CBP Has Not 

Demonstrated Acquisition 

Capabilities Needed to 

Secure the Southern 

Border 

July 14, 2020 

OIG-20-52 
-XO\
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Please send your response or closure request to 

OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We 

will post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Sondra McCauley, 

Assistant Inspector General for Audits, at (202) 981-6000. 

Attachment 

cc: James Mccament, Deputy Under Secretary, Office of Strategy, 

Policy, and Plans 

www.oig.dhs.gov 2 
 

 

 

 

 

DHS OIG HIGHLIGHTS 

CBP Has Not Demonstrated Acquisition 

Capabilities Needed to Secure the Southern Border 

July 14, 2020 

Why We Did 

This Audit 

Executive Order 13767, 

issued on January 25, 

2017, directed the 

Department of Homeland 

Security to plan, design, 

and construct a physical 

wall along the southern 

border. We conducted this 

audit to determine to what 

extent CBP has executed 

the Analyze/Select Phase, 

the second phase of the 

Acquisition Life Cycle 

Framework, for the 

acquisition of the barrier 

along the southern border. 

What We 

Recommend 

We made three 

recommendations to 

improve CBP’s ongoing 

acquisition to obtain 

operational control of the 

southern border. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

What We Found 

U.S. Customs and Border Protection (CBP) has not 

demonstrated the acquisition capabilities needed to 

execute the Analyze/Select Phase of the Wall Acquisition 

Program effectively. Specifically, CBP: 

x did not conduct an Analysis of Alternatives to assess 

and select the most effective, appropriate, and affordable 

solutions to obtain operational control of the southern 

border as directed, but instead relied on prior outdated 

border solutions to identify materiel alternatives for 

meeting its mission requirement; and 

x did not use a sound, well-documented methodology to 

identify and prioritize investments in areas along the 

border that would best benefit from physical barriers. 

The Department also did not complete the required plan to 

execute the strategy to obtain and maintain control of the 

southern border, as required by its Comprehensive 

Southern Border Security Study and Strategy. Without an 

Analysis of Alternatives, a documented and reliable 

prioritization process, or a plan, the likelihood that CBP 

will be able to obtain and maintain complete operational 

control of the southern border with mission effective, 

appropriate, and affordable solutions is diminished. 

DHS Response 

DHS concurred with recommendation 2 but did not concur 

with recommendations 1 and 3. Appendix D contains DHS 

management comments in their entirety. We consider all 

recommendations unresolved and open. 

www.oig.dhs.gov OIG-20-52 
 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 1 

Results of Audit .............................................................................................. 6 

CBP Did Not Conduct an Analysis of Alternatives to Assess All 

Possible Alternatives to Secure the Southern Border .............................. 7 

Methodology for Identifying and Prioritizing Investments along 

the Southern Border Was Not Comprehensive ....................................... 8 

Inadequate Planning for Operational Control of the Southern 

Border ................................................................................................. 12 

Conclusion.................................................................................................... 13 

Recommendations......................................................................................... 14 

Management Comments and OIG Analysis .................................................... 14 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 21 

Appendix B: CBP Funding for Procurement, Construction, and 

Improvements along the Southern Border ....................... 24 

Appendix C: Status of Border Wall Construction as of July 2019 ......... 25 

Appendix D: CBP Comments to the Draft Report .................................. 26 

Appendix E: Report Distribution.......................................................... 34 

Abbreviations 

ADE Acquisition Decision Event
 

ALF Acquisition Lifecycle Framework 

AoA Analysis of Alternatives 

CBP U.S. Customs and Border Protection 

DOD Department of Defense 

IPLAN DHS Executive Order Implementation Plan 

OIG Office of Inspector General 

U.S.C. United States Code 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

Within the Department of Homeland Security, U.S. Customs and Border 

Protection (CBP), U.S. Border Patrol is responsible for preventing terrorists, 

terrorist weapons, transnational crime, and illegal immigrants from entering 

the United States between the land ports of entry. Border Patrol also disrupts 

and degrades transnational criminal organizations by targeting enforcement 

efforts against the highest priority threats, smuggling, and crimes associated 

with smuggling. In total, nine Border Patrol Sectors are responsible for 

guarding the nearly 2,000-mile U.S. border shared with Mexico.1 

CBP invests in and deploys essential personnel, technology, and infrastructure 

to gain and maintain operational control of the southern border.2 According to 

the 2017 U.S. Border Patrol Impedance and Denial Prioritization Strategy (2017 

Impedance and Denial Strategy), four capability needs have consistently been 

identified as required for operational control. 

x impedance and denial – the ability to slow or stop illicit cross border 

activity; 

x domain awareness – the ability to continuously detect, identify, classify, 

and track border incursions for the purpose of planning and executing a 

response; 

x access and mobility – the ability to access areas of responsibility and, 

under all conditions, effect mobility for the purpose of responding to 

illicit cross-border activity; and 

x mission readiness – the ability to develop, construct, deploy and 

maintain a proper logistics chain for the purpose of securing 

infrastructure and equipping agents. 

CBP’s infrastructure investments for impedance and denial needs have 

resulted in construction of 654 miles of fencing along the southern border — 

comprising 354 miles of pedestrian fence and 300 miles of vehicle fence. These 

structures span Federal, private, and tribal areas. Table 1 depicts the 

pedestrian and vehicle fencing in place along the southern border, as of 

January 2017. 

1 Border Patrol divides responsibility for border security operations geographically among nine
 

sectors along the southwest border – San Diego, California; El Centro, California; Yuma, 

Arizona; Tucson, Arizona; El Paso, Texas; Big Bend, Texas; Del Rio, Texas; Laredo, Texas; and 

Rio Grande Valley, Texas. Each sector is further divided into stations, with agents assigned to
 

patrol defined geographic areas, or zones, within each station.
 2 To achieve its mission, Border Patrol has identified 12 needed Master Capabilities: (1) 

impedance and denial, (2) domain awareness, (3) access and mobility, (4) mission readiness, (5) 

command and control, (6) security and partnerships, (7) human capital management,
 

(8) doctrine and policy, (9) intelligence and counter-intelligence, (10) planning and analysis, 

(11) communications, and (12) information management. 

www.oig.dhs.gov 1 OIG-20-52 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1: Southern Border Fencing Miles, as of January 2017 

Land Type Primary Pedestrian Fence Miles Primary Vehicle Fence Miles 

Federal 294 298 

Private 60 0 

Tribal 0 2 

Total 354 300 

Source: CBP Facilities Management and Engineering Division 

CBP has used various designs and materials to construct this existing border 

fencing. Figure 1 illustrates each type of structure. 

Figure 1: Examples of Existing Barriers along the Southern Border 

Levee Wall Steel Bollard Vehicle Fence 

Landing Mat 

Fence 

topped with 

Concertina 

Wire 

Steel Mesh 

Fence 

topped with 

Concertina 

Wire 

Source: Photos taken by DHS Office of Inspector General (OIG) 

On January 25, 2017, the President issued Executive Order No.13767, Border 

Security and Immigration Enforcement Improvements (Executive Order). The 

Executive Order directed the Secretary of Homeland Security to take all 

appropriate steps to immediately plan, design, and construct a physical wall 

along the southern border, using appropriate materials and technology to most 

effectively achieve complete operational control of the southern border.3 

In response, then-Secretary John F. Kelly issued a memorandum instructing 

CBP to immediately begin planning, designing, constructing, and maintaining a 

wall along the land border with Mexico in the most appropriate locations. He 

also established the Executive Order Task Force (Task Force) to outline for DHS 

the action items needed to implement the Executive Order. CBP received 

funding to support accomplishment of the objectives of the Executive Order 

and its operational requirements. 

