Special Report: 

Lessons Learned from 

Prior Reports on CBP's 

SBI and Acquisitions 

Related to Securing our 

Border 

June 12, 2017 

OIG-17-70-SR
 
 

 

 

 

DHS OIG SPECIAL REPORT

Lessons Learned from Prior Reports on CBP’s

SBI and Acquisitions Related to Securing our Border 
 

June 12, 2017 

Why We Did This 

Special Report 

This is a Department of 

Homeland Security Office of the 

Inspector General (DHS OIG), 

special report regarding the U.S. 

Customs and Border Protection’s 

(CBP) physical security of the 

southern border of the United 

States. This is the first in a series 

of reports about CBP’s physical 

security of the southern border. 

This report describes lessons 

learned from prior DHS-OIG, 

Government Accountability 

Office, and Department reports 

on CBP’s Secure Border Initiative 

(SBI), and other relevant CBP 

acquisitions related to securing 

our borders. 

What We 

Recommend 

We made no recommendations. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov

practices, DHS sometimes approves moving 

forward with major acquisition programs 

without appropriate internal oversight. 

www.oig.dhs.gov OIG-17-70-SR 

What We Found 

CBP currently faces an aggressive 

implementation schedule to satisfy its 

requirements under the President’s Executive 

Order. CBP is working on an acquisition plan 

while simultaneously preparing a solicitation 

for the design and build of a southern border 

wall. CBP must continue to be mindful of the 

lessons learned related to an aggressively 

scheduled acquisition in order to protect 

taxpayer dollars associated with the 

acquisition of the construction of a southern 

border wall. 

Prior reports (see Appendix A) found that CBP 

did not have defined and validated 

operational requirements resulting in 

unachievable performance. CBP also lacked a 

proper acquisition workforce that resulted in 

missteps, waste, and delays. In addition, CBP 

did not have robust business processes and 

information systems needed to enable 

program offices to move forward expeditiously 

on the tasks of managing to program 

objectives. 

Although DHS has made much progress, it 

needs to continue toward a strong central 

authority and uniform policies and 

procedures. Most of DHS’s major acquisition 

programs continue to cost more than 

expected, take longer to deploy than planned, 

or deliver less capability than promised. 

Although its acquisition policy includes best 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

June 12, 2017 

MEMORANDUM FOR: The Honorable General John F. Kelly 

Secretary 

Department of Homeland Security 

FROM: John Roth 

Inspector General 

SUBJECT: Special Report: Lessons Learned from Prior Reports 

on CBP’s SBI and Acquisitions Related to Securing 

our Border 

Attached is our final special report, Lessons Learned from Prior Reports on 

CBP’s SBI and Acquisitions Related to Securing our Border. This report was 

conducted under the Inspector General Act of 1978, as amended, Section 2-2, to 

provide leadership and coordination and recommend policies for activities 

designed to promote economy, efficiency, and effectiveness in the 

administration of, and to prevent and detect fraud and abuse in, such 

programs and operations. 

This report describes lessons learned from prior DHS-OIG, Government 

Accountability Office, and Department reports on CBP’s Secure Border 

Initiative, and other relevant CBP acquisitions related to securing our borders. 

We made no recommendations in this report. 

We provided a draft report for your comments. We received the Department’s 

response and also received technical comments from CBP. We have included 

the Department’s response as an appendix in this report and incorporated the 

CBP technical comments as appropriate. Consistent with our responsibility 

under the Inspector General Act, we will provide copies of this report to 

appropriate congressional committees with oversight and appropriation 

responsibility over the Department of Homeland Security. We will post a 

version of the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact John V. Kelly, 

Deputy Inspector General, at (202) 254-4100. 

Attachment 

www.oig.dhs.gov 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

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

Security and Immigration Enforcement Improvements. The Executive Order 

directed executive departments and agencies to deploy all lawful means to 

secure the Nation’s southern border through the immediate construction of a 

physical wall, monitored and supported by adequate personnel so as to prevent 

illegal immigration, drug and human trafficking, and acts of terrorism. 

Subsequently, DHS Secretary John F. Kelly issued a memorandum 

implementing the President’s border security and immigration enforcement 

improvements policies. Specifically, Secretary Kelly instructed U.S. Customs 

and Border Protection (CBP) to immediately begin planning, design, 

construction, and maintenance of a wall, along the land border with Mexico, 

utilizing appropriate materials and technology to most effectively achieve 

operational control of the border. 

According to the Department, CBP has taken immediate action in response to 

the Executive Order and has identified locations near El Paso, Texas; Tucson, 

Arizona; and El Centro, California; to build a wall where fencing is no longer 

effective. U.S. Border Patrol (Border Patrol) is currently conducting an 

operational assessment to identify priority areas for building a wall or similar 

physical barrier where none exists. 

