Department of Homeland Security 

Office of Inspector General 

U.S. Customs and Border Protection’s 
 


Ground Transportation of Detainees 
 


OIG-11-27 January 2011 
Office ofInspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security JAN 11 2011 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (DIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the effectiveness of U.S. Customs and Border Protection's efforts to 

create a plan to provide efficient ground transportation for detainees. It is based on 

interviews with employees and officials of relevant agencies and institutions, direct 

observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all ofthose who contributed to the preparation of this report. 

Anne 

~~~ L. Richards 

Assistant Inspector General for Audits 
 

Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 
 

Background..........................................................................................................................2 
 


Results of Audit ...................................................................................................................3 
 


CBP Does Not Have a Comprehensive Approach for 
 

Determining Transportation Needs................................................................................3 
 

CBP Did Not Provide Adequate Oversight of the Transportation PMO.......................6 
 


CBP Is Ill-prepared to Make Long-Term Transportation Decisions .............................7 
 


Recommendations..........................................................................................................7 
 


Management Comments and OIG Analysis ..................................................................8 
 


Appendices 

Appendix A: Purpose, Scope, and Methodology.......................................................11 
 


Appendix B: Management Comments to the Draft Report.......................................13 
 


Appendix C: Detainee Transportation Process..........................................................16 
 


Appendix D: Major Contributors to This Report ......................................................17 
 


Appendix E: Report Distribution ..............................................................................18 
 


Abbreviations 

CBP U.S. Customs and Border Protection 
 


DHS Department of Homeland Security 
 


FY Fiscal Year 
 


ICE U.S. Immigration and Customs Enforcement 
 


OIG Office of Inspector General 
 


PMO Program Management Office 
 

OIG
 
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

U.S. Customs and Border Protection is responsible for securing the 

Nation’s borders while facilitating legitimate trade and travel. The 

agency often requires transportation services for illegal aliens 

apprehended at or between U.S. ports of entry. This includes 

medical escort, transport to U.S. Immigration and Customs 

Enforcement facilities, and transport to and from local jails and 

courts. Our objective was to determine whether the U.S. Customs 

and Border Protection Transportation Program Management Office 

developed an effective plan to provide efficient and cost effective 

ground transportation for detainees. 

The U.S. Customs and Border Protection Transportation Program 

Management Office has not developed an effective plan to provide 

efficient and cost effective ground transportation for detainees. It 

has not developed a comprehensive approach for identifying and 

evaluating current transportation uses and therefore has been 

unable to develop a model to predict future transportation 

requirements. U.S. Customs and Border Protection has not clearly 

defined the scope and authority of the Transportation Program 

Management Office or provided sufficient management and 

oversight of the office to ensure that it accomplished its mission. 

U.S. Customs and Border Protection has spent more than 

$229 million on transportation services and the Transportation 

Program Management Office since August 2006. Without a 

thorough evaluation of the current uses and future requirements for 

transportation services, U.S. Customs and Border Protection is illprepared to make an informed long-term decision for transportation 

services when the existing transportation contract expires in August 

2011. 

We are making two recommendations that, if implemented, would 

help U.S. Customs and Border Protection’s efforts in identifying 

and implementing comprehensive ground transportation solutions. 

The U.S. Customs and Border Protection concurred with both 

recommendations and has begun to formulate plans and initiate 

actions to address the recommendations. 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 

Page 1
 
Background 

U.S. Customs and Border Protection (CBP) is responsible for 

securing the Nation’s borders while facilitating legitimate trade 

and travel. Within CBP, the Office of Field Operations (Field 

Operations) relies on Customs and Border Protection Officers 

(officers) for the security and flow of people and cargo at ports of 

entry, whereas the Office of Border Patrol (Border Patrol) relies on 

Border Patrol Agents (agents) for maintaining border security 

between ports of entry. 

Field Operations and the Border Patrol often require transportation 

services. These services include transporting illegal aliens 

apprehended at or between the ports of entry to medical facilities, 

to U.S. Immigration and Customs Enforcement (ICE) facilities, 

and to and from local jails and courts. Appendix C contains more 

details on the transportation of detainees. 