3 Executive Order 13767 defines operational control as the prevention of all unlawful entries 

into the United States, including entries by terrorists and other unlawful aliens, and 

instruments of terrorism, narcotics, and other contraband. 

www.oig.dhs.gov 2 OIG-20-52 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

CBP Wall Acquisition Program Establishment 

In March 2017, CBP’s Wall Acquisition Program was established as a DHS 

“Level 1” major acquisition program and was added to the DHS Major 

Acquisition Oversight List.4 As a major acquisition, the Wall Acquisition 

Program must follow government-wide acquisition regulations implemented 

through the DHS Acquisition Lifecycle Framework (ALF).5 The ALF is a fourphase review process DHS uses to determine whether to proceed with an 

acquisition. The four phases are: 

1. Need Phase – Define the problem; 

2. Analyze/Select Phase – Identify alternatives and resource requirements; 

3. Obtain Phase – Develop and evaluate capabilities; and 

4. Produce/Deploy/Support/Dispose Phase – Produce and maintain 

capabilities. 

Each phase in the ALF leads to an Acquisition Decision Event (ADE). An ADE 

is a predetermined point in the phase at which, before commencing the next 

phase, the acquisition undergoes a review.6 The review ensures that needs are 

aligned with DHS’ strategic direction and that upcoming phases are adequately 

planned. The border wall was to be constructed in segments, with each 

segment requiring approval of the necessary acquisition documents prior to the 

acquisition proceeding to the Obtain Phase. 

At the start of our review, CBP had entered the second phase of the ALF — the 

Analyze/Select Phase. The purpose of the Analyze/Select Phase is to 

determine the most effective and affordable way to fill the capability gap 

identified by the program in its “Mission Needs Statement,” which documented 

the functional capabilities CBP must have to effectively obtain operational 

control of the southern border. On May 3, 2019, CBP was granted permission 

to move to the Obtain Phase where it develops and evaluates capabilities for 

just the Rio Grande Valley sector wall project. Figure 2 depicts each lifecycle 

phase and acquisition event. 

4 The DHS Major Acquisition Oversight List identifies acquisition programs designated as Level 

1 or Level 2 acquisitions in accordance with the Acquisition Management Directive 102-01. 

Special interest programs or programs with lifecycle cost estimates exceeding $1 billion or 

services programs with an annual expenditure level exceeding $1 billion are designated as 

Level 1 programs. 

5 DHS Instruction 102-01-001, Rev 01.1, Acquisition Management Instruction, May 3, 2019 

6 The DHS Acquisition Review Board reviews Level 1 and 2 investments for proper 

management, oversight, accountability, and alignment to strategic functions of the 

Department. The Acquisition Review Board reviews investments before granting approval to 

proceed to the next phase of an acquisition. 

www.oig.dhs.gov 3 OIG-20-52 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 2: Four-Phase Acquisition Lifecycle Framework 

Source: DHS Instruction 102-01, Rev 01.1, Acquisition Management Instruction, May 3, 

2019 

CBP’s Wall Acquisition Program Results through July 2019 

Since May 2017, CBP has received over $12 billion to support procurement, 

construction, and improvements along the southern border through a 

combination of appropriations, the Treasury Forfeiture Fund and in 

reprogrammed funds from the Department of Defense (DOD).7 8 For summary 

of yearly appropriations, see appendix B. 

As of July 2019, CBP had expended $268 million of the $341 million 

appropriated in fiscal year 2017. According to CBP, the majority of work along 

the southern border was accomplished using FY 2017 funds. Specifically: 

x	 CBP obligated $292 million for a total of 40 miles of replacement wall in 

San Diego, El Centro, and El Paso Sectors. At the time of our review, 

CBP completed 39.5 of the 40 miles of new border wall in place of 

pedestrian fence and vehicle barrier in those sectors. 

x	 CBP also obligated $49 million to construct 35 border wall gates in the 

Rio Grande Valley Sector, which were under construction. 

Using FY 2018 funds, CBP completed 7.2 miles of approximately 80 miles of 

planned new and replacement border wall. Construction started in February 

7 10 United States Code (U.S.C.) § 284(b)(7) authorizes DOD to support the counterdrug 

activities of other Federal agencies, including DHS, with the construction of roads, fences, and 

lighting to block drug smuggling corridors across international boundaries. 

8 10 U.S.C. § 2808 authorizes the Secretary of Defense to determine whether border barriers 

are necessary to support the use of the armed forces and to re-direct unobligated DOD Military 

Construction funding to construct border barriers if required. 

www.oig.dhs.gov 4 OIG-20-52 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

2019 for about 14 miles of secondary wall replacement in San Diego Sector, 

and in April 2019 for 37 miles of primary wall replacement in San Diego and 

Calexico, California, and Yuma, Arizona. Anticipated construction completion 

for these projects is late 2020. Additionally, about 25 miles of new border wall 

and levee wall was planned for the Rio Grande Valley Sector with FY 2018 

funding. Construction activities started for about 13 miles of the new levee 

wall system in Rio Grande Valley Sector’s Hidalgo County with estimated 

completion dependent on availability of real estate. CBP expected to award a 

construction contract for the remaining 12 miles of new border wall system in 

Rio Grande Valley Sector’s Starr County by December 31, 2019. As of July 

2019, CBP had expended $36.7 million of the $1.375 billion appropriated in FY 

2018 for border wall construction. 

CBP also planned to supplement $1.375 billion in FY 2019 appropriations with 

$601 million from the Treasury Forfeiture Fund to construct 11 miles of new 

primary levee wall system and 74 miles of new border wall system in Rio 

Grande Valley Sector. On May 2019, CBP awarded a $42.9 million contract to 

construct approximately three miles of new border wall system Rio Grande 

Valley Sector that was scheduled to begin in August 2019. See appendix C for 

the status of CBP’s use of appropriated funds for construction of new and 

replacement border wall along the southern border as of July 2019. 

Table 2 shows CBP’s planned construction of new and replacement border wall 

along the southern border using funds received through FY 2019. 

Table 2: CBP Planned Border Wall Construction through FY 2019 

New 

Primary 

Wall 

New 

Primary

Levee 

Wall 

Primary Wall 

Replacement

(in place of 

dilapidated 

designs) 

Primary Wall 

Replacement

(in place of 

vehicle barrier) 

Secondary 

Wall 

Replacement 

(in place of 

dilapidated 

designs) 

Total 

86 miles* 24 miles 62–66 miles 144 miles 14 miles 330–334 

miles 

Source: CBP 

* Miles are approximate and as of June 14, 2019 

According to CBP, DOD plans to fund up to $2.5 billion pursuant to 10 U.S.C. 

§ 284(b)(7) in support of CBP requirements to construct up to 129 miles of new 

replacement wall in place of dilapidated or outdated designs and vehicle 

barrier, within Yuma, El Paso, El Centro, and Tucson Sectors. In March 2019, 

DOD authorized the U.S. Army Corps of Engineers to begin planning and 

executing up to $1 billion to build 57 miles of pedestrian fencing, construct 

and improve roads, and install lighting within the Yuma and El Paso Sectors. 

