

officials’ statements, satisfied the condition to include 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.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 37 GAO-07-309

27

Legislative Condition #5: Includes Certifications by

CPO and CIO (Satisfied)

• On November 30, 2006, DHS’s Deputy Chief Information 

Officer certified the SBInet program has contracted with a

private corporation as the interim Independent Verification and 

Validation (IV&V) Agent. However, this corporation is also

responsible for the program’s requirements management and 

test and evaluation activities and thus is not independent of all 

the program’s products and processes that it could review. The 

Deputy CIO certified that a permanent IV&V agent is to be 

selected by February 28, 2007.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 38 GAO-07-309

28

The plan, including related documentation and program officials’

statements, partially satisfied the condition to comply with applicable 

acquisition rules, requirements, guidelines, and best systems

acquisition management practices of the federal government, such as 

the DHS’s acquisition guidelines, Federal Acquisition Regulation, and 

the Software Engineering Institute’s acquisition guidance and 

practices.

Legislative Condition #6: Complies with Acquisition Rules

and Requirements (Partially Satisfied)

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 39 GAO-07-309

29

Legislative Condition #6 continued

DHS Acquisition Guidelines

SBInet is using, at least to some extent, several of the best practices 

or “Guiding Principles” in DHS Management Directive 1400, 

including:

Competition

Earned Value Management

Performance-based contracting

Spiral Development

Risk Management

The extent to which these practices are in use varies, and outcomes

are dependent on successful implementation.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 40 GAO-07-309

30

Federal Acquisition Regulation (FAR):

• Under FAR Part 16, indefinite quantity contracts must specify the 

maximum quantity of supplies or services the agency will acquire. 

These may be stated as number of units or dollars.

• The SBInet contract does not contain specific numbers of units that 

may be ordered or a maximum dollar value. 

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 41 GAO-07-309

31

Other Issues:

• Fee Structure: The Program Management Task Order includes a relatively high base fee 

of 5 percent. By comparison, the Department of Defense regulations and the National

Aeronautics and Space Administration guidance generally limit base fees to 3 percent or

less. Conversely, our experience in reviewing contract matters shows that the award fee

of 3 percent may not be high enough relative to the base fee to motivate higher levels of

performance. DHS officials said that they will establish an appropriate fee structure when

issuing future task orders.

• Concurrency: 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. As shown on slide 17, DHS plans call for considerable concurrency

among SBInet planned tasks and activities that are related, such as the lessons learned

from the Project 28 task order that are to be incorporated in the sector task orders and the

program management task order that is to establish the capabilities to manage and 

oversee all of the other task orders. According to program officials, risks associated with

concurrency are being managed. However, we have yet to receive information showing 

that the program has defined task and activity dependencies and relationships, and the

risk inventory does not include a risk related to concurrency.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 42 GAO-07-309

32

Software Engineering Institute Acquisition Guidance

The Software Engineering Institute’s recognized guidance on system 

acquisition practices provides a management framework based on 

disciplined and rigorous processes for planning, managing, and 

controlling the acquisition of information technology (IT) resources.

These processes include, among others, acquisition management, 

project planning, project monitoring and control, requirements

management, measurement and analysis, process and product quality

assurance, and risk management.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 43 GAO-07-309

33

The program management office has not fully defined and 

implemented all of these key acquisition management processes.

• According to the SBInet Program Manager, these processes

have not been fully defined and implemented because of a 

lack of time due to the priority to meet a tight program 

implementation schedule. He further stated that he plans to 

develop a plan for defining and implementing these 

processes. The plan is to be incorporated in a revised 

Program Management Plan (PMP), which is to be available in

the spring of 2007.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 44 GAO-07-309

34

The program office has defined and begun implementing one of these 

process areas -- risk management. 

• The program office developed a draft risk management plan, 

dated September 29, 2006. This draft plan addressed, among 

other things, a process for identifying, analyzing, mitigating, 

tracking, and controlling risks. As part of its process, the 

program office has 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, although

we have yet to receive it.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 45 GAO-07-309

35

• The program office has also begun implementing its process.