In 2004, the Undersecretary for Border and Transportation 

Security issued a memorandum instructing that the apprehending 

agency is responsible for all costs associated with the care and 

custody of aliens until they are turned over to ICE. ICE initially 

provided CBP with 170 agents to perform transportation services. 

In 2006, ICE recalled its agents to comply with the memorandum. 

In August 2006, CBP awarded a transportation contract that 

provided support to CBP sectors and ports along the Southwest 

Border. The 5-year contract was intended as a stopgap measure to 

allow the agency the opportunity to identify alternative solutions 

during a transition period. The initial budget for the contract was 

$50 million, funded through an interagency agreement with ICE. 

In March 2007, the Secure Border Initiative created the detainee 

Transportation Program Management Office (PMO) to oversee the 

detainee transportation contract and develop a more efficient 

transportation solution at and between border ports of entry. In 

fiscal year (FY) 2008, the budget for the contract and the 

Transportation PMO was $75 million, which increased to 

$83 million per year in FYs 2009 and 2010. 

In 2008, the Secure Border Initiative approved the Transportation 

PMO’s charter, which tasked the office to implement new 

transportation capabilities through any mix of in-house, contract, 

or reimbursable support resources. The charter explains that the 

Transportation PMO is responsible for assisting Field Operations 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


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and Border Patrol in gathering, analyzing, and prioritizing 

operational needs as well as establishing processes to validate and 

prioritize transportation requirements. According to the Program 

Management Plan, the Transportation PMO functions as a major 

acquisition project to design and implement an integrated system 

of detainee transportation, security, and administrative support. 

In October 2008, the Transportation PMO was moved from the 

Secure Border Initiative to the Border Patrol’s Strategic Planning, 

Policy, and Analysis Division. According to CBP officials, the 

transition occurred as a result of reorganization within the Security 

Border Initiative, allowing the Secure Border Initiative to focus on 

its program priorities. As of August 2010, the Transportation 

PMO was staffed with seven CBP personnel and one contractor for 

technical support. 

From August 2006 through July 2010, CBP has spent 

approximately $291 million on the Transportation PMO and the 

transportation contract. The transportation contract expires in 

August 2011, requiring CBP to make decisions for developing and 

implementing future transportation solutions. 

Results of Audit 

CBP Does Not Have a Comprehensive Approach for Determining 

Transportation Needs 

Although CBP chartered the Transportation PMO to develop more 

efficient ground transportation capabilities, the office has not 

fulfilled its mission. The Transportation PMO did not establish a 

process to identify, analyze, or validate comprehensive 

transportation needs and did not provide well-supported options for 

addressing future transportation needs. CBP did not clearly define 

the scope and authority of the Transportation PMO or provide 

sufficient oversight to ensure that it accomplished its mission. 

Identifying, Analyzing, and Validating Transportation 

Requirements 

The Transportation PMO did not develop a plan to identify, 

analyze, or validate the level of transportation required for illegal 

aliens, which would include the actual hours CBP officers and 

agents and the CBP contractor dedicate to performing these 

services. This information is necessary for the office to create a 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 

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model to predict transportation requirements. In turn, those 

requirements are necessary for the Transportation PMO to develop 

a cost effective and efficient plan to address CBP’s ground 

transportation needs for illegal aliens. 

CBP uses the Border Patrol Enforcement Tracking System and 

CBP Overtime Scheduling System for time and attendance, but 

these systems do not capture or track data related to the time 

officers and agents spend specifically on transportation and guard 

services. CBP did not consider using some existing sources of 

information that might have assisted them in identifying 

transportation needs, such as the following: 

•	 Records of Persons and Property Transferred (Form I-216): 

Reports the number of trips to ICE facilities, local 

correctional facilities, or repatriation to Mexico. 

•	 Treatment Authorization Request: Reports trips to medical 

facilities. 

•	 Command Center Event/Shift Supervisor Log: Reports 

when CBP officers must leave their primary duty stations 

to provide transportation at some ports of entry. 

Instead, in January 2010, the Transportation PMO asked field 

offices and border sectors to estimate the number of hours that 

officers and agents spent on transportation services in FY 2009. 