However, these projects were subject to a permanent injunction on June 28, 

www.oig.dhs.gov 5 OIG-20-52 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

2019.9 On appeal, the Ninth Circuit affirmed the district court’s permanent 

injunction and held that Section 8005 of the Department of Defense 

Appropriations Act of 2019, Pub. L. No. 115-245, 132 Stat. 2981 did not 

provide transfer authority for projects funded under 10 U.S.C. § 284.10 

Although work on these projects had continued because the Supreme Court 

previously granted the government’s application for stay of the district court 

injunction pending appeal in the Ninth Circuit,11 funding for these projects is 

now barred until the government petitions for a writ of certiorari, at which time 

the stay will continue until the Court enters judgement, or declines certiorari. 

This is our second report on CBP’s efforts to secure the southern border 

physically.12 We conducted this audit to determine to what extent CBP has 

executed the Analyze/Select Phase, the second phase of the Acquisition 

Lifecycle Framework, for the acquisition of the barrier along the southern 

border. 

Results of Audit 

CBP has not demonstrated the acquisition capabilities needed to execute the 

Analyze/Select Phase of the Wall Acquisition Program effectively. Specifically, 

CBP: 

x	 did not conduct an Analysis of Alternatives (AoA) to assess and select the 

most effective, appropriate, and affordable solutions to obtain operational 

control of the southern border as directed, but instead relied on prior 

outdated border solutions to identify materiel alternatives for meeting its 

mission requirement; and 

x	 did not use a sound, well-documented methodology to identify and 

prioritize investments in areas along the border that would best benefit 

from physical barriers. 

The Department also did not complete its plan to execute the strategy to obtain 

and maintain control of the southern border, as required by its Comprehensive 

Southern Border Security Study and Strategy.13 Without an AoA, a documented 

and reliable prioritization process, or a plan, the likelihood that CBP will be 

able to obtain and maintain complete operational control of the southern 

9 Sierra Club v. Trump, No. 19-cv-00892-HSG, 2019 WL 2715422 (N.D. Cal. Jun. 28, 2019)
 10 Sierra Club v. Trump, No. 19-16102 19-16300, 2020 WL 3478900, at *11 (9th Cir. Jun. 26,
 

2020) 

11 Trump v. Sierra Club, 140 S.Ct. 1 (2019)
 12 Special Report: Lessons Learned from Prior Reports on CBP’s SBI and Acquisitions Related to
 

Securing our Border, OIG -17-70-SR, June 12, 2017
 13 U.S. Department of Homeland Security Comprehensive Southern Border Security Study and 

Strategy, November 2017
 

www.oig.dhs.gov 6 OIG-20-52 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

border with mission effective, appropriate, and affordable solutions is 

diminished. 

CBP Did Not Conduct an Analysis of Alternatives to Assess All 

Possible Alternatives to Secure the Southern Border 

Although directed to do so by Congress and the Department, CBP did not 

conduct an AoA to assess and select the most effective, appropriate, and 

affordable solutions to obtain operational control of the southern border. 

Specifically, the Consolidated Appropriations Act of 2017 (Public Law 115-31) as 

well as subsequent appropriations, required the Department submit to the 

Committees on Appropriations of the Senate and the House of Representatives 

a risk-based plan for improving security along the borders of the United States, 

including the use of personnel, fencing, other forms of tactical infrastructure, 

and technology. The plan was to include a description of the methodology and 

analyses used to select specific resources for deployment to particular locations 

that included among other things an AoA, and comparative costs and benefit 

analysis.14 Additionally, DHS acquisition guidance requires programs to 

identify alternatives and resource requirements during this phase.15 As 

previously stated, this phase, called the Analyze/Select Phase, aims to 

determine the most effective and affordable way to obtain operational control of 

the southern border. 

Analysis of Alternatives Was Outdated 

An AoA is a fundamental step necessary to determine the optimal way to meet 

the requirement. This analysis aims to fully evaluate the cost, effectiveness, 

and risk of potential materiel alternatives to meet a mission requirement. 

According to CBP's Component Acquisition Executive, in 2008 CBP completed 

85 AoAs for all segments along the southern border. Based on the 2008 AoA 

results, CBP recommended a border wall as the most cost-effective option to 

fulfill its operational requirements at that time. However, we requested copies 

during our audit 10 years later, but CBP could not locate 59 of the 85 (69 

percent) AoAs. The remaining 26 AoAs CBP provided were limited in their 

usefulness because they did not reference the locations prioritized by Border 

Patrol for border wall investment. 

After reviewing the 26 AoAs, we concluded that the cost per mile to construct a 

border wall in 2008 was outdated. In the AoAs, CBP estimated that about 60 

14 Consolidated Appropriations Act, 2017, Public Law 115-31, May 5, 2017; 

Consolidated Appropriations Act, 2018, Public Law 115-141, March 23, 2018; and 

Consolidated Appropriations Act, 2019, Public Law 116-6, February 15, 2019 

15 DHS Instruction 102-01-001, Rev 01, Acquisition Management Instruction, March 9, 2016 

www.oig.dhs.gov 7 OIG-20-52 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

miles of new border wall would cost approximately $466 million, or $8 million 

per mile. However, in the 2017 Impedance and Denial Strategy, which includes 

Border Patrol’s priorities for deploying barriers and other assets along the 

southern border, Border Patrol estimated that completing construction in its 

17 priority groups would result in about 722 additional miles of new border 

wall at a cost of approximately $18 billion, or $25 million per mile.16 

Furthermore, according to the 26 AoAs, a border wall was less costly in the 

long run than additional agents. However, the outdated AoAs did not account 

for the hiring of 5,000 additional Border Patrol agents, as required by the 

President’s 2017 Executive Order. Additional Border Patrol agents can have a 

significant effect on border security as evidenced in a recent OIG report.17 For 

example, our report disclosed that moving agents out of mission support roles 

and returning them to their primary border enforcement duties resulted in an 

increase in apprehensions along the southern border. In response to the 

Executive Order, Border Patrol has taken steps to recruit additional agents. 

This constitutes a change that would be important to consider in completing 

updated AoAs. 

Instead of conducting a new AoA, CBP conducted an Alternatives Analysis to 

identify a type of physical barrier for each location prioritized in the 2017 

Impedance and Denial Strategy. However, this type of analysis is more limited 

than an AoA because it will only evaluate a specific solution, rather than a 

broader range of solutions, such as technologies or additional personnel. 

Fulfilling the direction to secure the southern border constitutes a significant 

investment. Without full and up-to-date AoAs, CBP cannot accurately identify 

the cost, effectiveness, and risk of potential materiel alternatives to meeting its 

mission requirement. 

Methodology for Identifying and Prioritizing Investments along 

the Southern Border Was Not Comprehensive 

Congress required the Department submit a risk-based plan for improving 

security along the U.S. border that identifies the planned locations, quantities, 

and types of resources. The plan must also include a description of the 

methodology and analyses used to select specific resources for deployment to 

particular locations. In its 2017 Impedance and Denial Strategy, Border Patrol 

documented its process for identifying and prioritizing impedance and denial 

16 Border Patrol divided the 9 southern border sectors into 197 segments, which it then 

organized into 33 groups. Each group consists of one or more segments.
 17 Border Patrol Needs a Staffing Model to Better Plan for Hiring More Agents, OIG-19-23,
 

February 28, 2019 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

investments along the southern border. Border Patrol intended for its process 

to lead to informed investments that achieve the greatest possible operational 

impact, are feasible in terms of constructability, and are scalable to available 

budgetary resources. However, Border Patrol did not use a sound methodology 

to identify and prioritize these investments. Border Patrol did not document its 

justification for re-ordered priority rankings for border wall construction, or 

how evaluation criteria were weighted. It also used only a single fiscal year of 

border activity data as a basis for prioritizing construction locations. Without a 

comprehensive, well-documented approach, Border Patrol cannot be certain it 

is making fully informed investment decisions and investing in border locations 

that could best benefit from physical barriers. 

Inadequate Justification for Prioritizing Locations for Wall Construction 

Border Patrol did not adequately justify its decisions to prioritize certain 

southern border locations over others for wall construction. To help evaluate 

and prioritize locations for investment, Border Patrol developed a decision 

support tool in a spreadsheet. Data in this tool comes from two existing 

sources — the Capability Gap Analysis Process, and the 2017 Southwest 

Capability Roadmap (Roadmap). Specifically: 

x In the Capability Gap Analysis Process, Border Patrol collected and 

managed capability and operational requirements by identifying 

resources (personnel, training, equipment, technology, and 

infrastructure) in each southern border sector that fell short of meeting 

required needs. 

x In the Roadmap, Border Patrol surveyed stations with border zones in 

their area of responsibility and identified the most important capabilities 

each station and sector needed. The Roadmap also identified areas of 

the border that might benefit from improved impedance and denial, 

domain awareness, and access and mobility. 

Using information from both of these processes, the decision support tool 

scored groups and ranked them 1 through 33 in priority for border wall 

construction.18 CBP’s Operational Review Board, comprised of CBP and Border 

Patrol subject matter experts, then considered the decision support tool 

rankings, along with broader operational concerns and intelligence reports, to 

establish a list of priority locations for border wall construction. However, the 

Board adjusted the rankings without documenting its rationale for prioritizing 

certain lower scoring southern border locations over those that the decision 

18 Border Patrol used this decision support tool to establish and score 197 segments of varying 

distances, across the 9 southern border sectors. Border Patrol organized these 197 segments 

into 33 groups for evaluation and prioritization. Each group consists of one or more segments 

that collectively promote greater operational control along the border. 

www.oig.dhs.gov 9 OIG-20-52 
 

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 -

 -

 -

 -

 -

 -

 -

 -

 -

 -

 -

 -

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

support tool had scored higher for investment in impedance and denial. For 

example, the Operational Review Board elevated San Diego Group D — a 

location that already has a dual-layer border wall system and had already 

received funding for primary wall replacement — to a higher priority. 

Specifically, the decision support tool ranked San Diego Group D as 12 of 33, 

although the Operational Review Board moved the group up to 4 of 33. 

Upon further analysis, we determined that border wall construction in San 

Diego Group D is not supported by CBP’s previous analyses or scheduled 

plans. First, neither the Roadmap, which cited the San Diego Sector as among 

the lowest priorities on the southern border for impedance and denial 

investment, nor the decision support tool’s evaluation of the sector supports 

wall construction. Second, border wall construction in the San Diego Sector is 

not supported by the Department’s 2017 Comprehensive Southern Border 

Security Study and Strategy to obtain and maintain operational control of the 

southern border, in which DHS assessed and categorized the sector’s risk level 

as low. Finally, under the Consolidated Appropriations Act, 2017, CBP had 

already scheduled about 14 miles of fence removal and replacement in San 

Diego Group D. Conversely, the decision support tool ranked El Centro Group 

X as the top priority for border wall construction, but the Operational Review 

Board moved El Centro Group X to 5 of 33. Figure 3 shows the Operational 

Review Board’s rankings compared to those of the decision support tool. 

Figure 3: Comparison of Sector Group Rankings 

Sector Group 

Decision Support Tool 

Ranking Overall Score 

(100%) 

Operational 

Review Board 

Ranking 

Decision 

Support Tool 

Ranking 

Change 

Rio Grande Valley Group C 79.71 

78.71 

77.81 

75.01 

81.25 

80.85 

79.78 

78.22 

78.05 

77.85 

77.65 

75.98 

74.90 

73.68 

73.58 

72.96 

71.51 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

4 

5 

9 

12 

1 

2 

3 

6 

7 

8 

10 

11 

13 

14 

15 

16 

17 

3 

3 

6 

8 

-4 

-4 

-4 

-2 

-2 

-2 

-1 

-1 

0 

0 

0 

0 

0 

Rio Grande Valley Group B 

Rio Grande Valley Group A 

San Diego Group D 

El Centro Group X 

Yuma - Group X 

Laredo Group A 

El Paso Group X 

El Centro Group A 

Yuma - Group B 

San Diego Group A 

Laredo Group C 

El Paso Group B 

El Paso Group C 

El Centro Group B 

Del Rio Group D 

Tucson - Group E 

Source: DHS OIG analysis of the decision support tool and Border Patrol’s Impedance and 

Denial Prioritization Strategy 

We asked Border Patrol to explain why the lower scoring southern border 

locations were prioritized over those that its decision support tool scored higher 

www.oig.dhs.gov 10 OIG-20-52 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

for investment in impedance and denial. In response, Border Patrol officials 

provided us a presentation that included the same justifications for investing in 

all 33 groups along the southern border as in the 2017 Impedance and Denial 

Strategy. But, they offered no further rationale for prioritizing for example San 

Diego Group D over the other groups. Documenting revisions to priority 

justification would help ensure that Border Patrol made sound decisions and 

selected and prioritized the most appropriate locations for border wall 

construction. 

Weighting of Decision Support Tool Criteria Was Not Explained 

Border Patrol did not provide rationale for how it weighted the criteria in its 

decision support tool for prioritizing wall construction locations. Federal 

Government standards call for management to clearly document internal 

controls, all transactions, and other significant events to allow documentation 

to be readily available for examination.19 Border Patrol’s 2017 Impedance and 

Denial Strategy outlined the evaluation criteria used in the decision support 

tool to score and prioritize impedance and denial investments along the 

southern border and the corresponding weights per the following: 

x ability to achieve strategic objectives (40 percent), 

x analysis of border census data (40 percent), and 

x operational and engineering feasibility considerations (20 percent). 

Using Border Patrol’s scoring process, weighting of the criteria greatly 

influenced the score of each border location. As such, Border Patrol should 

establish and document a clear rationale for the weights to provide more 

informative, transparent, and defensible investment decisions. For example, if 

the operational and engineering feasibility considerations criteria had been 

weighted more heavily than 20 percent, certain areas in the Rio Grande Valley 

Sector may not have scored as highly because these areas present unique 

feasibility challenges related to land acquisition and environmental 

requirements. Such challenges could inhibit construction and increase costs 

beyond available funding. Border Patrol officials said they weighted operational 

and engineering feasibility considerations lower than achieving strategic 

objectives and analysis of border census data because the tool focused on 

where the need is regardless of implementation. However, Border Patrol’s 

process for identifying and prioritizing investments along the southern border 

is supposed to result in fully informed investments that achieve the greatest 

possible operational impact, but are also feasible to implement. 

19 Standards for Internal Control in the Federal Government, GAO-14-704G, September 2014 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

These issues are magnified by CBP’s plans to rely solely on an analysis of types 

of physical barriers for all segments prioritized for improved impedance and 

denial, rather than completing an AoA, which might identify alternative 

solutions. Constructing a border wall may be a viable option for some 

locations, but in other locations non-construction alternatives may be more 

feasible, and may best help CBP achieve operational control of the southern 

border. 

Multi-year Border Activity Data Was Not Used to Support Investment 

Decisions 

Although Border Patrol recognizes that the threat along the southern border is 

dynamic, it used only the most recent complete year (FY 2016) of border 

activity data, such as drug seizures, apprehensions, and assaults on Border 

Patrol agents, to determine the locations with the greatest need for impedance 

and denial investment. According to Border Patrol officials, they considered 

using multi-year data but decided instead to use the most recent complete year 

of data in the decision support tool. However, they also said they would 

consider using multi-year data in their future assessments as they see the 

value in multi-year data and trends. 

