Department of Homeland Security

2IÀFHRI,QVSHFWRU*HQHUDO
 

Annual Review of the United States Coast Guard's 

Mission Performance (FY 2013)
 

OIG-14-140 September 2014
 
 

 

 

 

MEMORANDUM FOR:	 Rear Admiral Todd A. Sokalzuk 

Assistant Commandant for Resources and 

Chief Financial Officer 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

SEP 11 2014 

United States Coast Guard 

FROM:	 Anne L. Richards 

Assistant Inspector General for Audits 

SUBJECT:	 Annual Review of the United States Coast Guard’s Mission 

Performance (FY 2013) 

 

Attached for your information is our final report, Annual Review of the United States 

Coast Guard’s Mission Performance (FY 2013). We incorporated the technical comments 

from the United States Coast Guard in the final report, as appropriate. The report 

contains no recommendations. 

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

copies of our report to appropriate 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 John E. McCoy II, Deputy 

Assistant Inspector General for Audits, at (202) 254-4100. 

Attachment 
 

 

Table of Contents

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

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

Results of Review................................................................................................................ 3

Resource Hours for NonͲHomeland Security and Homeland Security Missions.... 4

The USCG’s Mission Performance.......................................................................... 7

FY 2013 Budget Information.................................................................................. 7

Management Comments and OIG Analysis............................................................ 7

Appendixes


 

Appendix A:  Objectives, Scope, and Methodology ............................................. 8 
 

Appendix B:  Management Comments to the Draft Report .............................. 10 
 

Appendix C: NonͲHomeland Security Missions................................................. 11 
 

Appendix D: Homeland Security Missions......................................................... 22 
 

Appendix E: FY 2013 Performance Measure Summary .................................... 33 
 

Appendix F: Major Contributors to This Report ............................................... 34 
 

Appendix G: Report Distribution ....................................................................... 35 
 

Abbreviations

DHS Department of Homeland Security

FY fiscal year

GAO  Government Accountability Office

OIG  Office of Inspector General

OMB  Office of Management and Budget

SPD  Strategic Planning Direction

USCG  United States Coast Guard

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Executive Summary 

This report presents our annual review of the United States Coast Guard’s (USCG)

mission performance, as required by the Homeland Security Act of 2002. The act defines

the USCG’s 11 statutory missions as either nonͲhomeland security missions or homeland

security. The act also prohibits the Secretary of Homeland Security from substantially

reducing any of the USCG’s missions after its transfer to the Department of Homeland

Security, except as specified in subsequent acts.

The objective of this review was to determine the extent to which the USCG is

maintaining its historical level of effort on nonͲhomeland security missions. To address

our objective, we reviewed the resource hours the USCG used to perform its various

missions. We also reviewed the USCG’s performance measures and results for each nonͲ

homeland security and homeland security mission. We did not verify the accuracy of the

USCGͲprovided data.

According to USCG’s data, the majority of resource hours are no longer dedicated to

homeland security missions. For fiscal year 2013, the USCG dedicated about the same

percentage of resource hours to homeland security missions as to nonͲhomeland

security missions.

The USCG reported that it met or exceeded 15 of 23 summary performance measure

targets in fiscal year 2013. This includes 9 of 12 nonͲhomeland security performance

measures and 6 of 11 homeland security performance measures targets. In fiscal year

2013, the USCG budgeted nearly the same percentage of funding to its nonͲhomeland

security and homeland security missions.

This report contains no recommendations.

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Background

Section 888 of the Homeland Security Act of 2002, Public Law 107Ͳ296, dated

November 25, 2002, directs the Department of Homeland Security (DHS) Office of

Inspector General (OIG) to conduct an annual review that assesses the performance of

all USCG missions, with an emphasis on nonͲhomeland security missions. The act defines

the USCG’s 11 statutory missions as either nonͲhomeland security missions or homeland

security missions, and prohibits the Secretary of Homeland Security from substantially

or significantly reducing any of the USCG’s missions or its capability to perform those

missions. Table 1 depicts the USCG’s 11 statutory missions and the alignment of those

missions with DHS programs.

Table 1:Alignment of DHS Programs With Statutory NonͲHomeland Security and

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Homeland Security Missions

NonͲHomeland Security Missions Alignment With DHS Programs

1. Living Marine Resources Maritime Law Enforcement

2. Marine Safety Maritime Prevention

3. Marine Environmental Protection Maritime Response

Maritime Prevention

4. Search and Rescue Maritime Response

5. AidsͲtoͲNavigation Marine Transportation System Management

6. Ice Operations Marine Transportation System Management

Homeland Security Missions Alignment With DHS Programs

1. Ports, Waterways, and Coastal

Security

Maritime Security Operations

Maritime Prevention

2. Drug Interdiction Maritime Law Enforcement

3. Migrant Interdiction Maritime Law Enforcement

4. Defense Readiness Defense Operations

5. Other Law Enforcement Maritime Law Enforcement

Source:DHS OIG based on USCGͲprovided data.

The USCG uses resource hours to determine the amount of time expended on each of

its nonͲhomeland security and homeland security missions. We analyzed the total

number of resource hours reported by the USCG for fiscal years (FY) 2011 through 2013.

The USCGͲcalculated baseline is an annual average of resource hours based on eight FY

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quarters preceding September 11, 2001. We did not verify the resource hour data

reported by the USCG, nor did we validate whether the USCG accurately classified

resource hours used for each mission. We assessed total resource hours for the 11

individual missions to identify the changes in each.