The Transportation PMO did not provide specific instructions on 

how to estimate the hours used, but instead relied on the officers’, 

agents’, and their supervisors’ memories of what took place up to 

15 months previously. 

Additionally, the Transportation PMO does not verify the number 

of hours reported by the contractor or the number of detainees 

moved during the trips. Instead, the Transportation PMO used the 

contractor’s self-reported data to identify contractor services and 

the level of contractor support needed. Field contracting officer’s 

technical representatives met with CBP representatives from Field 

Operations and Border Patrol to schedule contractor hours and 

routes without validating the services reported. 

Identifying Optimal Actions to Meet Future Transportation 

Requirements 

The Transportation PMO did propose a set of transportation 

solutions to replace the current contract when it expires. These 

proposals included awarding a new contract for transportation 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


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support, hiring additional officers and agents to perform the 

transportation duties, and creating a new type of position and 

hiring detention enforcement officers1

 to perform transportation 

duties. The Transportation PMO presented these options to the 

Executive Coordinating Council, an overarching group established 

to review integration of detainee transportation and related guard 

services for Field Operations and Border Patrol, showing the 

replacement contract as the low cost alternative. However, the 

Transportation PMO did not adequately evaluate and present the 

costs associated with these options to identify the optimal solutions 

for transportation requirements. 

Our review of the information the Transportation PMO provided to 

the Executive Coordinating Council showed that the 

Transportation PMO: 

•	 Did not have adequate support for its estimate of future 

transportation requirements; 

•	 Overstated the cost of the detention enforcement officer 

position by $89 million; 

•	 Overstated the cost of hiring additional officers and agents 

by $75 million; and 

•	 Understated contract costs by $22 million. 

The Transportation PMO used CBP’s FY 2011 budget model as a 

basis for the life cycle cost estimate of the detention enforcement 

officer position as well as the costs for CBP officers and agents. In 

contrast, the office used FY 2009 actual expenses adjusted for 

inflation as a basis for the contract alternative. 

We reviewed these models and identified that the Transportation 

PMO included inappropriate costs for each government employee2 

for personal compensation awards, relocation, long-distance phone 

calls, and recruitment expenses, which were not included for the 

contractor. The Transportation PMO overstated the detention 

enforcement officer option by using an inflated grade level. In 

addition, the Transportation PMO understated the contract costs by 

excluding the amounts spent on continuous contract support and 

oversight. 

1 A Detention Enforcement Officer would be a newly formed position within CBP, focused primarily on 

transportation functions. The position would also be able to provide support for additional activities as 

needed by CBP. This position would not have the full law enforcement responsibilities of a CBP agent or 

officer and would use a lower pay structure.

2

 This includes the proposed detention enforcement officer and additionally hired officers and agents. 

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The Transportation PMO also included overhead expenses already 

incurred by the government such as General Services 

Administration rental payments, utilities, and shipping fees that 

should not significantly increase with the addition of the detention 

enforcement officer position. 

CBP Did Not Provide Adequate Oversight of the Transportation 

PMO 

The agency has not provided adequate management and oversight 

for the Transportation PMO. CBP did not provide criteria that 

clearly defined the scope, authority, or performance expectations 

of the office. Without establishing performance expectations and 

monitoring the Transportation PMO’s execution of its mission, 

CBP was not able to ensure that the office identified and presented 

appropriate future solutions for transportation requirements. 

Transportation PMO Not Following its Charter 

CBP has not ensured that the Transportation PMO is fulfilling its 

mission as defined in its charter. The charter establishes the 

office’s overall mission broadly in some sections, yet narrows its 

functions and responsibilities to contract-related tasks in others. 

For example, the charter tasks the Transportation PMO to assist 

Field Operations and Border Patrol sponsors to gather, analyze, 

validate, and prioritize operational requirements and ensure that 

transportation solutions meet end users’ requirements. Yet it 

further defines the scope of the Transportation PMO to: 

•	 Provide oversight and visibility of current contract service. 

•	 Develop an integrated system of detainee transportation, 

security, and administrative support. 

•	 Implement short-term and stopgap strategies pending 

development of long-term capabilities. 

•	 Identify acquisition strategies that provide transportation 

solutions. 