Using multiyear data may help Border Patrol maximize the decision support 

tool's utility in addressing its mission needs by providing insights about trends 

and context not available from single year data. For example, if segment X 

experienced more illicit activity in FY 2016 than segment Y, the decision 

support tool would score segment X higher based on information from just that 

single year. However, using data from multiple years might show illicit activity 

trending upward in segment Y and downward in segment X, providing more 

insight and fuller context to better inform Border Patrol’s prioritization and 

investment decisions. 

Inadequate Planning for Operational Control of the Southern 

Border 

A lack of detailed planning to help guide acquisition management efforts may 

be a contributor to the deficiencies we identified in the Analyze/Select Phase of 

the Wall Acquisition Program. Specifically, the Department has not conducted 

adequate planning for ensuring southern border security. Executive Order 

13767 required the Department to conduct a comprehensive study of the 

southern border’s security, including a strategy to obtain and maintain 

complete operational control. This study was due 180 days from the issuance 

of the Executive Order, or on July 24, 2017. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In response to these requirements, the Department submitted the 

Comprehensive Southern Border Study and Strategy 4 months after the 180-day 

deadline. The study included information on all geophysical and topographical 

aspects of the southern border, the availability of Federal and state resources 

necessary to achieve complete operational control of the southern border, and a 

strategy to obtain and maintain complete operational control of the southern 

border. The strategy included three general goals and objectives: 

x securing the southern border and approaches; 

x dismantling transnational criminal organizations; and 

x deterring flow of illegal entries through consequence delivery, benefit 

adjudication, interior enforcement, and partner engagement. 

To achieve these goals and objectives, the Department reported it planned to 

deploy physical barriers and personnel to high-risk areas; position security and 

response assets to prevent, detect, and defeat threats as far forward of the 

physical border as possible; and improve domain awareness using state-of-theart technology and operational assets, such as radar towers, cameras, aircraft, 

ships, and vehicles. 

However, the study was not accompanied by an implementation plan, as 

required. To execute the strategy described in the study, the DHS Office of 

Strategy, Policy, and Plans was to complete, with components including CBP 

and the Under Secretary for Management, a joint implementation plan. As of 

September 2019, the Department had neither finalized nor submitted an 

implementation plan. According to officials in the Office of Strategy, Policy, 

and Plans, they have not been involved or tasked to help with this action. 

Without an implementation plan, the Department cannot ensure it will fulfill its 

mission requirements with effective, appropriate, and affordable solutions. 

Conclusion 

CBP has not fully demonstrated that it possesses the capability to potentially 

spend billions of dollars to execute a large-scale acquisition to secure the 

southern border. The majority of work along the southern border so far has 

been accomplished using FY 2017 appropriations. As of July 2019, CBP had 

expended $268 million of the $341 million appropriated in FY 2017 to replace 

39.5 miles of fencing. CBP also had expended $36.7 million of $1.375 billion 

appropriated to install or replace 7.2 of approximately 80 miles of border wall 

in FY 2018. In FY 2019, $6.7 billion of DOD funds were reprogrammed for 

border construction. 

Given the challenges we identified through our lessons learned review, CBP’s 

inability to effectively guide this large-scale effort poses significant risk of 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

exponentially increased costs.20 Until it takes corrective action to improve its 

acquisition planning and management, CBP will remain challenged as in the 

past; any future initiative may take longer than planned, cost more than 

expected, and deliver less capability than envisioned to secure the southern 

border. 

Recommendations 

Recommendation 1: We recommend the Under Secretary for Management of 

DHS require CBP to conduct an up-to-date independent Analysis of 

Alternatives to identify the most appropriate and effective solutions to obtain 

complete operational control of the southern border. 

Recommendation 2: We recommend Border Patrol revise its methodology for 

prioritizing southern border investments to include: 

x a comprehensive justification for the Operational Review Board’s final 

group rankings for southern border investment; 

x a rationale for the weights assigned to the decision support tool’s 

evaluation criteria; 

x multi-year border activity data in the decision support tool; and 

x documenting any deviation from the decision support tool results. 

Recommendation 3: We recommend the Office of Strategy, Policy, and Plans 

for DHS determine the need for an implementation plan for obtaining and 

maintaining complete operational control of the southern border, as instructed 

by the Comprehensive Southern Border Security Study and Strategy. 

Management Comments and OIG Analysis 

The Department provided formal written comments in response to a draft of 

this report. We have included a copy of the Department’s response in its 

entirety in appendix D. The Department concurred with one recommendation, 

but did not concur with the remaining two. Additionally, the Department 

raised concerns about conclusions and assertions within our report. 

First, the Department claimed that we overlook CBP’s role as an agency under 

the executive branch of the government. The Department claimed we “seem to 

chastise” CBP and DHS for not undertaking actions to explicitly violate 

language in the Executive Order — namely, actions other than immediately 

constructing a border wall. Although we recognize our report is critical of 

20 Special Report: Lessons Learned from Prior Reports on CBP’s SBI and Acquisitions Related to 

Securing our Border, OIG -17-70-SR, June 12, 2017 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

CBP’s and the Department’s implementation of the Executive Order, our 

criticism is appropriate considering the cost and scope of a project as large as 

the construction of the southern border wall. We recognize the Department’s 

explicit, required role in the construction of the border wall in accordance with 

the Executive Order. However, DHS’ lead in implementing the construction of 

the border wall does not exempt the Department from following congressional 

requirements and established acquisition practices to safeguard taxpayers 

dollars from fraud, waste, and abuse. The Department can fully and 

successfully comply with the Executive Order while also adhering to these 

acquisition controls. 

Second, DHS claimed the purpose or objective of our audit is misaligned with 

the conclusions and recommendations contained within the report. 

Specifically, the Department stated that our report “pivots” from the original 

purpose of determining the extent to which CBP executed the Analyze/Select 

phase of the acquisition lifecycle framework for the acquisition of the barrier for 

the southern border to focus on CBP’s efforts to gain operational control of the 

southern border. DHS argued that the physical barrier constitutes an element 

of impedance and denial, which is only one of three aspects that comprise 

operational control. 

We recognize that implementing impedance and denial solutions are only a 

part of gaining operational control of the southern border. However, border 

wall construction was to be in the most appropriate locations to effectively 

achieve operational control of the border. This is significant because our 

review of Border Patrol’s Capability Gap Analysis Process for stations that have 

border zones within their areas of responsibility did not always identify 

impedance and denial as a need for securing the southern border. Specifically, 

three stations prioritized for border wall construction did not identify 

impedance and denial as a capability need. In fact, the capability needs most 

often identified for operational control of the southern border were domain 

awareness, followed by human capital management, mission readiness, and 

security partnerships. 

Third, the Department took issue with our analysis and discussion of CBP’s 

use of an AoA versus an Alternatives Analysis. Specifically, CBP claims that it 

did not conduct an AoA to select the most effective, appropriate, and affordable 

solution to obtain operational control of the southern border because it would 

have been inappropriate to do so. According to CBP, it conducted an extensive 

review on how best to provide impedance and denial when it previously built 

several hundred miles of barrier. This past analysis conclusively showed that 

the only cost-effective approach to impedance and denial was through the use 

of a physical barrier. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

As discussed in our report, CBP completed an AoA in 2008 for all segments 

along the southern border and recommended a border wall as the most costeffective option to fulfill its operational requirements at that time. However, we 

found those AoA to be outdated. We also concluded that CBP’s decision to use 

prior AoAs was not responsive to the DHS Executive Order Implementation 

Plan (IPLAN) and to congressional appropriations requirements for an AoA. 