Border Patrol’s operational assessment will address: 

x The current state of southern border security; 

x All geophysical and topographical aspects of the southern border; and 

x The availability of Federal and state resources necessary to achieve 

operational control of the southern border. 

This operational assessment aims to inform DHS’s strategy to obtain and 

maintain operational control of the southern border and is to be completed 

within 180 days of the announcement of the Executive Order. 

On March 17, 2017, CBP released two Requests for Proposal to award 

Indefinite Delivery Indefinite Quantity (IDIQ) Task Order contracts for the 

design and construction of wall prototypes with the capacity to issue future 

task orders for construction along the southwest border. The award amount for 

each IDIQ shall not exceed $300 million. The first Request for Proposal is for a 

solid concrete border wall, and the second is for an “Other Border Wall” 

incorporating a see-through capability to facilitate situational awareness. CBP’s 

goal is to award a contract by June 12, 2017, and begin construction of four to 

six prototypes by July 21, 2017. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Parallel to the wall construction, CBP reports it will be examining the Concept 

of Operations for a wall system that includes resources, infrastructure, and 

technology for the entire southern border. CBP will ensure that the results of 

this examination are incorporated into relevant, ongoing and future 

requirement development efforts. 

CBP guards nearly 2,000 miles of U.S. land border with Mexico, deterring, 

detecting, and interdicting illegal entry of people and contraband into the 

United States while facilitating lawful travel and trade. Currently, there is 654 

miles of fencing along the southwest border, consisting of 354 miles of 

pedestrian fence and 300 miles of vehicle fence. See table 1 for a breakdown of 

southwest border fencing miles. 

Table 1: Southwest Border Fencing Miles 

Land Type Primary Pedestrian 

Fence Miles 

Primary Vehicle 

Fence Miles 

Federal 294 298 

Private 60 0 

Tribal 0 2 

Total 354 300 

Source: CBP Facilities Management and Engineering Division 

Pedestrian fencing is mostly in urban areas of California, Arizona, and Texas. 

CBP also erected several miles of fence in the rural areas of the Arizona Yuma 

Sector. Most of the vehicle barriers along the southwest border are in rural 

areas where, according to CBP, pedestrian traffic is uncommon or easily 

detected. These barriers are designed to deny vehicle entry while allowing 

pedestrians and animals to pass freely. According to CBP, segments that 

require maintenance or upgrade repairs such as breach and erosion issues are 

fixed as they are identified. 

DHS Acquisition Framework and Lessons Learned 

From Prior Reports on CBP’s Secure Border Initiative 

The Department will be making a significant investment to satisfy its 

requirements under the President’s Executive Order. The Department has 

historically had significant challenges with acquisitions but has taken steps to 

strengthen department-wide acquisition management, such as establishing an 

Acquisition Life Cycle Framework (Acquisition Framework) and creating the 

Office of Program Accountability and Risk Management in 2011. 

DHS established the Acquisition Framework to assure consistent and efficient 

acquisition management, support, review, and approval throughout the 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Department. The framework is designed to ensure that acquisitions are stable 

and well managed; that the program manager has the tools, resources, and 

flexibility to execute the acquisition; that the product meets user requirements; 

and that the acquisition complies with applicable statutes, regulations, and 

policies. 

As shown in figure 1, the Acquisition Framework is a 4-phase process that 

DHS uses to determine whether to proceed with an acquisition: 

1. Need – identify the need that the acquisition will address; 

2. Analyze/Select – analyze the alternatives to satisfy the need and select 

the best option; 

3. Obtain – develop, test, and evaluate the selected option and determine 

whether to approve production; and 

4. Produce/Deploy/Support/Dispose – produce and deploy the selected 

option and support it throughout the operational life cycle. 

The DHS Acquisition Framework is structured to operate within a series of 

phases each leading to an Acquisition Decision Event (Decision Event), a 

predetermined point within an acquisition phase at which the acquisition will 

undergo a review prior to commencing the next phase. The review is designed 

to ensure that needs are aligned with DHS’s strategic direction, and that 

upcoming phases are adequately planned. 

Figure 1: 4-Phase Acquisition Life Cycle Framework 

Source: DHS Acquisition Management Instruction 102-01-001 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Prior to every decision event, components are required to submit acquisition 

documents to the Acquisition Review Board, the cross-component board in the 

Department composed of senior-level decision makers, for review, including: 

x Mission Needs Statement: Outlines specific functional capabilities 

required to accomplish the Department’s mission and objectives, along 

with deficiencies and gaps in these capabilities. 

x Capability Development Plan: Defines how critical knowledge to inform 

decisions will be obtained, defines the objectives, activities, schedule, 

and resources for the next phase. 

x Acquisition Plan: Provides a top-level strategy for future sustainment and 

support and a recommendation for the acquisition approach and types of 

acquisition. 