The Transportation PMO selected what functions it performed and 

limited its focus to the contract in place and planning for a followon contract. Transportation PMO leadership explained that they 

believed theirs was an acquisition management office with limited 

influence over CBP operations affecting officers and agents. The 

Transportation PMO Director believes the office cannot impose 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 

Page 6
 
changes outside of the transportation contract and should therefore 

limit itself to a narrow contract management role. 

CBP did not establish clear performance expectations to evaluate 

the Transportation PMO. The Transportation PMO established 

five performance goals for FY 2010, but none of the goals 

addressed how effectively the Transportation PMO program met 

the missions defined in its charter. Additionally, the five goals 

were not measurable and were limited to acquisition compliance 

and contract management. The CBP official responsible for 

overseeing the Transportation PMO acknowledged that he 

assumed that the office was functioning as intended without 

performing close oversight to ensure that it met its mission. 

CBP Is Ill-prepared to Make Long-term Transportation 

Decision 

CBP is ill-prepared to make a long-term decision for detainee 

transportation. CBP has invested more than $291 million in the 

Transportation PMO and its activities to implement more efficient 

ground transportation solutions. However, the agency has no 

assurance that the optimal transportation solution has been 

identified to meet future requirements. Without complete 

information and analysis, CBP does not know if its officers and 

agents perform excessive collateral transportation services or if the 

agency’s plans to award a new contract for transportation services 

will meet its needs efficiently. 

The agency plans to invest an estimated $400 million over 5 years 

for transportation solutions when the current contract ends in 

August 2011. Before CBP makes this investment, it should ensure 

that the Transportation PMO clearly identifies CBP’s 

transportation needs with a thorough analysis of alternatives to 

support the most cost effective long-term solution. 

Recommendations 

We recommend that the Chief, U.S. Border Patrol and the 

Assistant Commissioner, Office of Field Operations: 

Recommendation #1: Establish a methodology to identify current 

transportation requirements, create a model to predict future 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 

Page 7
 
requirements, and identify the optimal mix of resources to meet 

those requirements. 

Recommendation #2: Provide sufficient management and 

oversight to ensure accountability for performing the analysis of 

current and future transportation needs. 

Management Comments and OIG Analysis 

CBP concurred with both of the recommendations in the report and 

the agency has already begun to formulate plans and initiate 

actions to address the recommendations. CBP expressed concern 

that the report does not acknowledge some of the significant efforts 

on the part of the Transportation PMO, thereby negatively skewing 

the balance and tone of the report. We recognize the PMO’s 

efforts; however, the agency’s official response provided general 

statements without the documentation and evidence to refute the 

message of our report. CBP explained that the PMO adhered to 

the DHS acquisition program management policy and guidance 

and used an approved Analysis of Alternatives Study Plan to guide 

their cost benefit analysis. While CBP may have used the 

approved Study Plan, the draft report identifies internal control 

weaknesses with CBP’s approach to determining its transportation 

needs. Specifically, the Transportation PMO did not establish a 

process to identify, analyze, or validate comprehensive 

transportation needs. We continue to assert this is necessary 

information to use as a foundation for a realistic cost analysis. 

CBP disagreed with the OIG’s conclusion that the Transportation 

PMO overstated the cost of the detention enforcement officer and 

the cost of hiring additional Office of Field Operations officers and 

Border Patrol agents. The agency noted that even if all cost 

adjustments recommended by the OIG were made, the five year 

estimates would not change the fact that contracting is still the low 

cost alternative. The OIG reviewed all documentation provided by 

the PMO, held meetings with the PMO to discuss the cost analysis 

methodology, and briefed PMO management on multiple 

occasions. Our report does not disagree that using a transportation 

contract may be the lowest cost option, but emphasizes the absence 

of basic data elements and unnecessary overhead expenses makes 

the cost analysis unreliable for CBP to make an informed longterm transportation decision. The OIG team attempted to further 

discuss and gather evidence to support CBP’s position; however, 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 8
 
 
the agency cancelled the meeting and did not provide additional 

supporting documentation. 

CBP expressed concern with the OIG’s conclusion that the agency 

has not provided adequate oversight to the Transportation PMO. 