Contrary to the Department’s assertion, conducting an AoA would not violate 

the Executive Order. An AoA would support the solutions most appropriate for 

prioritized locations along the southern border while also being responsive to 

congressional appropriation requirements. 

Lastly, the Department emphasized that this audit took 34 months to 

complete. Although we recognize the length of the audit timeline, the purpose 

of the OIG remains, as established in the Inspector General Act of 1978 as 

amended. Our purpose, in part, is to conduct and supervise audits related to 

agency programs and operations; to recommend policies for activities designed 

to promote economy, efficiency, and effectiveness; and to prevent and detect 

fraud and abuse. Our work keeps the Department and the Congress fully and 

currently informed about problems and deficiencies related to the 

administration of such programs and operations as well as the necessity for, 

and progress of, corrective action. Border wall construction remains a 

significant, high-cost work in progress in need of oversight. As such, we 

believe our report provides value to the Department, Congress, and the public. 

We also received technical comments from the Department and made revisions 

to the report where appropriate. We consider the three recommendations 

unresolved and open. A summary of the Department’s responses and our 

analysis follows. 

DHS Response to Recommendation 1: Non-concur. According to the 

Department, the CBP Wall Acquisition Program appropriately conducted an 

Alternatives Analysis in accordance with DHS Acquisition Management 

Directive 102-01, its implementing instruction, and other related guidance. 

The Alternatives Analysis examined performance characteristics of alternative 

ways to implement the material solution of creating a physical barrier in 

accordance with Executive Order 13767. The Department added that the CBP 

Wall Acquisition Program addressed impedance and denial capabilities as 

stated in the Mission Need Statement, not operational control. 

DHS indicated conducting an AoA of solutions to obtain complete operational 

control of the southern border was neither appropriate nor necessary. 

Alternatives for operational control of the southern border are not generally 

considered through an AoA, nor under the authority of the DHS Under 

Secretary for Management. Instead, reviews of these types of alternatives are 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

conducted through strategic and operational evaluations, such as the Border 

Security Improvement Plan, which was required pursuant to language set forth 

in the DHS Appropriations Act of 2018. The alternatives considered through 

this strategic and operational review process were considered in a 

complementary fashion via CBP’s layered enforcement strategy and through 

the Requirements, Acquisition, and Planning, Programming, Budgeting, 

Execution processes. Additionally, DHS’ Chief Acquisition Officer required that 

CBP further document the rationale for its integrated system architecture. 

This deliverable will further portray the complementary nature of the integrated 

systems planned to support operational control of the southern border. 

Estimated Completion Date: January 31, 2021. 

OIG Analysis: We do not agree with the Department’s conclusion that the CBP 

Wall Acquisition Program properly followed instruction and other related 

guidance. We also disagree with the Department’s assertion that conducting 

an AoA of solutions is neither appropriate nor necessary to obtain complete 

operational control of the southern border. The IPLAN identified and 

instructed lead components responsible for executing tasks to implement the 

executive orders. It also established responsibilities for activities the 

Department must perform for this broad unity of effort and strategy to succeed. 

Specifically, the IPLAN tasked CBP with ensuring compliance with DHS 

Management Directive 102, including completing an AoA to include an analysis 

of costs, benefits, and effectiveness of existing fencing. 

Additionally, the Consolidated Appropriations Act of 2017 (Public Law 115-31) 

as well as subsequent appropriations, required the Department to submit to 

the Committees on Appropriations of the Senate and the House of 

Representatives a risk-based plan for improving security along the borders of 

the United States, including the use of personnel, fencing, other forms of 

tactical infrastructure, and technology. The plan was to include a description 

of the methodology and analyses used to select specific resources for 

deployment to particular locations that included, among other things, an AoA 

and comparative costs and benefits. The Department’s Border Security 

Improvement Plan was developed pursuant to language set forth in the 

Appropriations Act. However, an AoA was not completed. 

We consider this recommendation unresolved. It will remain open until CBP 

provides an estimated completion date along with a corrective action plan to 

conduct an AoA identifying appropriate and effective solutions to obtain 

complete operational control of the southern border or provides evidence that it 

has satisfied its congressional requirement. 

DHS Response to Recommendation 2: Concur. The Department stated that 

the Chief of Border Patrol addressed the recommended enhancements as a 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

result of a U.S. Government Accountability Office audit report,21 and an 

independent verification and validation analysis. Enhancements to the process 

included improving the documentation associated with quantitative and 

qualitative data input into the decision support tool, weighting, and 

calculations to assess the most operationally effective location for the border 

wall. Border Patrol removed feasibility to avoid skewing operational 

prioritization with nonoperational data. Feasibility, however, remains an 

important aspect, which was addressed after the prioritization, as a part of 

DHS Acquisition Management Directive 102-01. 

Border Patrol assessed 198 segments of border wall requirements that were not 

funded as of June 30, 2019, scoring segments individually according to the 

updated decision support tool methodology. These segments were then 

combined into 31 groups that collectively promoted operational control. Border 

Patrol convened an Operational Review Board on May 8, 2019. The 

Operational Review Board, comprised of executive leadership, reviewed and 

validated the decision support tool’s results, making some minor adjustments 

to the prioritization and applying and documenting a border-wide perspective. 

On June 21, 2019, the Chief of Border Patrol was briefed on the outcomes and 

approved the Operational Review Board’s priority list. 

The Department, however, clarified that Border Patrol will not be using multiyear operational data given the dynamic and changing environment in which it 

operates. Instead, Border Patrol needs to utilize the most recent information 

and threat data to adequately assess requirements needs. DHS requested the 

recommendation be closed as implemented upon issuance of the final report. 

OIG Analysis: Although the Department concurred with the recommendation, 

we find Border Patrol’s actions do not meet the intent of the recommendation. 

Border Patrol has taken steps to enhance the selection process for prioritizing 

southern border investments. Enhancements to the decision support tool, 

which is used to prioritize locations for investment though a scoring process, 

included improving the documentation associated with the quantitative and 

qualitative data input, weighting, and calculations to assess the most 

operationally effective locations for the border wall. However, these stated 

enhancements do not include the Operational Review Board’s documented 

justification for deviating from the decision support tool’s results. 

Additionally, we disagree with Border Patrol’s decision not to use multi-year 

border activity data. As presented in our report and confirmed in the 

Department’s formal written comments, activity along the southern border is 

dynamic and constantly changing. Using multiyear data helps Border Patrol 

21 Southwest Border Security: CBP Is Evaluating Designs and Locations for Border Barriers but Is 

Proceeding Without Key Information, GAO-18-614, July 30, 2018 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

maximize the decision support tool's utility to obtain operational control by 

providing insights about trends and context not available from single year data. 

Using multi-year data would provide additional insight and fuller context to 

inform Border Patrol’s prioritization and investment decisions, while also 

minimizing the likelihood of the Operational Review Board making significant 

adjustments to the decision support tool’s priority rankings. Refining the 

prioritization methodology to include multi-year data in the decision support 

tool would also account for changes in illegal entry traffic patterns as CBP 

constructs new border wall. 

We consider this recommendation unresolved. It will remain open until Border 

Patrol provides an estimated completion date along with updates and 

documentary evidence that these enhancements were completed and 

implemented. 