For example, it has 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 risk inventory,

which was provided to us on November 6, 2006, identified 30 

risks, of which 11 are designated as high risks and 2 are 

designated as issues – understanding overall program cost and 

program management office staffing. According to the SBInet

Program Manager, an issue is a risk that has been realized. He 

further stated that the program cost issue is to be closed, but 

the program management office staffing issue is still open.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 46 GAO-07-309

36

• Examples of other high risks include

• Timely completion of environmental risk assessments,

• Early definition of tactical infrastructure requirements, and

• Success of 8-month milestone for Project 28.

Legislative Condition #6 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 47 GAO-07-309

37

Legislative Condition #7: Complies with Capital Planning and 

Investment Control Review Requirements (Partially Satisfied)

The plan, including related program documentation and program 

officials’ statements, partially satisfied the Capital Planning and 

Investment Control (CPIC) review requirements established by OMB, 

including Circular A-11, part 7, which establishes policy for planning, 

budgeting, acquisition, and management of federal capital assets.

Examples of our analysis follow.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 48 GAO-07-309

38

Legislative Condition #7 continued

A-11 Requirement

• Provide a brief description of the investment and its status in the CPIC review, 

including major assumptions made about the investment. 

Results of our analysis

• The expenditure plan includes a brief description of SBInet. The plan does not

describe the status of the investment in the DHS CPIC process, but indicates that

SBInet is being managed using a CPIC framework. However, it is unclear where

SBInet is in the CPIC process.

• According to the SBInet DHS Joint Requirements Council and IRB briefing document

for fiscal year 2007, dated November 22, 2006, the program office plans to

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

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 49 GAO-07-309

39

Legislative Condition #7 continued

A-11 Requirement

• Describes the management structures, responsibilities, and qualifications that

contribute to achievement of cost, schedule, and performance goals.

Results of our analysis

• The expenditure plan and other documentation address the management structures

and responsibilities. Specifically, the program office includes six line and four staff

directorates reporting to the SBInet Program Manager. The management structure 

also includes the use of integrated project teams that consist of subject matter 

experts from a variety of disciplines required to effectively manage an acquisition 

project.

• The draft Program Management Plan, dated September 18, 2006, identified

responsibilities for five of the six program office line directorates, and for two of the

four staff directorates. The plan also identified responsibilities for some, but not all, 

divisions within each of the directorates. For example, the plan describes the 

responsibilities of the Mission Engineering Directorate, but it does not describe the 

responsibilities for the five divisions within the Directorate.

• We have not yet seen any documentation that describes the qualifications of the

program office staff.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 50 GAO-07-309

40

Legislative Condition #7 continued

A-11 Requirement

• Provide a summary of the investment’s risk assessment, including how 19 OMBidentified risk elements are being addressed.

Results of our analysis

• The program office has defined and begun implementing a risk management

process, and developed a risk database that addresses 13 of the 19 OMB-identified 

risk. The risk elements that are not addressed include privacy and technical 

obsolescence.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 51 GAO-07-309

41

A-11 Requirement

• Provides a summary of the investment’s status in accomplishing baseline cost

and schedule goals through the use of an earned value management (EVM)

system or operational analysis, depending on the life-cycle stage.

Results of our analysis

• The program office is currently relying on the prime integrator’s EVM system to

manage the prime contractor’s progress against cost and schedule goals. The 

prime integrator’s EVM system has been independently certified as meeting 

established standards.

• However, the EVM system has not yet been fully implemented because the 

baselines against which progress can be measured for the two task orders that

have been issued to date has not yet been established. According to program

officials, these baselines will be established for the program management task

order and the Project 28 task order in mid-December 2006 and mid-January

2007, respectively.

Legislative Condition #7 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 52 GAO-07-309

42

A-11 Requirement

• Demonstrates that the investment is included in the agency’s enterprise architecture 

and CPIC process.

Results of our analysis

• The expenditure plan did not include a discussion of the program office’s activities in

regard to the DHS enterprise architecture. 