Our conclusion is based on the absence of specific criteria that 

clearly defined the scope, authority, or performance expectations 

of the office, leaving the PMO to limit its focus to the contract in 

place and planning for a follow-on contract and not managing the 

comprehensive transportation program. 

We consider the recommendations unresolved and open until more 

information is provided. CBP’s response also included technical 

comments which provided additional details and clarification that 

was unavailable at the time of our fieldwork. We considered these 

comments when preparing the final report and, where appropriate, 

modified the report. A summary of the recommendations and 

CBP’s actions to address the recommendations follows. 

Management Response to Recommendation #1: 

CBP concurred: CBP agreed with the need to establish a 

methodology to identify current transportation requirements, create 

a model to predict future requirements, and identify the optimal 

mix of resources to meet those requirements. The agency 

confirmed that the ideal data collection methodology would 

include activity-based data captured real or near real time. The 

data would be verified and validated, and made available to 

decision makers on a timely basis. The method must integrate 

collection activity between Border Patrol and Field Operations 

whose operations are substantially different from each other. It 

must identify and accurately allocate the correct time and resources 

spent on multiple, but concurrent activities such as line watch and 

transporting apprehended aliens. 

CBP plans to assess the cost and feasibility of a system with the 

need to minimize operational impact and increase effectiveness 

and efficiency. In the meantime, Border Patrol and Field 

Operations have begun a process of collecting requirements from 

data calls and survey instruments. The data will be verified and 

validated by comparing existing databases and prior submissions. 

The agency will also collect data from a modified random 

sampling of locations that transport a high number of aliens to 

independently validate data. CBP indicated that the PMO has been 

using several modeling approaches developed by a contractor to 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


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analyze transportation routes to determine the optimal mix of 

staffing resources such as detention enforcement officers, 

contractors, and CBP personnel. CBP will collect data more 

frequently to reduce error and improve data quality. The agency 

plans to complete a feasibility study by June 30, 2012. 

OIG Analysis: We appreciate CBP’s efforts to move towards a 

data collection methodology would include activity-based data 

captured real or near real time. Although CBP has begun 

collecting more information and agreed to conduct a feasibility 

study to assess the cost and feasibility of such a system, the agency 

did not provide sufficient details on its effort and commitment to 

identify accurate transportation requirements create a model to 

predict future requirements, and identify the optimal mix of 

resources. This recommendation is unresolved and will remain 

open. 

Management Response to Recommendation #2: 

CBP concurred: CBP responded that management oversight to 

provide guidance and to ensure accountability for accurately 

determining current and future transportation needs is important. 

The agency agreed to provide more management and oversight to 

ensure accountability for performing the analysis of current and 

future transportation needs. CBP indicated that Border Patrol 

provided oversight of the Transportation Office, but acknowledged 

the office could do more to improve management oversight. CBP 

will review the charters for the PMO and the ECC and make 

revisions to better define the scope of the PMO and clarify the 

roles and responsibilities of each no later than April 30, 2011. 

CBP has recently established a Component Acquisition Executive 

to provide acquisition oversight of the Transportation program and 

similar programs. This management oversight will include a 

quarterly program review with the Component Acquisition 

Executive beginning no later than March 31, 2011. 

OIG Analysis: This recommendation is unresolved and will 

remain open. We recognize CBP’s efforts to provide acquisition 

oversight of the Transportation program; however, more details are 

needed to understand how Border Patrol will improve management 

oversight. We also need to review all modifications made to the 

PMO and ECC charters to ensure the intent of the recommendation 

is satisfied. 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 10
 
 
 

Appendix A 

Purpose, Scope, and Methodology 

Our objective was to determine whether the U.S. Customs and 

Border Protection (CBP) Transportation Program Management 

Office (PMO) developed an effective plan to provide efficient and 

cost effective ground transportation for detainees. 

To accomplish our objective, we reviewed and analyzed applicable 

laws and regulations; prior audit reports; CBP documentation 

establishing and managing the Transportation PMO, Executive 

Coordinating Council, and Integrated Project Team outputs; and 

contract documents related to transportation services from August 

2006 through August 2010. 

We interviewed CBP headquarters personnel from the Secure 

Border Initiative, Field Operations, and Border Patrol, including 

staff from the Transportation PMO. We also spoke with personnel 

from the Office of Border Patrol Workforce Management, Finance 

and Logistics branches, CBP Acquisition and Program 

Management Offices, as well as personnel from Transportation 

PMO contractor companies. 

We analyzed cost models that the Transportation PMO used to 

estimate contract and CBP alternatives to support long-term 

transportation decisions. We also reviewed analysis performed by 

Transportation PMO contractors that the office included in its cost 

models. We reviewed data from apprehension and timekeeping 

systems to see whether they contained information that CBP could 

use to determine transportation needs. 

We selected and visited field locations in California and Arizona 

based on high rates of apprehensions and border-crossing statistics. 

We toured one Border Patrol station and two ports of entry in San 

Diego, CA, and two Border Patrol stations and two ports of entry 

in Tucson, AZ. We also visited the Border Patrol and Field 

Operations headquarters offices in both locations. During these 

visits, we spoke with field personnel, including chiefs, shift 

supervisors, and agents at Border Patrol stations and at Border 

Patrol sectors. We spoke with port directors, watch commanders, 

and CBP officers at ports of entry and Field Operations offices. 

We conducted this performance audit between April and 

September 2010 under the authority of the Inspector General Act 

of 1978, as amended, and according to generally accepted 

government auditing standards. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 

Page 11
 
Appendix A 

Purpose, Scope, and Methodology 

conclusions based on our audit objectives. We believe the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 12
 
 
MEMORANDUM FOR RICHARD L. SKINNER

INSPECTOR GENERAL

DI::PARTMENT OF IIOMELAND SECURITY

FROM: Assistant Commissioner ..... 1 --o:reDs Q

Office of Internal Affairs cr--~' t

SUBJECT: U.s. Customs and Border Prot~tion's Response to the Office of Inspector

General's Draft Re]Xlrt Entitled, "U.S. Customs and Border Protection's

Ground Transportation of Detainees Program"

Thank you for providing us with a copy of your draft report entitled ··U.S. Customs and Border

Protl~tion's Ground Transportation of Detainees Program." dated November 2010. We appreciate the

opportunity to revie\\ and respond to the report. The report llddresses the effectiveness of U.S.

Customs and Border Protection's (CBI') efforts to create a plan to provide efficient ground

transportation for detainees.

After careful review, we believe the draft report docs not acknowledge some of the significant cfforts

on the part ofthe Transportation Program Management Office (1'11.10). thereby negativel) skewing the

balance and tone of the report. For example. the Office of Inspector General (O[G) concluded that

CBp docs not have a comprehensive approlleh for determining transportation needs lind that COP did

not provide adequate oversight ofthe Tr.msportation PMO. The Transportation PMO adhered to

f)epartmenl ofllomcland Security (DHS) acquisition program management policy and guidance. In

support orlhis process. the Transportation I'MO developed an Analysis of Alternatives (AoA) Stud}

Plan that \,as endorsed by the Executiv<,: Coordinating Courn;il (fCC) and approved by the Chief.

Ollice of Border Patrol (ODp). The AoA Study Plan defined the scope ofthe cost benefit analysis to

be perfonncd, defined the estimate approach. identified the ground rules and assumptions. and

assigned various CIlP organi7.3tional subject mailer experts, as well as agents lind officers to

participatc in the Life Cyele Cost Estimate Working Group.

FurthernlUre. the O[G reported that the Tr.rnsportation PMO overstated thc cost of the Detention

Fnforcemellt Officer (DEO) position by $89 million and the cost of hiring additional Omee of Field

Operations (OFO) Officers and Border Pmrol Agents by $75 million. 111is conclusion is based upon a

lack of understanding ofthe methodology used to dcvelop these estimates, TIte Transportation PMO

worked closely with the CDI' Office of Administration to develop a cost model to estimate the costs

associated with hiring additional ollicers and agents or DEOs. In addition, it should be noted Ihm even

if all cost adjustments [(."Commended by the DIG were made, the five year estimates "ould not change

the fact that eontracling is still the low cost altemathe.

rhe Iransportation PMO is also nol without oversight and scrutiny at the CBP and DHS level. The

Tmnsportation PMO has received positive input and review from various omees, including the Chief

1300 ""nllsylvmi~ A"enue!':W

W~lhillglon. DC 20229

u.s. Customs ilnd

Border Protection

Dccemher 13,2010

Appendix B 

Management Comments to the Draft Report 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 13
 
 
 

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""to "',," ,...,.,.. ,I) '"8 &rod "01""01'''1I"<'VOm """""lI<'" ni "'I:>:ro<' nul'" .'''''''" ""'Ii .. the r""''''''''"8 Ofli«r'.

'''''M'''01 Rqnoo:n i'es. '"f""""i"" from <>,..i"ll~_b .. oppr<hrnsioo-.l

IlfI\"r<'h<noi "'m' ""'t uO«IlO...i" ;" th< vali<lation -.l ,·air....;"" pnx.... l'nron......dy.

,hi. 1"""'" ..co.' on< ,0< OIG di<l _ boli<.. odoGu.Jl<ly corouroJ th< .......1110<", <kdi<"ed '"

ot'IOlSf"'rl.-to. W. all'"" that ,0< i<Jo:.>l <Iol.a <011«:,,,,,, m<ll>ndol"ll) ,,,,,,Id ,,,,,ud< ..."i'y·o..«I

""a capluml "'01 Of .... ouI 'i"", Tho dol. ",,,,,Id bo ,....,f>«l ond ,,,I....od..... ma.:le ""i1.obl< to

.k<i';on mol..... on. """'y t-i" M_ imf'O"'W'''Y. _h. mo<tbo.l mu>< ,mel"" ..".",.... """ ;'y

bot",·..." Oil? ord OFO """",, <>p<flI'JOIIll on: JUbsl,.,"iaJly dilT"""" from...,1i o<h<,. furtb<rm.>r<."

m"" _,fy ond """",..dy .Ik><*II>< oorncI '''"'' and '""""'" _

...i,·n.., 0<1 mnlllpk buI ron<llfT<II'"",Ii .. I"", ......b -.l nnopnnillj app«hmded "oro>.

CliP "ill th< COiI-.l f=ibili'y of""," ..y""'" "',111 tho o<ed "' m,nlm<Z<!Ia,. op<t>tlOn:ll ,mf'""l

ond ;"',. 1T""ti,....... ond .lTocimcy. ,f ""y', In 'h< """",,,mo. OIIP ar>d OHI bog 0

pro<'" of ooll<e1JJl.ll "'Iu,........,,,, from dala ....,.-.J ......·cy in""""",,"- TO< <!Iou "'ill '..-iIi<\!

-.l "olidaled by rompoI'I"I .'''''''8 _ and p.-i<M- ,,,Om;..ionl.- F........, ' 'ill ooIk<:t dala

from 0 mod,fled rondom ""'pli"ll """,..«I oflo< """ "*""",,,. high "umbo< "foli to ;OO<p<ntI<nLly

,1oI>J;,t< <lata <o11<e1ed ,i'''·,i. l., AI.... "" 110.. bo<n "'ina ""'· 1m<:><I<linl

IOJ'PI'*'.... dovdopod by • ~"'" to p" _iooo ""'I<> "' "",,,,,,,it>< ,Ii< "1",,,,,,1 mix of

otoffm8 .....,..,.,.. <trlI ..il<lool,..,., ""fOftrn>rn' off...... tool""""'" and CHP ~I, .....,y..." "ill roll<et llaI3 ...... ft«fU""lIy to oal..,...,..". on<! 'm",,""', _ quohly We ..ill rompklo: ,0<

r",ibilil)-' <tOOl' h~' Jun< 10. 2012

Appendix B 

Management Comments to the Draft Report 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 14
 
 
 

,

Kuomm!ldlljoa n, Pro> ,<Ie ..tfo<otnt ond ,,",'enlV!' to."""" -=unlabiht), for

p<>1onn;"lI'he """lySis of <ur=Il ,.,.,t r..."", ......""""',"'"

eRr R",oo".r; eBr """"on ..i,1I ,he mo<>m....,..woon. M>nag<mcn' ""'"'sh' '" p"','id\: 1JUidancc:

on<! "'""""" •••,,,,."bili'y ro. ..eun.l"lj' <IoI<:""i,".& <.ItI.'>1 IU1d r..= nn>ponation M'<d> ...