DHS Response to Recommendation 3: Non-concur. The Department 

disagrees with our conclusion that “[w]ithout an implementation plan the 

Department cannot ensure it will fulfill its mission requirements with effective, 

appropriate, and affordable solutions.” According to DHS, the DHS Executive 

Order Implementation Plan (IPLAN), dated March 1, 2018, is exactly the 

implementation plan the Secretary directed to be created in order to unify the 

disparate and broad requirements and tasks embodied within multiple related 

national security Executive Orders and supplemental guidance. The IPLAN 

established responsibilities for the remaining activities that the Department 

must perform for this broad unity of effort and strategy to succeed. 

The Department also stated that the Border Security Improvement Plan 

provided more detail to guide wall acquisition than the IPLAN could have. Of 

necessity, a Department implementation plan such as the IPLAN is a high-level 

guidance document that does not provide the details to influence an AoA or 

revision to Border Patrol’s methodology for prioritizing southern border 

investments. The Department concluded that it made very little sense as a 

matter of appropriate resource management or logic for the Office of Strategy, 

Policy, and Plans in 2020 to retrospectively determine the need for an 

implementation plan for efforts successfully ongoing since January 2017. The 

Department requested the recommendation be closed as implemented upon 

issuance of the final report. 

OIG Analysis: During the course of our audit we had numerous written 

exchanges with the Strategy and Analysis team within the Office of Strategy, 

Policy, and Plans. Through these exchanges, we confirmed that the 

Department never produced an implementation plan for its Comprehensive 

Southern Border Study and Strategy. The Strategy and Analysis team’s 

misrepresentation of the IPLAN as exactly the implementation plan required by 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the Comprehensive Southern Border Study and Strategy highlights the 

Department’s ongoing struggle with providing appropriate documentation, 

which reduces program auditability and extends audit timelines. The inability 

to prepare and provide appropriate documentation also inhibits the ability to 

determine and assign accountability by Department decision makers. The 

IPLAN assigned lead and support components responsible for executing tasks 

to implement the Executive Orders. Among the tasks articulated in the IPLAN 

was ensuring that DHS Headquarters produce a final draft of the 

Comprehensive Southern Border Security Study and Strategy. However, the 

Department now claims that the IPLAN is an implementation plan of that same 

Comprehensive Southern Border Security Study and Strategy. 

The Department also indicated in its response that the Border Security 

Improvement Plan provides more detail to guide wall acquisition than the 

IPLAN could. The Border Security Improvement Plan was developed in 

accordance with the Consolidated Appropriations Act of 2017 (Public Law 115-

31). However, the Department did not explain how the Border Security 

Improvement Plan satisfies the requirement for an implementation plan called 

for in the Comprehensive Southern Border Security Study and Strategy. To 

state otherwise in our opinion, is misleading. 

We disagree with the Department’s conclusion that it makes very little sense as 

a matter of appropriate resource management or logic to retrospectively 

determine the need for an implementation plan to execute the approach 

identified in the Comprehensive Southern Border Study and Strategy. The 

Comprehensive Strategy’s implementation plan was to include baselines to 

monitor implementation and progress as well as an impact analysis for DHS to 

adjust its approach to ensure that resources were optimally applied to securing 

the border. Although the Department referenced other documents that it 

created to meet the requirements of Executive Order 13767, the Comprehensive 

Strategy’s implementation plan was to ensure the right capability was deployed 

to secure the southern border. We consider this recommendation unresolved. 

It will remain open pending further review and clarification of the Department’s 

next steps to determine the need for an implementation plan to execute the 

Comprehensive Southern Border Security Study and Strategy. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

Department of Homeland Security Office of Inspector General was established 

by the Homeland Security Act of 2002 (Public Law 107−296) by amendment to 

the Inspector General Act of 1978. 

We conducted this audit to determine to what extent CBP has executed the 

Analyze/Select Phase, the second phase of the ALF, for the acquisition of the 

barrier along the southern border. Specifically, we (1) determined to what 

extent CBP identified the alternatives to select the most appropriate solution 

and locations to effectively and efficiently achieve operational control, (2) 

determined to what extent CBP and Border Patrol supported its decision 

making, and (3) assessed to what extent the Department developed and 

implemented a strategy to obtain complete operational control of the southern 

border. 

To accomplish our objective, we obtained and reviewed pertinent Federal, DHS, 

CBP, and Border Patrol specific regulations, policies, procedures, and guidance 

relevant to the Analyze/Select Phase of the Wall Acquisition Program. We 

reviewed prior DHS OIG and GAO reports, the Department’s Comprehensive 

Southern Border Security Study and Strategy, and the Department’s Border 

Security Improvement Plan. We reviewed acquisition documents produced 

during the Need Phase, such as the Mission Need Statement and the Capability 

Development Plan. We interviewed representatives of DHS’ Joint Requirements 

Council and CBP’s Component Acquisition Executive. We also met with Border 

Patrol officials and staff responsible for management and oversight of the Wall 

Acquisition Program as well as the Border Patrol’s Enforcement Systems 

Division. 

To determine relevant executive and departmental guidance, we reviewed the 

requirements set forth in Executive Order 13767 and then-DHS Secretary John 

F. Kelly’s implementation memo. To assess whether CBP followed the 

appropriate acquisition steps, we compiled pertinent Federal and departmental 

regulations, policies, procedures, and guidance relevant to DHS acquisitions. 

To verify compliance with DHS acquisitions policy, we reviewed acquisition 

documents, including the Requirements Decision and Action Memorandum, 

Acquisition Decision Memorandum, the Concept of Operations for Impedance 

and Denial, Preliminary Operational Requirements Document for Impedance 

and Denial, the Border Wall System Program Cost Estimating Baseline 

Document, and the Acquisition Plan produced during the Analyze/Select Phase 

of the Wall Acquisition Program. We interviewed DHS, CBP, and Border Patrol 

officials responsible for recommending a solution to fulfill the capability gap in 

the southern border and analyzed the requirements set forth in Public Law 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

115–31 and the DHS Executive Order Implementation Plan. We obtained and 

analyzed the letter from the U.S. Senate Committee on Appropriations 

requesting that the Department complete an AoA. We obtained and assessed 

26 of the 85 AoAs that CBP developed during the Secure Border Initiative 

Network (SBInet) to determine whether the estimated cost included in the 

analysis was comparable to the estimated cost in the Wall Acquisition Program 

and assessed the cost estimate’s accuracy. 

To verify Border Patrol’s capability development need, we reviewed FY 2016 

Capability Gap Analysis Process (CGAP) reports from four of the nine Sectors 

along the southern border. We judgmentally selected San Diego, El Centro, 

Yuma, and Rio Grande Valley Sectors because (1) the decision support tool 

ranked El Centro and Yuma highest, (2) CBP prioritized San Diego and Rio 

Grande Valley for FY 2018 border wall funding, and (3) the Operational Review 

Board ranked these four sectors highest. We selected FY 2016 CGAP reports 

because they were current during the creation of the Roadmap, the decision 

support tool, and CBP’s FY 2018 Budget Request (the 2017 CGAP was not 

completed until September 2017). We obtained the CGAP reports directly from 

Border Patrol’s Webtool, which is the system of record for Border Patrol’s sector 

and station CGAP reports. We also examined Capabilities, Objective Measures, 

Resources, Evaluative Methods cards submitted by stations located in El 

Centro, Rio Grande Valley, San Diego, and Yuma Border Sectors. Specifically, 

we reviewed 190 - FY 2016 cards from 13 of the 16 stations that have border 

zones within their area of responsibility located in the four judgmentally 

selected sectors. 