Each phase ends with a presentation to the Acquisition Review Board. The 

Acquisition Review Board determines whether a proposed acquisition meets the 

requirements of key phases in the Acquisition Framework and is able to 

proceed to the next phase and eventual full production and deployment. The 

Acquisition Review Process ensures appropriate implementation of the 

Acquisition Review Board’s decisions. 

Strong and clear definitions of operational requirements appropriately focus 

and stabilize the direction of program plans. Contracts expedited too quickly 

without proper and meaningful reviews by knowledgeable and experienced DHS 

staff, in response to aggressive program deadline requirements, may result in 

higher costs, schedule delays, and failures to accomplish adequate technical or 

critical mission requirements. 

Need Phase 

At the time of our review, CBP was in the Need Phase of the Acquisition 

Framework for a physical wall to secure the southern border. The purpose of 

this phase is to ensure alignment of needs to strategic DHS direction along 

with adequate planning and resourcing for upcoming phases. On March 20, 

2017, the Acquisition Review Board granted permission to CBP to proceed to 

Decision Event 1, meaning to validate the need. 

CBP submitted to DHS’s Joint Requirements Council its Capability Analysis 

Report (capability analysis), which identified Impedance and Denial1 as one of 

 1 “Impedance and Denial” refers to the capability to impede border incursions and deny the 

adversary's use of terrain (i.e., land, air, water) for advantage in conducting illegal activity and 

acts of terrorism. Additionally, Impedance enhances the U.S. Border Patrol's capability to 

execute its mission essential tasks by increasing adversary vanishing times and giving law 

enforcement capabilities more time to detect and respond.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the master capabilities required for operational control of a safe and secure 

border. 

The DHS Joint Requirements Council approved the capabilities analysis but 

identified additional action items in order to graduate to the Obtain Phase of 

the acquisition process. Specifically, the Joint Requirements Council requested 

CBP develop and submit a concept of operations that addresses the following: 

x	 Refine areas from the capability analysis and Mission Needs Statement, 

including robust description of the as-is capability, a quantification of 

the gap, measures of operational outcomes, and description of solution 

approach. 

x	 Identify: 

o	 A relationship of solution approach with other assets, systems, 

capabilities, and procedures, including those being addressed as 

part of the current Domain Awareness Land Surveillance efforts.2 

o	 How CBP will use the capability in actual operations or business 

processes, including the 

 Solution approaches outlined in Secretary Kelly's February 

17, 2017 memo, and 

 Patrol and access roads along the land border with Mexico to 

most effectively achieve operational control of the border. 

o	 How CBP would employ and support the solution approach to meet 

objectives and fill related capability gaps; and 

o	 How the solution approach would fulfill user requirements.

To its credit, CBP is in the process of refining its capability needs by issuing its 

Requests for Proposal for the design and construction of wall prototypes. 

However, without a foundation of well-defined, validated operational 

requirements, acquisition programs flounder and often result in wasted effort, 

the inefficient use of resources, and a system or product that does not achieve 

the desired result. Prior reports identified that CBP did not have defined and 

validated operational requirements resulting in unachievable performance. 

 2 Domain Awareness Land Surveillance refers to the ability to continuously detect, identify, 

classify, and track all border incursions (land, air, maritime, and subterranean) in targeted 

areas under all weather, terrain, vegetation, and light conditions for providing security-indepth along the border area. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

For instance, in our audit of the SBInet program in 2006,3 we reported that 

CBP bypassed existing required processes. Key decisions about the scope of the 

program and the acquisition strategy were made without rigorous review, 

analysis, or transparency. As a result, CBP awarded a multimillion dollar 

contract without having laid the foundation to oversee and assess contractor 

performance and control cost and schedule.4 

We also identified that although CBP made progress in recognizing the Border 

Patrol’s operational requirements for technology and tactical infrastructure, 

better documented and defined operational requirements for tactical 

infrastructure would ensure that border fence construction was linked to 

resource decisions and mission performance goals.5 

CBP ultimately terminated SBInet in 2011 after expending about $1 billion. 

SBInet clearly illustrates that poorly defined and documented operational 

requirements, and failure to adequately plan, results in missed milestones and 

wasted resources. This further hampers adequate definition of customer needs 

in the contract solicitation. CBP’s missteps with SBInet’s planning should be a 

reminder of the importance of proper planning of major acquisitions and that 

acquisition controls should not be bypassed. 

Analyze and Select Phase 

The Analyze and Select Phase identifies and explores alternative ways to fill 

gaps in the Mission Needs Statement with mission effective, suitable, and 

affordable solutions. It also allows decision makers to select the optimal 

solution to effectively deliver required capability to users. 