b<aI. and will <:ootmuc: to be oflIUrml imporlOn« "' ... A• ....,n. OBP as u., h<CUl"" Ai<....

pro,-i<k<l IWer.!I&h< .ftho T'""'I"J'Ution OIl\«by nokli"ll _'y """"..lIS ,"'i'" rnaIIIIll<m<ttl.

1"'''''';1'''';'' in oil """,,,Iy klint I'row>m M>n>.ll<m<nl R<''''..... -.:I 'haorinH tho ECe.•ll"'"r

J<>;~'" ."..erx< the '""'KfOlionor'h< I«hn,,,.1 ",.) ,",,'i<oJ "'I'l"" Q""" '" bolh Uord<r ....roI

and oro. N"'"nh<k>., "'" "","",",..t tN., ,,"'< ..., <10 """" '" imf.f'l"'''''' 1IUII:lj!..,. o>er>ijlk!.

We ..ill l'r"icvo tho <h.on<n fOf !he: PMO .... the: ECe ..... ,...,is< ",h<-re Oi'!"'>flIUlC H' d<fo.. tho

"""II" .fth< PMO or.d darif) tho roI.. ond f<>I'O'l'ibih'''''.f .""" no 1,1<r ,.." 11.""1 )1), 1011 MOSI

,mpo<U:llly. eBP ... ",,<.tly ...,,\>I1>hOO • Componrnt /\<qui,i'ion b«u,i,'<(CAf) '" 1",,,,;<1<

0«(11;,1'"", over..ghI.r"",h 1'fOIJVTI'" !he: T~"IOO prowM1 Thi> ."""~

""II ,,,,1_. """,,my rmwum "'.';.,... ....Ill the "E tqinru"ll "" 101<. than 0«<lI'0J ~""""" ~oll '"~

byM""hlUOIl

1'0 l1h "'1I"f'I'" tho cl....,flCOtJOll of II>< dr:1ft "po<'!. CHI' ... "'" IdenlJl1<d ...y ,nfOl1l\Olion ,,"hm ,h..

rq>on 1Iw ""min" 0 "F", OllIe... U..Only" <I.,.jrlC.t1on,

'" oJ".).. CUP ~i''''' II>< """""un,') "' highli~ "'" «>DIino'''i <tYotts to ''''P'''''e

1"0("""""",•• oro ", pro' Od< oo.!J;,""" ;"r""""..... ", ,... <HItO]() "'i""!;".lI (ott fill"", .Il"... lhoI 00l

,,"I) -.... ".. 010 tt<"'"""""'"'...... but "'II .1", Impn>'e "'"' ",<fOl1 0p<nl"""1 .«eo,,,........

If)',," ho,', ony 4...'..... ~i"lI,h;,"'_ """"'" ......""_<. m<mb« ofr-.,.IT

<,,"to<! M.. t}nn Ri<"""-l""" CIlP A"";' Lioi""" Olliox of I""",.. AlT.;.,., ., 1202)l«-2953

Appendix B 

Management Comments to the Draft Report 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 15
 
 
Appendix C 

Detainee Transportation Process 

Field to Border Patrol Station: Transportations usually conducted by Border Patrol 

agents from locations between the ports of entry near the border or from checkpoints 

established on known egress routes. 

Port of Entry or Border Patrol Station to Detention and Removal Facilities: 

Transportation conducted by CBP officers and agents after the detainee has been 

processed and a final disposition of the detainee has been determined 

Port of Entry or Border Patrol Station to Other: Transportations conducted by CBP 

officers and agents after the detainee has been apprehended at a port of entry or 

transported to a Border Patrol station, but before the detainee has been processed or a 

final disposition of the detainee has been determined. 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 16
 
 
Appendix D 

Major Contributors to This Report 

Patrick O’Malley, Director 

Christine Haynes, Audit Manager 

Jeanette Hyatt, Auditor in Charge 

Jacque Bear, Program Analyst 

John Jadick, Program Analyst 

Keith Lutgen, Program Analyst 

Thomas Bobrowski, Independent Referencer 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 17
 
 
Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

U.S. Customs and Border Protection 

Commissioner 

Chief, U.S. Border Patrol 

Assistant Commissioner, Office of Field Operations 

OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

U.S. Customs and Border Protection’s Ground Transportation of Detainees 
 


Page 18
 
 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.