We conducted site visits to the four judgmentally selected sectors and 

interviewed Sector Chiefs, station patrol agents-in-charge, and the Sector 

Strategic Planning Teams, who were involved in the CGAP process. We 

assessed the reliability of the CGAP data by contacting the Strategic Planning 

Officers in El Centro, Rio Grande Valley, and San Diego to verify the 

completeness of CGAP reports. We also compared the sector to station 

Capabilities, Objective Measures, Resources, Evaluative Methods cards to 

confirm that the capability gaps identified matched between the sector and 

stations. We determined the CGAP reports were sufficiently reliable for the 

purposes of this report. We also toured the southern border, observed the 

prototypes in San Diego, and examined the various types of barriers to 

determine how terrain influences barrier types appropriate to each location. 

To assess the Roadmap, we analyzed the instructions provided to the 9 Border 

Patrol sectors and 47 Border Patrol stations along the southern border. We 

then met with Border Patrol’s Operational Requirements Management Division 

to understand the methodology for the statistical information contained in the 

document. We compared relevant data included in the Roadmap to Border 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Patrol’s prioritized locations for border wall and found variances. However, we 

considered them immaterial for the purposes of our report. 

To understand the decision support tool, we met with Operational 

Requirements Management Division and contractor staff. We also analyzed the 

decision support tool’s evaluation criteria, the segments scoring and ranking, 

and the qualitative and quantitative details. To determine whether the decision 

support tool was consistent with standards for internal control requirements, 

we compared the supporting documentation of the evaluation criteria and its 

weights and sub-weights to the standards. We also reviewed source 

documents used to populate the decision support tool from three southern 

border Sectors to determine whether the decision support tool considered the 

impact of scheduled work funded from prior year appropriations on the 

southern border. In their submissions, Border Patrol sectors identified 

whether scheduled work will be ongoing in their area of responsibility. 

To assess the reliability of the decision support tool, we performed comparative 

analyses of the quantitative and qualitative data. We compared the decision 

support tools quantitative data to data in the Border Patrol Enterprise 

Reporting Tool and to data obtained directly from Border Patrol stations. 

Although we found slight variances, we determined the decision support tool 

data was sufficiently reliable for the purposes of this report. We also compared 

the qualitative data to the results of the CGAP reports. Specifically, we 

identified locations with capability gaps that related to “impedance and denial,” 

and we reviewed the scores for these locations in the decision support tool that 

related to the ability to impede and deny. 

We conducted this performance audit between June 2017 and September 2019 

pursuant to the Inspector General Act of 1978, as amended, and according to 

generally accepted government auditing standards (GAGAS). GAGAS 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

CBP Funding for Procurement, Construction, and

Improvements along the Southern Border 

Fiscal 

Year Appropriated Amount 

201722 $497.4 

Million* 

x $341.2 million to replace approximately 40 miles of existing primary 

pedestrian and vehicle border fencing along the southwest border, and to 

add gates to existing barriers; 

x $78.8 million for acquisition and deployment of border security technology; 

and 

x $77.4 million for new border road construction. 

201823 $1.5 

Billion 

x $251 million for approximately 14 miles of secondary fencing along the 

southwest border in the San Diego Sector; 

x $445 million for 25 miles of primary pedestrian levee fencing along the 

southwest border in the Rio Grande Valley Sector; 

x $196 million for primary pedestrian fencing along the southwest border in 

the Rio Grande Valley Sector; 

x $445 million for replacement of existing primary pedestrian fencing along 

the southwest border; 

x $38 million for border barrier planning and design; and 

x $196 million for acquisition and deployment of border security technology. 

201924 

$2.3 

Billion 

x $1.375 billion for the construction of primary pedestrian fencing, including 

levee pedestrian fencing, in the Rio Grande Valley Sector; 

x $725 million for the acquisition and deployment of border security 

technologies and trade and travel assets and infrastructure; and 

x $270.2 million for construction and facility improvements and 

humanitarian needs. 

$6.7 

Billion** 

x about $601 million from the Treasury Forfeiture Fund; 

x up to $2.5 billion under DOD funds transferred for support for counterdrug 

activities (10 U.S.C. 284); and 

x up to $3.6 billion reallocated from DOD military construction projects 

under the President’s declaration of a national emergency (10 U.S.C. 2808). 

202025 $1.9 

Billion 

x $1.375 billion for the construction of barrier system along the southern 

border; 

x $221.9 million for the acquisition and deployment of border security 

technologies and trade and travel assets and infrastructure; 

x $62.3 million for facility construction and improvements; 

x $199.5 million for integrated operations assets and infrastructure; and 

x $45.6 million for mission support and infrastructure. 

Source: DHS OIG analysis of 2017, 2018, 2019, and 2020 Consolidated Appropriations Act 

*Amount does not include appropriations for border security assets and infrastructure 

**Upon signing the FY 2019 appropriations bill into law in February 2019, the President 

identified about $6.7 billion in funds that could be re-programmed, primarily from DOD. 

22 Consolidated Appropriations Act, 2017, Public Law 115-31, May 5, 2017 23 Consolidated Appropriations Act, 2018, Public Law 115-141, March 23, 2018 24 Consolidated Appropriations Act, 2019, Public Law 116-6, February 15, 2019 25 Consolidated Appropriations Act, 2020, Public Law 116-93, December 20, 2019 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Status of Border Wall Construction as of July 2019 

Type of Barrier and 

Location 

FY 2017 Appropriations: 

Replace approximately 

40 miles of existing 

primary pedestrian and 

vehicle border fencing 

along the southern 

border 

FY 2018 Appropriations: 

14 miles of secondary 

wall replacement in San 

Diego Sector 

Amount 

Appropriated 

$341 million 

$251 million 

x

x

x

Funded work 

40 miles of new wall replacement in San 

Diego, El Centro, and El Paso Sectors. 

Construction underway for 35 border wall 

gates in the Rio Grande Valley Sector. 

Construction started in February 2019. 

25 miles of new border 

wall and levee wall in 

Rio Grande Valley 

Sector 

$445 million x

x

Construction activities have started for 

approximately 13 miles of new levee wall 

system in Hidalgo County. Estimated 

completion will depend on availability of real 

estate. 

An additional 12 miles of new border wall 

system located in Starr County is set for 

award by December 31, 2019. 

Primary pedestrian 

fencing in Rio Grande 

Valley Sector 

$196 million x No work to date. 

Replacement of existing 

primary pedestrian 

fencing along the 

southern border 

FY 2019 Appropriations: 

Construction of primary 

pedestrian fencing, 

including levee 

pedestrian fencing, in 

the Rio Grande Valley 

Sector 

$445 million 

$1.375 billion* 

x

x

Construction started in April 2019 for 

approximately 37 miles of new border wall in 

place of dilapidated and outdated designs in 

San Diego and Calexico, California, and 

Yuma, Arizona. 

Contract awarded May 2019 to construct 

approximately three miles of new bollard wall 

system within Rio Grande Valley Sector’s Rio 

Grande City Border Patrol Station area of 

responsibility. Construction is anticipated to 

begin in 2019. 

Source: DHS OIG analysis of 2017, 2018, and 2019 Consolidated Appropriations Act and CBP's 

status update of border wall construction. 

* Amount does not include funds from the Treasury Forfeiture Fund or 10 U.S.C. § 284(b)(7) 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

DHS Comments to the Draft Report 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Under Secretary, Office of Strategy, Policy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

CBP Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 34 OIG-20-52 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305