The USCG completes a Strategic Planning Direction (SPD) for each fiscal year. This

document provides strategic guidance for aligning frontline activities with overarching

priorities. According to the SPD, the demand for USCG services will continue to increase

as maritime activity increases. According to the USCG, resource decisions in the FY 2014

SPD reflect careful tradeoffs among future capability and current services.

The USCG establishes targets based on the Office of Management and Budget’s (OMB)

FY 2008 Program Assessment Rating Tool Guidance, which states that targets should be

“ambitious and achievable,” and built off a reliable baseline. USCG personnel said they

are aiming for an ambitious and achievable target in accordance with this OMB

guidance, which promotes continued improvements, and therefore, not every target

might be achieved every year.

Results of Review

Our review of USCGͲprovided data indicated that in FY 2013, the USCG budgeted nearly

the same percentage of funding to its nonͲhomeland security and homeland security

missions. FY 2013 homeland security mission resource hours totaled 284,496, while

nonͲhomeland security mission resource hours totaled 285,848. FY 2013 homeland

security mission resource hours decreased by about 19 percent from FY 2012 and

remained about 53 percent above the baseline. NonͲhomeland security mission

resource hours decreased by about 12 percent from FY 2012 and were 4 percent below

the baseline.

The total number of resource hours for all missions has continued to decline since

FY 2005. With the exception of ice operations, resource hours for the USCG’s individual

missions decreased by 5 to 28 percent in FY 2013. Coast Guard personnel attribute the

decreases to the March 2013 sequestration reductions in spending required by the

Budget Control Act of 2011.

The USCG reported that it met or exceeded 15 of 23 summary performance measures in

FY 2013. This includes 9 of 12 nonͲhomeland security performance measures and 6 of

11 homeland security performance measures. For FY 2013, the USCG budgeted about 50

percent of its funding for nonͲhomeland security missions and about 50 percent for

homeland security missions.

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Resource Hours for NonͲHomeland Security and Homeland Security Missions

In FY 2013, the USCG used nearly the same percentage of its resource hours for

nonͲhomeland security missions (about 50 percent) as for homeland security

missions, as illustrated in the following chart.

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Chart 1: Resource Hours – All Missions

Source:DHS OIG based on USCGͲprovided data.

As illustrated in table 2, the total number of resource hours the USCG dedicates

to its specific statutory missions continues to decline. In FY 2013, the total USCGͲ

reported resource hours dropped to 570,344, which is a decline of about 17

percent compared with 683,594 hours in FY 2011.

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2:FY 2013 Coast Guard Resource Hours

Missions

FY 2011 FY 2012 FY 2013

Hours

% of

total

Mission

Hours

Hours

% of

total

Mission

Hours

Hours

% of

total

Mission

Hours

Non Homeland Security      

Living Marine Resources



93,616 13.7%



94,379 13.9%



79,004 13.8%

Marine Safety



64,210 9.4%



63,632 9.4%



57,447 10.1%

Marine Environmental

Protection



4,682 0.7%



3,091 0.5%



2,298 0.4%

Search and Rescue



55,934 8.2%



58,770 8.7%



52,974 9.3%

AidsͲtoͲNavigation



98,819 14.5%



97,960 14.5%



83,697 14.7%

Ice Operations



10,747 1.5%



7,528 1.0%



10,428 1.8%

SubͲtotal



328,008 48.0%



325,360 48.0%



285,848 50.1%

Homeland Security      

Ports, Waterways, Coastal

Security



155,969 22.8%



150,699 22.3%



108,015 18.9%

Drug Interdiction



73,401 10.7%



85,089 12.6%



80,883 14.2%

Migrant Interdiction



72,213 10.6%



69,018 10.2%



56,464 9.9%

Defense Readiness



41,424 6.1%



34,644 5.1%



29,695 5.2%

Other Law Enforcement



12,579 1.8%



12,117 1.8%



9,439 1.7%

SubͲtotal



355,586 52.0%



351,567 52.0%



284,496 49.9%

Total



683,594 100.0%



676,927 100.0%



570,344 100.0%

Source:DHS OIG based on USCGͲprovided data. (*Individual totals may have been rounded to the nearest

tenth. As a result, the table contains inconsequential rounding differences of 0.1% in FYs 2011 through

2013.)

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

The percentages of total resource hours by statutory mission areas from FY 2011

through FY 2013 are illustrated in chart 2.

Chart 2:Percentage of Total Resource Hours by Fiscal Year

0% 5% 10% 15% 20% 25% 

Search and Rescue 

Marine Safety 

Aids-to-Navigation 

Ice Operations 

Marine Environmental Protection 

Living Marine Resources 

Illegal Drug Interdiction 

Undocumented Migrant Interdiction 

Other Law Enforcement 

Ports, Waterways, Coastal Security 

Defense Readiness 

Percentage of Total Resource Hours by Fiscal Year 

FY 

13 

FY 

12 

FY 

11 

Source:DHS OIG based on USCGͲprovided data.

Resource hours for nonͲhomeland security missions are summarized in appendix

C, and homeland security missions are summarized in appendix D.

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The USCG’s Mission Performance

We based the performance portion of our review on the USCG’s December 2013

internal report titled United States Coast Guard Fiscal Year 2013 Performance

Report, as well as previous USCG performance reports and OIG reports. Because

USCG performance reports are internal documents, they contain additional

management and breakͲout measures that we did not include in our report. This

report includes those measures that the USCG considers summary measures. In

FY 2013, the USCG used the same 23 summary performance measures as they

had in FY 2012.