This is accomplished with the completion of an Analysis of Alternatives. The 

Analysis of Alternatives is an analytical comparison (from a high-level cost and 

performance perspective) of selected solution alternatives for fulfilling the 

specific capability need. The Analysis of Alternatives explores these alternatives 

with the goal of identifying the most promising approach to achieve userrequired capabilities within practical performance, cost, schedule, and risk 

boundaries. 

 3 Secure Border Initiative Net (SBInet) is a component of the overall SBI effort intended to 

improve border control operations, deploying more infrastructure and personnel with 

modernized technology and tactics. 

4 OIG-07-07, Risk Management Advisory for the SBInet Program Initiation, November 14, 2006 

5 OIG-09-56, Progress in Addressing Secure Border Initiative Operational Requirements and 

Constructing the Southwest Border Fence, April 15, 2009 

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OFFICE OF INSPECTOR GENERAL 

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A full life cycle cost estimate is developed during this phase to support the 

preferred solution. The Acquisition Decision Authority approves the 

recommendation from the program for the best alternative that provides the 

required performance at acceptable cost, schedule, and risk. 

As previously stated, the Acquisition Review Board approved CBP to progress to 

Decision Event 1 of the Acquisition Framework. In its approval memorandum, 

the Acquisition Review Board also granted CBP permission to develop a 

procurement solution that allows for the purchase and delivery of four to six 

wall prototypes and possible construction of a larger prototype in Yuma, 

Arizona, or San Diego, California, to support Alternatives Analysis and to refine 

its requirements. 

CBP reports the wall will be constructed and delivered in segments, as 

prioritized by CBP, and each segment, succeeding the prototype phase, will be 

assessed by the Acquisition Review Board to baseline the segment and 

determine affordability. The DHS Chief Acquisition Officer will be the 

Acquisition Decision Authority. A limited Alternatives Analysis will be 

performed that will focus on the prioritization of segments and the technical 

solution that best supports each segment. Before program approval and 

identification of cost, schedule, and performance parameters (Decision Events 

2A and 2B) each segment will also require: 

x Life Cycle Cost Estimate, 

x Acquisition Program Baseline, 

x Integrated Logistics Support Plan, 

x Certification of Funds memorandum, 

x Operational Requirements Document, and 

x Test and Evaluation Master Plan. 

These items are required before each segment delivery. 

Prior reports identified that CBP did not have a comprehensive plan for 

justifying its needs in a timely manner and at a reasonable cost. These reports 

also identified that CBP did not have an overall strategy for managing its 

acquisitions along the southwest border. 

In 2011, the Government Accountability Office (GAO) reported CBP did not 

document the analysis justifying the specific types, quantities, and deployment 

locations of border surveillance technologies proposed in the Arizona Border 

Surveillance Technology Plan (Plan). In addition, CBP’s life cycle cost estimate 

for the Plan did not sufficiently meet characteristics of a high-quality cost 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

estimate, such as credibility, because it did not identify a level of confidence or 

quantify the impact of risks.6 

We also reported in 2014, that CBP did not effectively plan employee housing 

in Ajo, Arizona, and made decisions that resulted in additional costs totaling 

$4.6 million. CBP spent about $680,000 per house and about $118,000 per 

mobile home for employee housing in Ajo, which was significantly more than 

the Ajo average home price of $86,500. CBP also offered to purchase land in 

Ajo, Arizona before evaluating the cultural, social, and environmental impact of 

housing construction as required by Federal law. In doing so, CBP took a risk 

that, depending on the outcome of the evaluation, it might not be able to build 

on the land and would possibly have to sell or donate it.7 

CBP also faced challenges such as land acquisition and environmental 

requirements which impeded fence construction progress.8 According to 

National Environmental Policy Act (42 USC 4321) and other laws involving 

extensive public and federal agency participation, CBP is required to conduct 

environmental impact assessments prior to constructing fencing and vehicle 

barriers unless these requirements are waived by the Secretary of Homeland 

Security. 

Environmental impact assessments determine the potential impacts on a range 

of issues, including geologic, biological, cultural resources, social and economic 

profiles, and land use of the area. Section 102(c) of The Illegal Immigration 

Reform and Immigrant Responsibility Act of 1996, as amended, allows the 

Secretary to waive legal requirements in order to ensure the expeditious 

construction of barriers and roads. 

In his April 2017 testimony before the United States Senate, Secretary Kelly 

indicated that CBP is committed to proceeding in an environmentally sensitive 

manner to build a wall where it makes sense. Environmental, geographical, 

cultural resources, social, and economic profiles along the border with Mexico 

could have a significant impact on the costs associated with securing the 

southwest border. CBP must be mindful that coordinating with other 

government agencies will require additional time and resources that could 

impede or delay fence construction progress. These factors make planning the 

most important phase in the acquisition process. The planning phase is when 

the efforts of all personnel responsible for an acquisition are coordinated and 

 6 GAO-12-22, More Information on Plans and Costs Is Needed before Proceeding, November 4, 

2011

7

OIG-14-131, CBP Did Not Effectively Plan and Manage Employee Housing in Ajo, Arizona, 

October 6, 2014 

8 OIG-09-56, Progress in Addressing Secure Border Initiative Operational Requirements and 

Constructing the Southwest Border Fence, April 15, 2009 

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OFFICE OF INSPECTOR GENERAL 

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integrated through a comprehensive plan for fulfilling the agency need in a 

timely manner and at a reasonable cost. It also includes developing the overall 

strategy for managing the acquisition. 

Obtain Phase 

The Obtain Phase develops, tests, and evaluates the preferred alternative 

selected to obtain the capability. The Acquisition Program Baseline is further 

refined by providing more detail on specific cost, schedule, and performance 

parameters. 

Prior reports have identified that DHS did not effectively manage, plan, and 

execute SBInet testing. SBInet was intended to cover the entire southwest 

border with an integrated set of fixed sensor towers. Early in its design, SBInet 

gave little, if any, consideration to other technologies, as the presumption was 

that SBInet would handle all technology needs. 

In 2010, GAO reported that CBP’s test plans, cases, and procedures for 

component and system qualification tests were not defined in accordance with 

important elements of relevant guidance. GAO also noted that changes made to 

system qualification test cases and procedures appeared to be designed to pass 

the test instead of being designed to qualify the system.9 GAO also identified 

that CBP relaxed the stringency of performance capabilities to the point that 

system performance would have been deemed acceptable if it identified less 

than 50 percent of items of interest that cross the border, resulting in a system 

that was unlikely to live up to expectations.10 

DHS had also not tested the individual system components to be deployed to 

the initial locations, even though the contractor initiated integration testing of 

these components with other system components and subsystems. Because of 

this issue, there was an increased risk that SBInet may not have performed as 

intended.11 

Over time, DHS advised CBP to conduct an Analysis of Alternatives of SBInet. 

As a result, CBP’s analysis identified that proven, commercially available 

systems could fill critical gaps in capability and that the original SBInet plans 

did not fill those gaps. CBP proposed diverting SBInet funding to a new border 

 9 GAO-10-158, Secure Border Initiative: DHS Needs to Address Testing and Performance 

Limitations That Place Key Technology Program at Risk, January 29, 2010 

10 GAO-10-340, DHS Needs to Reconsider Its Proposed Investment in Key Technology Program, 

May 5, 2010

11 GAO-08-1086, Secure Border Initiative: DHS Needs to Address Significant Risks in Delivering 

Key Technology Investment, September 22, 2008

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OFFICE OF INSPECTOR GENERAL 

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security technology plan for Arizona, and eventually the remainder of the 

border. 

In March 2014, GAO reported that CBP’s Test and Evaluation Master Plan12 

only described testing to determine the Integrated Fixed Tower’s13 mission 

contribution but did not include testing operational effectiveness and 

suitability, which specifically identifies how effective and reliable a system is in 

meeting its operational requirements in its intended environment. Revising the 

Test and Evaluation Master Plan to include more robust testing to determine 

operational effectiveness and suitability could have better positioned CBP to 

evaluate Integrated Fixed Tower capabilities before moving to full production 

for the system. Also, it could have helped provide CBP with information on the 

extent to which the towers satisfy the Border Patrol’s user requirements and 

helped reduce potential program risks.14 

Without strong and clear definitions of operational requirements related to a 

physical wall along 2,000 miles of border, CBP may not properly focus and 

stabilize the direction of the acquisition. Prior reports identified that CBP did 

not have defined and validated operational requirements resulting in 

unachievable performance. Failure to adequately plan may result in poorly 

defined and documented requirements, further hampering adequate definition 

and evaluation of needs. 

Produce/Deploy/Support/Dispose Phase 

Based on successful completion of required documents, the Acquisition 

Decision Authority may authorize initiation of the 

Produce/Deploy/Support/Dispose Phase of the acquisition program at 

Decision Event 3. This phase produces and maintains capabilities to meet the 

needs identified for the acquisition program. 

Prior reports have shown that although CBP has implemented many new 

programs to address border security issues, it has struggled to develop 

measures of effectiveness. CBP also has had trouble ensuring it has enough 

staff to adequately manage programs and contractors. If this struggle persists 

CBP could have challenges in adequately overseeing acquisitions, building 

 12 The Test and Evaluation Master Plan is important because it describes the strategy for 

conducting developmental and operational testing to evaluate a system’s technical 

performance, including its operational effectiveness and suitability. 

13 The Integrated Fixed Tower consists of towers with, among other things, ground surveillance 

radars and surveillance cameras mounted on fixed towers. 14 GAO-14-368, Arizona Border Surveillance Technology Plan: Additional Actions Needed to 

Strengthen Management and Assess Effectiveness, March 3, 2014

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metrics into program planning and management, and collecting reliable and 

complete data for cost estimating and program performance. 

For example, in June 2009, we identified that CBP had not established 

adequate controls and effective oversight of contract workers responsible for 

providing SBI program support services. Contract personnel made up more 

than 50 percent of the SBI workforce, and CBP had not clearly distinguished 

between roles and responsibilities that were appropriate for contractors and 

those that must be performed by government employees.15 

The low number of government personnel to oversee contractor activities 

increased the SBI program office’s risk that program cost and schedule could 

not be adequately managed. Consequently, the SBI program office’s ability to 

ensure that both current and future program goals were accomplished was 

reduced. In our June 2010 report, we found that CBP program officials did not 

ensure that contractors maintained up-to-date information in the primary 

management tool designed to provide managers with advance information 

regarding potential cost overruns and program progress.16 

Similarly, in October 2010, GAO reported that CBP did not ensure its 

contractor had effectively implemented earned value management. Earned 

value management is a proven management approach for understanding 

program status and identifying early warning signs of impending schedule 

delays and cost overruns. CBP regularly received incomplete and anomalous 

earned value management data from the SBInet prime contractor, which it had 

to rely on to measure progress and project the time and cost to complete the 

program.17 

In our review of CBP’s use of Unmanned Aircraft Systems program we reported 

that CBP had not developed performance measures to prove the program was 

effective. Although CBP anticipated increased apprehensions of illegal border 

crossers, a reduction in border surveillance costs, and improvement in the 

Border Patrol’s efficiency, the report found little or no evidence that CBP met 

those program expectations. The report concluded that CBP invested 

significant funds in a program that did not achieve the expected results, and 

could not demonstrate how much the program has improved border security.18 

 15 OIG-09-80, Better Oversight Needed of Support Services Contractors in Secure Border Initiative 

Programs, June 17, 2009 

16 OIG-10-96, Controls Over SBInet Program Cost Schedule Could Be Improved, June 16, 2010 

17 GAO-11-6, Secure Border Initiative: DHS Needs to Strengthen Management and Oversight of 

Its Prime Contractor October 18, 2010 

18 OIG-15-17, U.S. Customs and Border Protection's Unmanned Aircraft System Program Does 

Not Achieve Intended Results or Recognize All Costs of Operations, December 24, 2014 

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Because CBP lacks strong well-defined operational requirements and an overall 

strategy framework for securing the 2,000 miles of border, CBP may not 

properly focus and stabilize the direction of the acquisition.19 

Conclusion 

Acquisition planning is one of the most important phases in the acquisition 

process. It is the process by which all efforts of all personnel responsible for an 

acquisition are coordinated and integrated through a comprehensive plan for 

fulfilling the agency need in a timely manner and at a reasonable cost. It also 

includes developing the overall strategy for managing the acquisition. Failure to 

adequately plan may result in missed milestones and poorly defined and 

documented requirements. This further hampers adequate definition of 

customer needs in the contract solicitation. 

CBP currently faces an aggressive implementation schedule as it did with SBI 

and SBInet, though CBP officials we met with stated they understand the value 

of pre-solicitation activities. CBP is working on an acquisition plan while 

simultaneously preparing a solicitation for the design and build of a southern 

border wall. CBP must continue to be mindful of the lessons learned about an 

aggressively scheduled acquisition in order to protect taxpayer dollars 

associated with the acquisition of the construction of a southern border wall. 

OIG Analysis of Management Comments 

We obtained written comments on a draft of this report from the Director of the 

Departmental GAO-OIG Liaison Office. We have included a copy of the comments 

in their entirety in appendix C. In its comments, DHS concurred with our 

conclusion and stated it believes that based on the lessons it learned from 

SBInet, DHS is better positioned to face the challenges in satisfying the 

requirements of Executive Order 13767. 

 19 OIG-17-39, CBP’s Border Security Efforts – An Analysis of Southwest Border Security 

Between the Ports of Entry, February 27, 2017

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Scope and Methodology 

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

Security and Immigration Enforcement Improvements directing executive 

departments and agencies to deploy all lawful means to secure the Nation’s 

southern border through the immediate construction of a physical wall, 

monitored and supported by adequate personnel so as to prevent illegal 

immigration, drug and human trafficking, and acts of terrorism. 

Due to the impact on the Department and CBP, the objective of this review was 

to identify lessons learned from prior Office of Inspector General (OIG), GAO, 

and Department reports on CBP’s Secure Border Initiative that began in 2005 

and ended in 2011. We also reviewed other relevant CBP acquisition audit 

reports related to securing our borders. 

To accomplish our objective, we reviewed the Secretary’s February 20, 2017 

memorandum – Implementing the President's Border Security and Immigration 

Enforcement Improvements Policies. We reviewed prior OIG, GAO, and 

Department reports on CBP’s Secure Border Initiative. We also reviewed other 

relevant CBP acquisition audit reports related to securing our borders. 

Additionally, to identify lessons learned we reviewed Homeland Security 

Studies and Analysis Institute’s SBInet Analysis of Alternatives Report. We also 

contacted the Department’s Joint Requirements Council and the Office of 

Program Accountability and Risk Management to formulate an understanding 

on where CBP was in the Acquisition Life Cycle Framework. 

This is the first in a series of reports about CBP’s physical security of the 

southern border. This report was conducted under the Inspector General Act of 

1978, as amended, Section 2-2, to provide leadership and coordination and 

recommend policies for activities designed to promote economy, efficiency, and 

effectiveness in the administration of, and to prevent and detect fraud and 

abuse in, such programs and operations. Our review focused on identifying 

Acquisition Life Cycle challenges identified through prior DHS OIG and GAO 

reports and internal DHS documents associated with constructing a physical 

barrier along the southern border. The work performed in this review does not 

constitute an audit in accordance with generally accepted government auditing 

standards. 

The Office of Audits major contributors to this report are: Maureen Duddy, 

Deputy Assistant Inspector General for Audits; Carolyn Hicks, Acquisitions 

Director; Paul Exarchos, Audit Manager; Jeff Mun, Auditor-in-charge; Corneliu 

Buzesan, Program Analyst, Steffanie Moore, Program Analyst, Roger Thoet, 

Auditor; Ellen Gallagher, Communications Analyst; and Frank Lucas, 

Independent Referencer. 

www.oig.dhs.gov 14 OIG-17-70-SR 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Prior DHS OIG Reports on CBP’s Secure Border Initiative, and 

Other Relevant CBP Acquisitions Related to Securing our 

Borders: 

DHS OIG reports can be found under the “Reports” tab at 

http://www.oig.dhs.gov/ 

x Risk Management Advisory for the SBInet Program Initiation (OIG-07-07, 

November 2006), https://www.oig.dhs.gov/assets/Mgmt/OIG_07-

07_Nov06.pdf 

x Progress in Addressing Secure Border Initiative Operational Requirements 

and Constructing the Southwest Border Fence (OIG-09-56, April 2009), 

https://www.oig.dhs.gov/assets/Mgmt/OIG_09-56_Apr09.pdf 

x	 Better Oversight Needed of Support Services Contractors in Secure Border 

Initiative Programs (OIG-09-80, June 2009), 

https://www.oig.dhs.gov/assets/Mgmt/OIG_09-80_Jun09.pdf 

x	 CBP's Construction of Border Patrol Facilities and Acquisition of Vehicles 

(OIG-09-91, July 2009), 

https://www.oig.dhs.gov/assets/Mgmt/OIG_09-91_Jul09.pdf 

x	 Controls Over SBInet Program Cost Schedule Could Be Improved (OIG-10-

96, June 2010), https://www.oig.dhs.gov/assets/Mgmt/OIG_10-

96_Jun10.pdf 

x	 U.S. Customs and Border Protection’s Management of the Purchase and 

Storage of Steel in Support of the Secure Border Initiative (OIG-12-05, 

November 2011), https://www.oig.dhs.gov/assets/Mgmt/OIG_12-

05_Nov11.pdf 

x	 CBP's Strategy to Address Illicit Cross-Border Tunnels (OIG-12-132, 

September 2012), https://www.oig.dhs.gov/assets/Mgmt/2012/OIG_12-

132_Sep12.pdf 

x	 CBP Did Not Effectively Plan and Manage Employee Housing in Ajo, 

 Arizona (OIG-14-131, October 2014), 

https://www.oig.dhs.gov/assets/Mgmt/2014/OIG_14-131_Oct14.pdf 

www.oig.dhs.gov 15	 OIG-17-70-SR 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x U.S. Customs and Border Protection's Unmanned Aircraft System Program 

Does Not Achieve Intended Results or Recognize All Costs of Operations 

(OIG-15-17, December 2014), 

https://www.oig.dhs.gov/assets/Mgmt/2015/OIG_15-17_Dec14.pdf 

x CBP’s Border Security Efforts – An Analysis of Southwest Border Security 

Between the Ports of Entry (OIG-17-39, February 2017), 

https://www.oig.dhs.gov/assets/Mgmt/2017/OIG-17-39-Feb17.pdf 

Prior GAO Reports on CBP’s Secure Border Initiative and Other 

Relevant CBP Acquisitions Related to Securing our Borders: 

x	 Secure Border Initiative: DHS Needs to Address Significant Risks in 

Delivering Key Technology Investment (GAO-08-1086, September 2008), 

http://www.gao.gov/assets/290/281239.pdf 

x	 Secure Border Initiative: Technology Deployment Delays Persist and the 

Impact of Border Fencing Has Not Been Assessed (GAO-09-896, 

September 2009), http://www.gao.gov/assets/300/294982.pdf 

x	 Secure Border Initiative: DHS Needs to Address Testing and Performance 

Limitations That Place Key Technology Program at Risk (GAO-10-158, 

January 2010), http://www.gao.gov/assets/310/300562.pdf 

x	 Secure Border Initiative: DHS Needs to Reconsider Its Proposed Investment 

in Key Technology Program (GAO-10-340, May 2010), 

http://www.gao.gov/assets/310/304036.pdf 

x	 Secure Border Initiative: DHS Needs to Strengthen Management and 

Oversight of Its Prime Contractor (GAO-11-6, October 2010), 

http://www.gao.gov/assets/320/311431.pdf 

x	 Secure Border Initiative: Controls over Contractor Payments for the 

Technology Component Need Improvement (GAO-11-68, May 2011), 

http://www.gao.gov/assets/320/318871.pdf 

x	 Arizona Border Surveillance Technology: More Information on Plans and 

Costs Is Needed before Proceeding (GAO-12-22, November 2011), 

http://www.gao.gov/assets/590/586102.pdf 

www.oig.dhs.gov 16	 OIG-17-70-SR 
x

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Arizona Border Surveillance Technology Plan: Additional Actions Needed 

to Strengthen Management and Assess Effectiveness (GAO-14-368, 

March 2014), http://www.gao.gov/assets/670/661297.pdf 

www.oig.dhs.gov 17 OIG-17-70-SR 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Timeline of Prior Reports 

2017 

2011 

2012 

2013 

2014 

2015 

2016 

2005 

2006 

2007 

2008 

2009 

2010 

SBInet Launch 

OIG-07-07 

CBP bypassed Key Decisions 

due to SBInet's aggressive 

schedule. 

GAO-08-1086 

SBInet program may not meet

mission needs or perform as

intended. OIG-09-56 

Progress made but need better

defined operational

requirements for tactical 

infrastructure. 

OIG-09-80 

CBP reliedon contractors (due 

to aggressive schedule), but 

provided inadequate oversight. 

GAO-09-896 

Border Patrol continued to rely

on existing technology due to

deployment delays. 

GAO-10-158 

New system defects increased 

faster than the number of 

defects that were fixed. 

OIG-10-96 

Info in management tool was 

not up-to-date regarding cost 

overrun or program progress. 

GAO-10-340 

DHS did not know whether its 

planned investment of SBInet 

would produce mission value. 

GAO-11-6 

DHS did not effectively

monitor SBInet contractor's 

progress in meeting cost and 

schedule expectations. 

GAO-11-68 

CBP's design of controls for

SBInet contractor payments

were not effective. 

OIG-12-05 

CBP did not effectively manage 

the purchase and storage of 

steel in support of SBI. 

GAO-12-22 

CBP did not have the 

information neededto support 

and implement its Plan. 

GAO-14-368 

CBP did not develop an

integrated master schedule for

the Plan in accordance with 

best practices. 

OIG-14-131 

CBP did not effectively plan 

and manage employee housing 

in Ajo, AZ resulting in

additional costs. 

OIG-15-17 

CBP did not adequately plan 

the resources needed to 

support its unmanned aircraft. 

EO13767 

Signed 

OIG-09-91 

CBP did not adequately plan 

the design and construction of 

its Border Patrol facilities. 

SBInet cancelled 

OIG-12-132 

PMO must address mission 

needs of both CBP and HSI to 

disrupt cross-border threats. 

OIG-17-39 

CBP faces program 

management challenges in 

planning and overall efficiency. 

www.oig.dhs.gov 18 OIG-17-70-SR 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Management Comments to the Draft Report

www.oig.dhs.gov 19 OIG-17-70-SR 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 20 OIG-17-70-SR 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

CBP Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 21 OIG-17-70-SR 
 

 

 

 

 

 

 

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

at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. Follow us on Twitter at: @dhsoig. 

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hotline at (202) 254-4297, or write to us at: 

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Attention: Hotline 

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