• Moreover, according to program officials, the program office has not yet determined 

if SBInet is aligned with the architecture. According to these officials, SBInet is to be

reviewed by the Enterprise Architecture Center of Excellence, which is the DHS

entity that determines enterprise architecture alignment, by the end of December

2006.

• With respect to the CPIC requirement, the plan does not describe the status of the

investment in the DHS CPIC process, but indicates that it is being managed using a 

CPIC framework. Also, as stated previously, it is unclear where SBInet is in the

CPIC process.

Legislative Condition #7 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 53 GAO-07-309

43

A-11 Requirement

• Provides a description of an investment’s security and privacy issues. Summarizes 

the agency’s ability to manage security at the system or application level.

Demonstrates compliance with the certification and accreditation process, as well as 

the mitigation of IT security weaknesses. 

Results of our analysis

• The expenditure plan did not include a discussion of security and/or privacy.

According to a program office security specialist, the program office has not yet 

developed a system security plan because it is too early in the system development

life cycle. A system security plan is to be developed as a part of the system

certification and accreditation process.

• Regarding privacy, the program office developed a draft privacy impact assessment

dated October 2006. The assessment addresses several, but not all, of OMB’s

criteria.

1

1OMB, Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-03-22 

(Sept. 26, 2003).

Legislative Condition #7 continued

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 54 GAO-07-309

44

Legislative Condition #8: Includes Approvals by IRB, 

DHS Secretary and OMB (Satisfied)

• DHS’s Investment Review Board approved the plan on

November 22, 2006.

• The Secretary of Homeland Security approved the expenditure 

plan on November 22, 2006. 

• OMB approved the plan on December 4, 2006.

The expenditure plan, including related documentation and program 

officials’ statements, satisfied the condition that the plan be reviewed

and approved by DHS’s Investment Review Board, the Secretary of 

Homeland Security, and OMB.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 55 GAO-07-309

45

Legislative Condition #9: Is Reviewed by GAO 

(Satisfied)

• The SBInet PMO provided draft versions of the expenditure 

plan and supporting documentation.

• We conducted our review from October 11, 2006, to December

5, 2006.

The expenditure plan, including related documentation and program 

officials statements, satisfies the condition that the plan be reviewed 

by GAO.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 56 GAO-07-309

46

Conclusions

• The SBInet December 2006 expenditure plan, including related documentation and 

program officials’ statements, has satisfied four, partially satisfied four and not

satisfied one of the nine conditions legislated by the Congress. Satisfying the 

legislative conditions is important because the expenditure plan is intended to

provide Congress with the information needed to effectively oversee the program

and hold DHS accountable for program results. Satisfying the legislative conditions

is also important to minimize the program’s exposure to cost, schedule, and

performance risks.

• DHS’s approach to SBInet introduces additional risk because the program’s

structure entails a high level of concurrency and lacks a maximum quantity or dollar 

value for the integration contract.

• The current expenditure plan offers a high-level and partial outline of a large and 

complex program that forms an integral component of a broader multi-year 

initiative. However, Congress and DHS need additional details of planned 

milestones, anticipated interim and final costs, and staffing to be reasonably

assured that the current risk to the project’s cost, schedule, and ultimate

effectiveness is minimized.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 57 GAO-07-309

47

Recommendations

To 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, we recommend that

the Secretary of Homeland Security direct the U.S. Customs and Border 

Protection Secure Border Initiative Program Management Office 

Executive Director to take the following three actions:

• ensure that future expenditure plans include explicit and 

measurable commitments relative to the capabilities, schedule, 

costs, and benefits associated with individual SBInet program

activities; 

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

acquisition strategy; and 

• modify the SBInet systems integration contract to include a

maximum quantity or dollar value.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 58 GAO-07-309

48

Agency Comments and Our Evaluation

In their oral comments on a draft of this briefing, DHS, SBI, and SBInet officials 

generally agreed with our findings. However, they did not agree with our

assessment that the expenditure plan did not satisfy legislative condition #2 which 

requires the expenditure plan to demonstrate how activities will further the goals

and objectives of SBI’s strategic plan. They stated that all SBInet activities link

back to the overall goal of controlling the border and that the linkage between 

program goals and activities is intuitive. We maintain our position that the

requirement has not been satisfied because the plan and supporting documentation 

does not directly link SBInet’s activities to SBI’s goals and objectives; therefore,

Congress is not in a position to understand how SBInet’s activities contribute to

these goals and objectives.