NonͲhomeland security performance measures and results are included in

appendix C, and homeland security measures and results are in appendix D.

Appendix E contains a summary of the USCG’s FY 2013 performance measures

for its 11 missions.

FY 2013 Budget Information

In FY 2013, the USCG budgeted approximately 50 percent of its funding for nonͲ

homeland security missions and approximately 50 percent for homeland security

missions. Based on the USCG’s FY 2015 Congressional Justification, the historical

funding gap between nonͲhomeland security and homeland security missions is

expected to remain narrow. For FY 2014, the USCG budgeted about 48 percent

of its mission operating expenses for nonͲhomeland security missions and about

52 percent for homeland security missions. The largest percentage of the USCG’s

mission resources continues to be dedicated to its ports, waterways, and coastal

security mission, which is projected to account for about 24 percent of the

budgeted operating expenses in FY 2014.

Management Comments and OIG Analysis

The USCG provided technical comments that have been incorporated into the

final report.

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A

Objectives, Scope, and Methodology

The DHS OIG was established by the Homeland Security Act of 2002 (Public Law 107Ͳ

296) by amendment to the Inspector General Act of 1978. 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.

Section 888(f)(1) of the Homeland Security Act of 2002 directs the Inspector General to

conduct an annual assessment of the USCG’s performance of all its missions, with a

particular emphasis on nonͲhomeland security missions. The objective of this review

was to determine the extent to which the USCG is maintaining its historical level of

effort on nonͲhomeland security missions.

We reviewed the following Government Accountability Office (GAO) reports and

testimonies:

x GAOͲ12Ͳ751R, Observations on the Coast Guard's and Department of Homeland

Security's Fleet Studies, May 31, 2012

x GAOͲ12Ͳ741, Legacy Vessels’ Declining Conditions Reinforce Need for More

Realistic Operational Targets, July 2012

x GAOͲ12Ͳ934T, Mission Performance Challenged by the Declining Condition and

Rising Cost of Its Legacy Fleet, September 2012

x GAOͲ13Ͳ321, Clarifying the Application of Guidance for Common Operational

Picture Development Would Strengthen Program, April 2013

x GAOͲ14Ͳ527, Resources Provided for Drug Interdiction Operations in the Transit

Zone, Puerto Rico, and the U.S. Virgin Islands, July 2014

We analyzed the total number of resource hours reported by the USCG for FYs 2011

through 2013. We did not attempt to verify the resource hour data, nor did we attempt

to validate whether the USCG had accurately categorized such data. We assessed total

resource hours for the USCG’s 11 individual missions to identify the changes in each.

We analyzed performance measures and targets to determine whether the measures

for each of the USCG’s missions had been accomplished. We obtained information on

performance from the USCG’s internal report, United States Coast Guard Fiscal Year

2013 Performance Report. In addition, we reviewed our Annual Review of the United

States Coast Guard’s Mission Performance (FY 2012), dated September 2013, for prior

performance measure data. We obtained budget information from DHS’ BudgetͲinͲBrief

for FY 2013 and the FY 2015 Congressional Justification.

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We conducted this review between July 2014 and August 2014 under the authority of

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

for Inspections issued by the Council of the Inspectors General on Integrity and

Efficiency.

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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Appendix B

Management Comments to the Draft Report

While the USCG did not provide a formal response, it did provide technical comments

that, where appropriate, have been incorporated into the final report.

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Department of Homeland Security 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C

NonͲHomeland Security Missions

The USCG’s FY 2013 nonͲhomeland security mission resource hours totaled 285,848, a

decrease of about 12 percent from FY 2012, and a 4 percent decrease below the

baseline level. The following graph illustrates the trend in nonͲhomeland security

mission resource hours since 2011 compared with the baseline period.

Source:DHS OIG based on USCGͲprovided data.

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

Baseline201120122013

Resource Hours

NonͲ Homeland Security Resource Hours

Fiscal Year

In FY 2013, the USCG reported that it met or exceeded 9 of 12 summary performance

measures for its six nonͲhomeland security missions, the same number they had met in

FY 2012. The resource hours and summary performance measures and results for each

nonͲhomeland security mission are discussed in the following subsections.

Living Marine Resources

Living marine resources law enforcement is an obligation under the MagnusonͲStevens

Fishery Conservation and Management Act, the Endangered Species Act, and several

other laws for the protection of marine resources. Its core responsibility is to provide

effective and professional enforcement to advance national goals for the conservation,

management, and recovery of living marine resources, marine protected species, and

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Department of Homeland Security 

national marine sanctuaries and monuments. This includes enforcement of living marine

resource regulations and other activities that strengthen both domestic and

international living marine resources regimes.

Resource Hours:FY 2013 resource hours for living marine resources totaled 79,004.

This is a decrease of about 16 percent from FY 2012, and is lower than the baseline by

about 13 percent.

Source:DHS OIG based on USCGͲprovided data.

0

20,000

40,000

60,000

80,000

100,000

120,000

Baseline201120122013

Resource Hours

Living Marine Resources Hours

Fiscal Year

Performance Measures and Results: The USCG uses the percentage of fishing vessels

observed at sea complying with domestic regulations as a measure of its impact on

enforcement of U.S. fisheries and protected species regulations. The measure reflects

the percentage of USCG boardings at sea where no significant violations of domestic

living marine resources regulations were detected. As shown in the following chart, the

USCG reported that it met its fishing regulation compliance rate living marine resources

performance measure in FY 2013.

Living Marine Resources

Performance Measure – Fishing Regulation Compliance Rate

FY 2011

Actual

FY 2012

Actual

FY2013

Target

FY2013

Actual

97.4% 98.3% 96% 98.1%



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Marine Safety

The focus of the USCG’s marine safety mission is the prevention of deaths, injuries, and

property loss. Marine safety responsibilities include ensuring the safe and

environmentally sound operation of millions of recreational vessels and thousands of

U.S. flagged commercial vessels. The USCG develops and enforces Federal marine safety

regulations, certifies and provides credentials to more than 218,000 mariners,

investigates commercial marine casualties and shares its findings, and conducts

compulsory inspections as well as voluntary safety exams.

Resource Hours: The USCG did not report hours for this mission prior to 2005. The

baseline consists of the fiveͲyear average of marine safety resource hours for

FYs 2008о2012. FY 2013 resource hours totaled 57,447. This is a 10 percent decrease

from FY 2012, and is about 1 percent above the fiveͲyear average baseline.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

Baseline200820092010201120122013

Resource Hours

Marine Safety Resource Hours

Fiscal Year

Source:DHS OIG based on USCGͲprovided data.

Performance Measures and Results: The USCG reported that it met three of four

summary performance measures related to marine safety in FY 2013. Federal

regulations require the person in charge of a commercial U.S. flagged vessel to notify

the USCG of any loss of life or injury requiring professional medical treatment beyond

first aid. The USCG uses the number of reported deaths and injuries as a measure of

commercial mariner and passenger safety and the fiveͲyear average number of deaths

and injuries as an indicator of longͲterm performance trends. In FY 2013, the USCG

reported fewer commercial mariner deaths and injuries than projected but reported

more commercial passenger deaths and injuries than projected, as shown in the

following tables. According to the USCG, more reported commercial passenger deaths

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and injuries are primarily attributable to growth in the cruise line industry and changing

regulations.

Marine Safety

Performance Measure – FiveͲYear Average Number of Commercial Mariner Deaths and

Injuries

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

498 475 454 431 426 453 418

N/A



Met



Met



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

Marine Safety

Performance Measure – FiveͲYear Average Number of

Commercial Passenger Deaths and Injuries

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

253 228 238 232 256 254 282

N/A



Met



Met

X X  X

Not Met Not Met Not Met

Source: DHS OIG based on USCGͲprovided data.

Federal regulations also require operators or owners of vessels used for recreational

purposes to file a boating accident report when a person dies or disappears from the

vessel under circumstances that indicate death or injury, or a person is injured and

requires medical treatment beyond first aid. The USCG uses the number of reported

deaths and injuries as a measure of marine safety for the recreational boating segment

of the U.S. maritime community, and a fiveͲyear average of these as an indicator of

longͲterm performance trends. The USCG reported that it met its target for this

measure in FY 2013.

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Department of Homeland Security 

Marine Safety

Performance MeasureͲFiveͲYear Average

Recreational Boating Deaths and Injuries

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

4,070 4,038 3,959 3,904 3,791 3,880 3,693



Met



Met



Met



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

In FY 2013, the USCG met the performance measure for the fiveͲyear average number of

commercial and recreational deaths and injuries.

Marine Safety

Performance Measure – FiveͲYear Average Number of

Commercial and Recreational Deaths And Injuries

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY2013

Actual

N/A N/A N/A 4,567 4,473 4,546 4,241

N/A N/A N/A



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

Marine Environmental Protection

The marine environmental protection mission focuses on minimizing oil and hazardous

substance effects on human health, the environment, and the marine transportation

system. The USCG regulates the handling of oil, hazardous substances, and other

shipboard wastes to prevent their discharge into U.S. and international waterways, stop

unauthorized ocean dumping, reduce shipͲbased air emissions, and avert the

introduction of invasive species. The USCG is the lead Federal agency for directing the

removal and mitigation of oil spills from the waters and adjoining shorelines of the

coastal zone.

Resource Hours:The baseline for this mission consists of the fiveͲyear average of

resource hours for FYs 2008Ͳ2012. Marine environmental protection resource hours

totaled 2,298 in FY 2013. This represents a decrease of 26 percent from FY 2012. These

resource hours are lower than the resource hours typical for this mission in

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FYs 2008Ͳ2009, prior to the Deepwater Horizon incident (British Petroleum oil spill in

2010).

Source:DHS OIG based on USCGͲprovided data.

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

Baseline200820092010201120122013

Resource Hours

Marine Environmental Protection Resource Hours

Fiscal Year

Performance Measures and Results:Federal regulation requires vessel or facility

operators to report the discharge of any hazardous substance that equals or exceeds

reportable quantities, and requires the reporting of any discharge of oil or oil products

that cause a sheen, discoloration, sludge, or emulsion on or below the surface of any

navigable waterway of the United States. The USCG uses the number of chemical

discharge incidents and the number of oil spills greater than 100 gallons as proxy

indicators of marine environmental protection, and normalizes fiveͲyear averages of

these incidents as indicators of longͲterm trends. In FY 2013, the USCG reported that it

met the target for the average number of chemical discharge incidents in the maritime

environment.

Marine Environmental Protection

Performance Measure – Average Number of Chemical Discharge Incidents in the

Maritime Environment

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

19.8 18.7 16.9 15 14.2 16 14.6

N/A



Met



Met



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

USCG also reported that it met the target for the average number of oil spills in the

maritime environment.

Marine Environmental Protection Performance Measure

Average Number of Oil Spills in the Maritime Environment

FY 2008

Actual

FY 2009

Actual

FY 2010

Actual

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

13.1 11.8 11.5 10.2 10.5 11.4 10



Met



Met



Met



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data. 

Search and Rescue

USCG strives to minimize lives lost, injury, and property loss or damage, by rendering aid

to those in distress in the maritime environment and elsewhere as called upon. The

search and rescue mission is accomplished through resource readiness, distress

monitoring and communication, search planning, onͲscene operations, and domestic

and international partnerships.

Resource Hours:Search and rescue is a demandͲdriven mission. The requirement for

search and rescue missions increases or decreases relative to the number of people

requiring the USCG’s assistance. Resource hours in FY 2013 totaled 52,974, a decrease

of 10 percent from FY 2012.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

Baseline201120122013

Resource Hours

Search and Rescue Resource Hours

FiscalYear

Source:DHS OIG based on USCGͲprovided data.

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Performance Measures and Results: The FY 2013 target for percentage of people in

imminent danger saved in the maritime environment was not met. In FY 2013, the USCG

executed 17,721 search and rescue cases and saved 3,263 lives. Numerous variables

affect the final percentage of people saved from imminent danger. Weather conditions,

water temperature, and distance to reported position of distress impact are a few

examples of factors that ultimately impact individual case outcomes. There is no single

factor to explain the fluctuations occurring on an aggregate level. The USCG stated that

it will continue to analyze search and rescue data to determine potential causes for

variances and contributing factors.

Search and Rescue

Performance Measure – Percent of People in Imminent Danger Saved in the Maritime

Environment

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

77.3% 77.3% 100% 78.7%

X X  X

Not Met Not Met Not Met

Source: DHS OIG based on USCGͲprovided data.

USCG reported that it did not meet its FY 2013 target for percentage of time that rescue

assets are onͲscene within two hours. However, overall performance is in line with the

USCG’s expectations based on placement of resources and proximity to shore of the

majority of search and rescue incidents. This measure has been adjusted to exclude

cases in which an operational decision was made to delay a response.

Search and Rescue

Performance Measure – Percent of Time Rescue Assets are OnͲScene within 2 Hours

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

93.0% 93.50% 100% 92.0%

X X  X

Not Met Not Met Not Met

Source: DHS OIG based on USCGͲprovided data.

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AidsͲtoͲNavigation

The USCG establishes, maintains, and operates more than 49,000 buoys and beacons

that comprise the U.S. Visual Aids to Navigation System. The purpose of the system is to

mitigate transit risks by reducing the potential for collisions, allisions, and groundings.

Resource Hours:FY 2013 resource hours totaled 83,697, a decrease of about

15 percent from FY 2012. This is about a 25 percent decrease from the baseline level.

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

0

20,000

40,000

60,000

80,000

100,000

120,000

Baseline201120122013

Resource Hours

AidsͲtoͲNavigation Resource Hours

Fiscal Year

Source:DHS OIG based on USCGͲprovided data.

Performance Measures and Results:The USCG reported that it met its FY 2013 target

for the availability of maritime navigation aids for the seventh consecutive year.

AidsͲtoͲNavigation

Performance Measure – Availability of Maritime Navigation Aids

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

98.5% 98.3% 97.5% 98.2%



Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 19 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In FY 2013, the USCG reported that it met its target for the average number of

navigational accidents. This is the third time this measure was met in the past six years.

AidsͲtoͲNavigation

Performance Measure – Average Number of Navigational Accidents

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

1,945 1,932 2,012 1,869



Met

 

Met

  

Met

Source: DHS OIG based on USCGͲprovided data.

Ice Operations

Ice Operations consist of Polar Icebreaking, International Ice Patrol, and Domestic

Icebreaking. This mission supports winter commerce and prevents and responds to ice

that causes flooding. On the Great Lakes, the USCG partners closely with Canada to

execute these responsibilities.

Resource Hours: In FY 2013, resource hours totaled 10,428, an increase of about

39 percent from FY 2012, and about 13 percent lower than the baseline level. Coast

Guard personnel attribute the increase in mission hours to a harsher than average ice

season requiring 32 percent more than average operating hours to maintain the Great

Lakes and Northeast shipping channels during the ice season. Additionally, Coast Guard

Cutter Polar Star was reactivated during FY 2013, after having zero operating hours

since FY 2006. In comparison to FY 2013, FY2012 was a slightly below average ice

season, requiring four percent fewer operating hours than average to maintain the

Great Lakes and Northeast shipping channels during the ice season.

www.oig.dhs.gov 20 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

Source:DHS OIG based on USCGͲprovided data.

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

Baseline201120122013

Resource Hours

Ice Operations Resource Hours

Fiscal Year

Performance Measures and Results:The USCG reported that it met its FY 2013 target

for the number of days critical waterways are closed to commerce due to ice. Favorable

environmental conditions, continued partnership with the Canadian Coast Guard, and

effective employment of domestic icebreaking assets contributed to achieving the

performance target.

Ice Operations

Performance Measure –

Number of Days Critical Waterways Are Closed to Commerce Due to Ice

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

0 0 2 avg. & 8 severe 1



Not Met



Met



Met

Source: DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 21 OIGͲ14Ͳ140
 

 

Appendix D

Homeland Security Missions

The FY 2013 homeland security mission resource hours totaled 284,496, a decrease of

approximately 19 percent from FY 2012, but remains 53 percent above the baseline, as

depicted in the following graph.

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Source:DHS OIG based on USCGͲprovided data.

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

Baseline201120122013

Resource Hours

Homeland Security Resource Hours

Fiscal Year

In FY 2013, the USCG reported that it met or exceeded 6 of 11 summary performance

measures for its 5 homeland security missions, compared with meeting 2 of 11 summary

performance measures in FY 2012. The resource hours and performance measures and

results for each homeland security mission are summarized in the following subsections.

Ports, Waterways, and Coastal Security

The ports, waterways, and coastal security mission aims to deny terrorists the use and

exploitation of the maritime domain and marine transportation system as a means for

attacks on U.S. territory, population centers, vessels, and maritime critical infrastructure

and key resources. This mission includes preparedness, planning and exercises,

antiterrorism and counterterrorism activities, and initial recovery efforts if attacks

occur.

Resource Hours: In FY 2013, resource hours for ports, waterways, and coastal security

totaled 108,015, which is a decrease of 28 percent from FY 2012.

www.oig.dhs.gov 22 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Source:DHS OIG based on USCGͲprovided data.

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

Baseline201120122013

Resource Hours

Ports Waterways Coastal Security Resource Hours

Fiscal Year

Performance Measures and Results: USCG reported that it met five of its six FY 2013

targets for ports, waterways, and coastal security.

The maritime security risk measures are riskͲbased outcome measures that begin with

an assessment of likely highͲconsequence maritime terrorist attack scenarios. Threat,

vulnerability, and consequence levels are estimated for each scenario, which generates

a proxy (index) value of “raw risk” that exists in the maritime domain. Next, the USCG

interventions (security and response operations, regime and awareness activities) for

the fiscal year are scored against the scenarios with regard to the decreases in threat,

vulnerability, and consequence that each has been estimated to have afforded. The

resulting measures are proxy measures of performance.

As depicted in the following table, the USCG reported that it met its FY 2013 target for

the percent reduction of all maritime security risk subject to USCG influence.

Ports, Waterways, and Coastal Security

Performance Measure – Percent Reduction of All Maritime Security Risk Subject to USCG

Influence

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

44% 36% 36% 36%



Met

X 

Not Met Met

Source:DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 23 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

USCG met its FY 2013 target for percent reduction of all maritime security risk resulting

from USCG consequence management.

Ports, Waterways, and Coastal Security

Performance Measure – Percent Reduction of Maritime Security Risk Resulting from

USCG Consequence Management

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

4% 2% 4% 4%



Met

X 

Not Met Met

Source:DHS OIG based on USCGͲprovided data.

The USCG met its target for the percent reduction of maritime security risk resulting

from USCG efforts to prevent a terrorist from entering the United States via maritime

means.

Ports, Waterways, and Coastal Security

Performance Measure – Percent Reduction of Maritime Security Risk Resulting from USCG

Efforts to Prevent a Terrorist Entering the United States via Maritime Means

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

43% 34% 34% 34%

X X 

Not Met Not Met Met

Source:DHS OIG based on USCGͲprovided data.

USCG met its target for the percent reduction of maritime security risk resulting from

USCG efforts to prevent a weapon of mass destruction from entering the United States

via maritime means.

www.oig.dhs.gov 24 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

Ports, Waterways, and Coastal Security

Performance Measure – Percent Reduction of Maritime Security Risk Resulting from USCG

Efforts to Prevent a Weapon of Mass Destruction from Entering the United States via

Maritime Means

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

28% 24% 24% 24%

X X 

Not Met Not Met Met

Source:DHS OIG based on USCGͲprovided data.

USCG met its FY 2013 target for the annual Maritime Transportation Security Act facility

compliance rate with transportation worker identification credential regulations.

Ports, Waterways, and Coastal Security

Performance Measure – Annual Maritime Transportation Security Act Facility Compliance

Rate with Transportation Worker Identification Credential Regulations

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

99% 99% 99% 99.9%



Met



Met



Met

Source:DHS OIG based on USCGͲprovided data.

USCG missed its target for the third year for the measure now called “Security

Compliance Rate for High Risk Maritime Facilities.” It was previously titled “Percent of

Maritime Facilities in Compliance with Security Regulations.” USCG reported that for this

metric, “compliance” indicates that a facility did not receive a notice of violation or a

civil penalty for failure to comply with Federal regulations. While performance did not

fully achieve the target of 100 percent, data indicates the overall “Security Compliance

Rate for High Risk Maritime Facilities” remains extremely high at 99.3 percent (i.e., 99.3

percent, did not receive a notice of violation or civil penalty). This is an improvement

over 2012’s rate of 98.7 percent and is a positive indicator that the notice of violations

and/or civil penalties which were issued prompted corrective action.

FY 2011 was the first year tracking this measure.

www.oig.dhs.gov 25 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Ports, Waterways, and Coastal Security

Performance Measure –Security Compliance Rate for High Risk Maritime Facilities

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013_

Actual

99.9% 98.7% 100% 99.3%

X X X

Not Met Not Met Not Met

Source:DHS OIG based on USCGͲprovided data.

Drug Interdiction

USCG’s drug interdiction efforts support national strategies to disrupt the market for

illegal drugs and prevent transnational threats from reaching the United States. The

USCG is the lead Federal agency for maritime interdiction and shares the lead for drug

interdiction in the territorial seas of the United States with U.S. Customs and Border

Protection. The USCG coordinates with its interagency partners including the

Department of Defense, Department of Justice, Department of State, and other

components within DHS, to deter illicit drug trafficking.

Resource Hours:FY 2013 resource hours totaled 80,883, a decrease of 5 percent from

FY 2012, and 34 percent below baseline levels.

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

Baseline201120122013

Resource Hours

Drug Interdiction Resource Hours

Fiscal Year

Source:DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 26 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Performance Measures and Results: The USCG uses the interagency Consolidated

Counter Drug Database as its main source for tracking cocaine movement estimates.

The one performance measure related to drug interdiction, removal rate for cocaine

from noncommercial vessels in the maritime transit zone, was met in FY 2013.

Drug Interdiction

Performance Measure – Removal Rate for Cocaine from NonͲcommercial Vessels in

Maritime Transit Zone

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

11.6% 13.4% 14.1% 15.3%

X X  

Not Met Not Met Met

Source:DHS OIG based on USCGͲprovided data.

Migrant Interdiction

USCG’s Alien Migrant Interdiction Operations are designed to provide an effective law

enforcement presence at sea and achieve three main objectives: (1) deter

undocumented migrants and transnational human smugglers from using maritime

routes to enter the United States, (2) detect and interdict undocumented migrants and

human smugglers far from the U.S. border, and (3) expand USCG participation in multiͲ

agency and biͲnational border security initiatives. The USCG leads the interdiction

mission on the high seas, and it partners with U.S. Customs and Border Protection and

U.S. Immigration and Customs Enforcement for shoreside interdiction operations.

Resource Hours:Migrant interdiction resource hours remain about 90 percent above

baseline levels. In FY 2013, resource hours totaled 56,464, a decrease of 18 percent

from FY 2012.

www.oig.dhs.gov 27 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

Source:DHS OIG based on USCGͲprovided data.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

Baseline201120122013

Resource Hours

Migrant Interdiction Resource Hours

Fiscal Year

Performance Measures and Results:The USCG reported that it did not meet its two

performance measures related to migrant interdiction in FY 2013. Although the target

for percentage of undocumented migrants who attempt to enter the United States via

maritime routes that are interdicted was not met, the actual result of 68.9 percent was

a decrease from 73 percent in FY 2012.

Migrant Interdiction

Performance Measure – Percentage of Undocumented Migrants who Attempt to Enter the

United States via Maritime Routes that are Interdicted by U.S. Coast Guard and Other Law

Enforcement Agencies

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

72.8% 73.0% 73.3% 68.9%

X X X

Not Met Not Met Not Met

Source:DHS OIG based on USCGͲprovided data.

As shown in the following table, the USCG did not meet its target for the percentage of

undocumented migrants who attempt to enter the United States via maritime routes

interdicted by the Coast Guard by 17.2 percent. USCG reported that the Alien Migrant

Interdiction Operations mission was impacted by sequestration, both through decreased

awareness of events and through decreased resources available to respond to events.

USCG explained that in FY 2013, the USCG interdiction rate was

www.oig.dhs.gov 28 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

27 percent compared to 52.8 percent in FY 2012. The decrease is primarily due to the

large number of interdictions by partner nations, which accounted for 46 percent of

total interdictions. Those interdictions, while reflecting positively on the overall

interdiction rate for FY 2013 (68.9 percent), negatively impact the USCG interdiction

rate, since the USCG’s share of interdictions is smaller. Reduced coverage hours for

USCG Alien Migrant Interdiction Operations negatively affected the interdiction

percentage rate.

Migrant Interdiction

Performance Measure – Percent of Undocumented Migrants who Attempt to Enter the

United States via Maritime Routes Interdicted by the Coast Guard

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

51.7% 52.8% 44.8% 27.6%



Met



Met

X

Not Met

Source:DHS OIG based on USCGͲprovided data.

Defense Readiness

The USCG maintains a level of readiness and training that allows for immediate

integration with Department of Defense forces, for peacetime operations or during

times of war.

Resource Hours: In FY 2013, resource hours for defense readiness totaled 29,695.

Although resource hours decreased by 14 percent from FY 2012 to FY 2013, they were

still well above the baseline.

www.oig.dhs.gov 29 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

Baseline201120122013

Resource Hours

Defense Readiness Hours

Fiscal Year

Source:DHS OIG based on USCGͲprovided data.

Performance Measures and Results:The USCG did not meet its overall target of

percent defense readiness for the year. According to the USCG, the declining readiness

of its highͲendurance cutter fleet continues to pose significant challenges to mission

performance. HighͲEndurance Cutter fleet readiness challenges are being addressed in

part by modernization of assets, which will yield essential systemͲwide capability for

maritime homeland security mission areas and sustain operational performance.

Defense Readiness

Performance Measure – Defense Readiness Assessment of all USCG HighͲEndurance

Cutters, Patrol Boats, and Port Security Units

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

25.1% 27.2% 35.9% 24.2%

X

Not Met

X

Not Met

X

Not Met

Source:DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 30 OIGͲ14Ͳ140
 

 

Other Law Enforcement

The other law enforcement mission orchestrates the enforcement of regulations on

foreign fishing vessels. This enforcement takes two forms: the first is the deterrence,

detection, and interdiction of illegal incursions into the U.S. exclusive economic zone1 by

foreign fishing vessels. The protection of the U.S. exclusive economic zone from

incursions by foreign fishing vessels contributes to a fundamental USCG maritime

security objective to protect our Nation’s renewable natural resources. The second part

of the other law enforcement mission is to ensure compliance with international

agreements for the management of living marine resources. This is accomplished

primarily through enforcement of conservation and management measures created by

Regional Fishery Management Organizations.

Resource Hours:In FY 2013, resource hours for the Other Law Enforcement mission

totaled 9,439, a decrease of about 22 percent from FY 2012.

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Source:DHS OIG based on USCGͲprovided data.

Performance Measures and Results: The USCG uses the number of detected incursions

into the U.S. exclusive economic zone by foreign fishing vessels as a measure of its

performance. In FY 2013, there were 189 detected incursions of foreign fishing vessels

into the U.S. exclusive economic zone, which did not meet the performance target of

fewer than 140 incursions. According to the USCG, this is likely a result of increased

USCG and partner agency patrol efforts in the area.



1 The exclusive economic zone is the zone where the United States and other coastal nations have

jurisdiction over economic and resource management. The exclusive economic zone includes waters 3 to

200 miles offshore (or 9 to 200 miles offshore in western Florida and in Texas).

www.oig.dhs.gov 31 OIGͲ14Ͳ140

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

Baseline201120122013

Resource Hours

Other Law EnforcementResource Hours

Fiscal Year
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 


 

Other Law Enforcement

Performance Measure – Number of Detected Incursions of Foreign Fishing Vessels

Violating U.S. Waters

FY 2011

Actual

FY 2012

Actual

FY 2013

Target

FY 2013

Actual

122 160 <140 189



Met

X X

Not Met Not Met

Source:DHS OIG based on USCGͲprovided data.

www.oig.dhs.gov 32 OIGͲ14Ͳ140
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E

FY 2013 Performance Measure Summary

Mission Measure Met

Not

Met

NonͲHomeland Security Missions

Living Marine

Resources Fishing Regulation Compliance Rate X 

Marine Safety

5ͲYr Average Number of Recreational Boating Deaths and Injuries X 

5ͲYr Average Number of Commercial Mariner Deaths and Injuries X 

5ͲYr Average Number of Commercial Passenger Deaths and Injuries  X

5ͲYr Average Number of Commercial and Recreational Boating Deaths and

Injuries X 

Marine

Environmental

Protection

Average Number of Chemical Discharge incidents in the Maritime

Environment

X 

Average Number of Oil Spills in the Maritime Environment X 

Search and Rescue

Percentage of people in Imminent Danger Saved in the Maritime

Environment X

Percent of Time Rescue Assets are OnͲScene within 2 Hours X

AidsͲtoͲNavigation Availability of Maritime Navigation Aids X 

Average Number of Navigational Accidents X 

Ice Operations Number of Days Critical Waterways Are Closed to Commerce Due to Ice X 

Total NonͲHomeland Security Performance Measures 9 3

Homeland Security Missions

Ports, Waterways,

and Coastal Security

Percentage Reduction of all Maritime Security Risk Subject to USCG Influence X 

Percent Reduction of Maritime Security Risk Resulting from USCG

Consequence Management

X 

Percent Reduction of Maritime Security Risk Resulting from USCG Efforts to

prevent a Terrorist Entering the United States via Maritime Means X 

Percent Reduction of Maritime Security Risk Resulting from USCG Efforts to

Prevent a Weapon of Mass Destruction from Entering the United States via

Maritime Means

X 

Annual MTSA Facility Compliance Rate with Transportation Worker

Identification Credential Regulations X 

Security Compliance Rate For High Risk Maritime Facilities  X

Drug Interdiction Removal Rate for Cocaine from NonͲcommercial Vessels in Maritime Transit

Zone X 

Migrant interdiction

Percentage of Undocumented Migrants who Attempt to Enter the United

States via Maritime Routes that are Interdicted  X

Percent of Undocumented Migrants who Attempt to Enter the United States

via Maritime Routes Interdicted by the USCG  X

Defense Readiness Defense Readiness Assessment of all USCG HighͲEndurance Cutters, Patrol

Boats, and Port Security Units

X

Other Law

Enforcement

Number of Detected Incursions of Foreign Fishing Vessels Violating

U.S. Waters

X

Total Homeland Security Performance Measures 6 5

Total USCG Performance Measure 15 8

Source:DHS OIG based on USCGͲprovided data.

 

www.oig.dhs.gov 33 OIGͲ14Ͳ140
 

 

Appendix F

Major Contributors to This Report

Richard Johnson, Director

Cheryl Jones, Audit Manager

David DeHaven, AuditorͲinͲCharge

Richard Kotecki, Auditor

Mark Phillips, Auditor

Peter Christopher, Program Analyst, Referencer

www.oig.dhs.gov 34 OIGͲ14Ͳ140

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G

Report Distribution

Department of Homeland Security

Secretary

Deputy Secretary

Chief of Staff

Deputy Chief of Staff

General Counsel

Executive Secretary

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

United States Coast Guard

Commandant

Assistant Commandant for Resources and Chief Financial Officer

USCG Audit Liaison

Office of Management and Budget

Chief, Homeland Security Branch

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees, as appropriate

www.oig.dhs.gov 35 OIGͲ14Ͳ140
ADDITIONAL INFORMATION 

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other kinds of criminal or noncriminal misconduct relative to Department of Homeland 

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Should you be unable to access our website, you may submit your complaint in writing 

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Office of Inspector General, Mail Stop 0305 

Attention: Office of Investigations Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305 

You may also call 1(800) 323-8603 or fax the complaint directly to us at 

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