With respect to our recommendations, DHS, SBI, and SBInet officials agreed with

our first recommendation on the need for future expenditure plans to include explicit 

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

associated with individual SBInet program activities. SBI and SBInet officials stated 

that more details will be available for future expenditure plans as subsequent task

orders for the program are awarded.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 59 GAO-07-309

49

Agency Comments and Our Evaluation continued

DHS, SBI, and SBInet officials took issue with our second recommendation that they reexamine the level of concurrency and appropriately adjust the acquisition strategy. They

stated that they understand the risks inherent in concurrency and are addressing these

risks. However, they have yet to provide evidence that shows they have identified the

dependencies among their concurrent activities and that their risk management framework

considers the issue of concurrency; therefore, we continue to believe that the level of

concurrency should be proactively addressed through reexamination and appropriate

adjustment of the acquisition strategy.

DHS, SBI and SBInet officials also took issue with our third recommendation on modifying

the SBInet integration contract to include a maximum quantity or dollar value. They stated

that the contract already contains a maximum quantity of “6,000 miles of secure U.S.

border” and that this was sufficient to satisfy the FAR requirement. We disagree and

continue to believe that a maximum quantity or dollar value limit should be included in the

integration contract in order to ensure that it is consistent with FAR requirements.

DHS, SBI and SBInet officials also provided clarifying information that we incorporated as

appropriate in this briefing.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 60 GAO-07-309

50

Attachment 1: Scope and Methodology

• To accomplish our objective, we analyzed the SBInet fiscal year 2007

expenditure plan and supporting documentation, comparing them to

relevant federal requirements and guidance, and applicable best practices.

• We reviewed draft versions of the expenditure plan, including versions 1.0 

(November 15, 2006); 2.0 (November 27, 2006); and 2.1 (November 29, 2006). We also reviewed the final version of the plan submitted to 

Congress on December 4, 2006.

• We interviewed DHS, CBP, SBI, and SBInet program officials and 

contractors.

• We did not review the justification for cost estimates included in the

expenditure plan. In addition, we did not independently verify the source or 

validity of the cost information.

Secure Border Initiative
Appendix I: Briefing to the Subcommittees on 

Homeland Security, Senate and House 

Committees on Appropriations

Page 61 GAO-07-309

51

Attachment 1: Scope and Methodology continued

• We reviewed and assessed available program documentation against

federal and industry acquisition guidelines and practices, such as the 

Software Engineering Institute’s acquisition management processes and 

controls. 

• We compared available program documentation to capital planning

guidance (OMB-A-11) to determine whether the information complies with 

the capital planning and investment controls.

• We conducted our work at CBP headquarters in the Washington, D.C., metropolitan area from October 2006 to December 2006, in accordance 

with generally accepted government auditing standards.

Secure Border Initiative
Appendix II: Comments from the Department Appendix II: Comments from the Department of Homeland Security

of Homeland Security 

Page 62 GAO-07-309 Secure Border Initiative
Appendix II: Comments from the Department 

of Homeland Security

Page 63 GAO-07-309 Secure Border Initiative
Appendix II: Comments from the Department 

of Homeland Security

Page 64 GAO-07-309 Secure Border Initiative
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 65 GAO-07-309

Appendix III: GAO Contact and Staff 

Acknowledgments 

Richard M. Stana, (202) 512-8816, stanar@gao.gov

In addition to the person named above, 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 made key contributions to this report. 

Secure Border Initiative

GAO Contact 

Staff 

Acknowledgments 

(440564) 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER