Department of Homeland Security

Office of Inspector General

DHS' Plan for Implementing Secure 

Systems of Transportation

OIG-09-03 October 2008
Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 October 24, 2008

Preface

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) 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. 

This report addresses the status of DHS’ plan to secure systems of transportation as 

required by the Coast Guard and Maritime Transportation Act of 2004. It is based on 

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

observations, and a review of applicable documents. 

It is our hope that this report will result in more effective, efficient, and economical 

operations. We express our appreciation to all of those who contributed to the 

preparation of this report. 

Richard L. Skinner 

Inspector General 
Table of Contents/Abbreviations 

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

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

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

Implementation Status of the Plan as of May 31, 2008.................................................3 

Late Submission of Plan to Congress ...........................................................................6 

Appendices

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

Appendix B: Management Comments..........................................................................9 

Appendix C: Status of Programs and Systems from the DHS Plan ..........................11 

Appendix D: National Planning Structure as Related to the International 

Cargo Supply Chain ...........................................................................23 

Appendix E: Major Contributors to This Report........................................................24 

Appendix F: Report Distribution ...............................................................................25 

Abbreviations

ACE Automated Commercial Environment 

ATS Automated Targeting System 

CBP Customs and Border Protection 

CONOPS Concept of Operations 

C-TPAT Customs-Trade Partnership Against Terrorism 

DHS Department of Homeland Security 

DNDO Domestic Nuclear Detection Office 

GAO Government Accountability Office 

MTSA Maritime Transportation Security Act of 2002 

NORM naturally occurring radioactive material 

OIG Office of Inspector General 

PEP Project Execution Plan 

PVT polyvinyl toluene 

SFI Secure Freight Initiative 

DHS’ Plan for Implementing Secure Systems of Transportation
OIG

Department of Homeland Security 

Office of Inspector General 

Executive Summary

Pursuant to the Coast Guard and Maritime Transportation Act of 2004,

the Department of Homeland Security must submit to Congress a plan for 

implementing secure systems of transportation by February 2005. The 

Act also required DHS to: analyze the resources necessary to conduct 

validations of trade partners; track containers entering the United States; 

develop international standards; and collect user fees. The Coast Guard 

Act also required us to report on the progress made by the department in 

implementing the plan. 

The department issued its Report to Congress on Secure Systems of 

Transportation on September 6, 2007, 2 1/2 years after the due date. By 

this time, the plan had been superseded by the passage of the Security and 

Accountability for Every Port Act of 2006. Although broader in scope, the 

Security and Accountability for Every Port Act of 2006 repeated and 

clarified the requirements of the Coast Guard Act. Although the 

department issued the plan late, it proceeded with the implementation of 

the programs and systems to secure systems of transportation. Also, the 

department did not timely conduct the analyses required by the Coast 

Guard Act. This report provides the status of the 10 programs and systems 

listed in the plan as of May 31, 2008.

Appendix D charts the relationships among the different requirements and 

the department’s plans on supply chain security. 

Due to the actions taken by the Secretary to ensure timely responses to 

congressional requests, we are not making recommendations in this report. 

Comments from Department of Homeland Security management are 

included in appendix B. 

DHS’ Plan for Implementing Secure Systems of Transportation 

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DHS’ Plan for Implementing Secure Systems of Transportation 

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Background

In response to the events of September 11, 2001, Congress passed the 

Maritime Transportation Security Act of 2002 (MTSA) to protect America’s 

maritime community against the threat of terrorism without adversely 

affecting the flow of U.S. commerce. One provision of MTSA required a 

program to evaluate and certify secure systems of international intermodal 

transportation. DHS assumed responsibility for MTSA after the Coast Guard 

transitioned to DHS in April 2003, pursuant to requirements of the Homeland 

Security Act.

The Coast Guard and Maritime Transportation Act of 2004 required DHS to 

submit a plan to implement the program required by MTSA by February 

2005. The Act also required the DHS Office of Inspector General (OIG) to 

report on DHS’ progress in implementing the plan. DHS’ Border and 

Transportation Security Directorate was responsible for preparing the plan, 

but the DHS Secretary abolished the directorate as part of an initiative to 

streamline DHS’ organizational structure. The Office of Policy assumed 

responsibility for coordinating plan development. 

Although broader in scope, the Security and Accountability for Every Port Act 

of 2006 (the SAFE Port Act) repeated and clarified requirements of both 

MTSA and the Coast Guard Act. The SAFE Port Act addressed security 

matters related to the movement of containers through the international supply 

chain. The Act created and codified new programs and initiatives, and 

amended some of the original provisions of MTSA. It included provisions 

that codified the Container Security Initiative and the Customs-Trade 

Partnership Against Terrorism (C-TPAT)—two programs administered by 

Customs and Border Protection (CBP) to help reduce threats associated with 

cargo shipped in containers. The Act also established the Domestic Nuclear 

Detection Office (DNDO) to complete a global nuclear detection architecture.

Further, the SAFE Port Act created an Office of Cargo Security Policy 

within DHS Office of Policy and tasked this office to coordinate all DHS 

policies relating to cargo security and to work with stakeholders and other 

federal agencies to establish standards and regulations and to promote 

best practices. The SAFE Port Act also required DHS to develop a 

strategic plan to enhance international supply chain security. DHS 

fulfilled this requirement in July 2007 by issuing the Strategy to Enhance 

International Supply Chain Security. In October 2007, the Government 

Accountability Office (GAO) testified before Congress on DHS’ progress 

in implementing the SAFE Port Act. The testimony highlighted 

improvements and challenges that DHS faces in three areas: overall port 

security, port facility security, and container security. 
DHS’ Plan for Implementing Secure Systems of Transportation 

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Results of Audit

Implementation Status of the Plan as of May 31, 2008 

In September 2007, DHS issued the Report to Congress on Secure Systems 

of Transportation—its plan for implementing secure systems of 

transportation in response to requirements of the Coast Guard Act. The 

plan provides information on implementation of various programs and 

systems to secure systems of transportation, but does not include the 

specific analyses required by the Coast Guard Act. 

Status of Programs and Systems in the Plan

The following is a brief overview and status update regarding the 10 

programs and systems the department instituted to help secure maritime 

containers entering the United States.

The Customs-Trade Partnership Against Terrorism (C-TPAT) is a 

voluntary government-business initiative designed to improve 

international supply chain security by providing incentives to 

businesses that meet certain security standards. As of May 31, 2008, 

CBP had certified 8,455 importers, carriers, and brokers as C-TPAT 

partners. The SAFE Port Act requires CBP to certify members within 

90 days, to validate those companies certified within 1 year of 

certification, and to conduct revalidations every 4 years to the extent 

possible and practical. As of May 31, 2008, CBP had 10 applicants 

for C-TPAT certification that were outstanding for more than 60 days 

and 2 that were outstanding for more than 90 days. 

The Container Security Initiative is a program in which CBP works 

with foreign customs organizations to shift the screening of maritime 

containerized cargo destined for the United States from domestic ports 

of entry to foreign ports of lading. As of May 31, 2008, CBP had met 

its goal of implementing the Container Security Initiative at 58 ports 

worldwide to prescreen 85 % of maritime containerized cargo destined 

for the United States. 

The Automated Targeting System (ATS) is a decision support 

system that performs an automatic risk assessment of cargo using 

weighted rules and measures. ATS alerts CBP officers of cargo that 

meets or exceeds predefined criteria. CBP continuously works to 

improve ATS with new technologies, techniques, and data sources.

As of May 31, 2008, CBP met its goal of screening 100 % of inbound 

cargo containers through ATS. Screening is defined as a visual or 

automated review of information about goods to determine the 
DHS’ Plan for Implementing Secure Systems of Transportation 

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presence of improperly declared, restricted, or prohibited items and to 

assess the level of threat posed by such cargo. 

The Automated Commercial Environment (ACE) is a system that 

allows CBP and the trade community to submit and retrieve data 

electronically through a secure Web portal. ACE will modernize 

targeting, inspection, enforcement, revenue collection, and trade 

statistics processing. CBP began developing ACE in August 2001 and 

plans to complete development by 2012. As of May 31, 2008, five 

ACE processes were operational, including: electronic truck manifest, 

cargo admissibility, cargo examination, cargo release, and conveyance 

crossing history.

The Secure Freight Initiative (SFI) is a pilot program at foreign 

ports for testing the feasibility of scanning 100 % of U.S.-bound 

containerized cargo with radiation detection equipment and 

nonintrusive imaging equipment. As of May 31, 2008, CBP was 

expanding SFI to additional foreign ports to test other challenges to 

the 100 % scanning goal. In June 2008, CBP reported to Congress on 

the legal, logistical, and technical challenges facing SFI. 

The World Customs Organization is an intergovernmental 

organization that developed the voluntary international customs 

standards known as the World Customs Organization SAFE 

Framework of Standards. As of May 31, 2008, 152 of 173 

organization members, including the United States, had signed a letter 

of intent to implement the SAFE Framework of Standards. 

Domestically, CBP is on step five of the six-step implementation 

process.

The International Ship and Port Facility Security Code is an 

amendment to the International Maritime Organization’s International 

Convention for the Safety of Life at Sea. This code prescribes 

minimum-security requirements to detect security threats and to take 

preventive measures against security incidents affecting ships and port 

facilities used in international trade. The DHS Secretary is required to 

assess the effectiveness of the antiterrorism measures maintained at 

foreign ports from which foreign vessels depart for the United States.

As of May 31, 2008, the Coast Guard continues to conduct foreign 

port visits on a 2-year cycle. 

Maritime Domain Awareness is the understanding of anything 

associated with the global maritime domain that could impact the 

security, safety, economy, or environment of the United States. The 

breadth of Maritime Domain Awareness requires a unified effort 









DHS’ Plan for Implementing Secure Systems of Transportation 

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through a collaborative network of partners. The National Concept of 

Operations for Maritime Domain Awareness lists various short-term 

goals for 0 to 5 years, midterm goals for 6 to 10 years, and long-term 

goals for 11 to 20 years. As of May 31, 2008, the Coast Guard had 

established the Maritime Domain Awareness Stakeholder Board to 

provide a cohesive governance structure for interagency efforts. 

The Advanced Spectroscopic Portal is a next-generation passive 

detection radiation portal monitor using spectroscopic analysis to 

distinguish between special nuclear materials and naturally occurring 

nuclear materials. As of May 31, 2008, DNDO was conducting 

performance tests to validate the Advanced Spectroscopic Portal’s 

detection abilities. 

The Cargo Advanced Automated Radiography System is a nextgeneration nonintrusive imaging system jointly managed by DNDO 

and CBP to improve CBP’s ability to identify shielded special nuclear 

materials. DNDO plans to complete developmental tests and 

evaluations of the system’s prototypes and a cost-benefit analysis of 

the entire program. As of May 31, 2008, the Cargo Advanced 

Automated Radiography System was in development and testing. 





For more detailed discussion of each program or system, including the 

status of open recommendations from previous GAO and OIG audits, see 

appendix C.

Status of Analyses Required by Congress

By 2006, DHS had not submitted to Congress the four analyses that the 

Coast Guard Act required. Congress repeated three of these requirements 

in greater detail in the SAFE Port Act of 2006. Following is the status of 

the three analyses required by the Coast Guard Act and repeated in the 

SAFE Port Act:

Section 218(a) required DHS to develop a plan to implement a 1-year 

voluntary pilot program to test and assess the feasibility, costs, and 

benefits of using third-party entities to conduct validations of C-TPAT 

participants. Section 218(b) required DHS to submit a report to 

Congress on the plan. On May 8, 2007, DHS transmitted the Report to 

Congress on SAFE Port Act Section 218(b): Customs-Trade 

Partnership Against Terrorism (C-TPAT) Third Party Validators Pilot 

Program Plan.

Section 406 required DHS to submit a report to Congress on in-bond 

cargo, including a plan for tracking in-bond cargo within the 

DHS’ Plan for Implementing Secure Systems of Transportation 

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Automated Commercial Environment. On October 17, 2007, DHS 

transmitted the Report to Congress on In-Bond Cargo.

Section 204(c) encouraged the DHS Secretary to promote and 

establish international standards for the security of containers moving 

through the international supply chain with foreign governments and 

international organizations. On May 18, 2007, DHS sent a letter to 

Congress explaining its decision not to initiate a rulemaking 

proceeding to establish minimum standards for securing containers in 

transit to the United States. In lieu of establishing standards, DHS 

requires C-TPAT participants to affix a high-security seal that must 

meet or exceed current international standards to all loaded containers 

bound for the United States. 

The fourth analysis required by the Coast Guard Act was repeated in the 

Implementing Recommendations of the 9/11 Commission Act of 2007 (the 

9/11 Act). The 9/11 Act required DHS to conduct a study of the need for 

and feasibility of establishing a system of maritime and surface 

transportation-related user fees that may be imposed and collected as a 

dedicated revenue source. As of October 2008, the department was 

reviewing a draft of the study on user fees. 

Late Submission of Plan to Congress

DHS issued its plan for implementing secure systems of transportation on 

September 6, 2007—2 1/2 years late. The Coast Guard Act required DHS 

to submit the plan to Congress within 180 days of enactment, which was 

February 7, 2005. 

The plan was developed to serve a twofold purpose. The Intelligence 

Reform and Terrorism Prevention Act of 2004 required DHS to submit to 

Congress a report of the status of MTSA’s program to evaluate and certify 

systems of transportation by March 17, 2005. Both the DHS plan and this 

new statutory requirement dealt with the same program, so DHS decided 

to merge the two requirements into one document. 

Initially, the Border and Transportation Security directorate convened a 

group of subject matter experts from across DHS to prepare the plan.

After the DHS Secretary abolished that directorate as part of an initiative 

to streamline DHS’ organization structure, the Office of Policy, which was 

established in July 2005, took over coordination of plan development. 

DHS then spent 5 months reviewing the plan and later spent 4 months 

responding to the Office of Management and Budget’s comments on it.

Another 7 months elapsed between the Office of Management and 

Budget’s clearance of the plan and its issuance. 
DHS’ Plan for Implementing Secure Systems of Transportation 

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In 2005, the new DHS Secretary made meeting congressional requests a 

higher priority because of the large number of inquiries that had not yet 

been responded to and the difficulties in providing timely responses. The 

department issued a management directive to improve DHS’ 

responsiveness to congressional requests. The directive provides clear 

guidance on the roles and responsibilities of various DHS officials and 

their offices in reviewing and addressing congressional requests.

In addition, DHS developed a tracking system to help meet its 

congressional requirements. Each week, the system is updated and shared 

with the Secretary’s Office. DHS also sends weekly reminders to 

component points of contact asking them to examine requests and update 

the system on progress or any delays in responding to them. Due to the 

actions taken by the Secretary to ensure timely responses to congressional 

requests, we are not making recommendations in this report. 
Appendix A 

Purpose, Scope, and Methodology

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The Coast Guard and Maritime Transportation Act of 2004 required DHS 

to submit a plan to Congress for implementing secure systems of 

transportation. The Act also required us to report on the department’s 

progress in implementing the plan. The objective of our audit was to 

determine DHS’ progress in implementing its plan for securing systems of 

transportation. 

We performed our audit fieldwork in Washington, D.C. Within DHS, we 

visited the Office of Policy, the Office of General Counsel, the Office of 

Chief Financial Officer, CBP, the Coast Guard, and DNDO. In addition, 

we contacted officials from the Operations Coordination and Planning 

Directorate. 

We worked with the DHS Office of General Counsel and the Cargo, 

Maritime and Trade unit of the Office of Policy Development to determine 

how DHS met the Coast Guard Act requirements by addressing 

subsequent legislative requirements. Also, we reviewed how DHS offices 

and bureaus implemented the plan. 

In addition, we reviewed the 10 programs and systems listed in the plan to 

determine how they will help to secure systems of international intermodal 

transportation, their status as of May 31, 2008, and the status of prior audit 

recommendations. We reviewed strategic plans, implementation plans, 

performance measures, reports to Congress, prior audit reports, and other 

documentation for each of the 10 programs and systems. Our discussion 

of the status of the 10 programs and systems contains information from 

both published reports and unaudited DHS management assertions. 

We reviewed the internal controls DHS put in place to meet congressional 

mandates. We interviewed DHS Office of General Counsel and Office of 

Chief Financial Officer officials involved in the process. We examined 

samples of the tracking system and reviewed the DHS management 

directive addressing the review and coordination of legislative documents. 

We conducted our audit between April and July 2008, according to 

generally accepted government auditing standards. Those standards 

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

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objective. Our reporting of the status of programs from 

the DHS Plan as of May 31, 2008, includes unaudited DHS management 

assertions. We believe that the evidence obtained, except as noted above, 

provides a reasonable basis for our findings and conclusions based on our 

audit objective.
Appendix B 

Management Comments

DHS’ Plan for Implementing Secure Systems of Transportation 

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Appendix B 

Management Comments

DHS’ Plan for Implementing Secure Systems of Transportation 

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Appendix C 

Status of Programs and Systems from the DHS Plan 

(The Status as of May 31, 2008 includes unaudited DHS management assertions.) 

DHS’ Plan for Implementing Secure Systems of Transportation 

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Customs-Trade Partnership Against Terrorism (C-TPAT)

C-TPAT is a voluntary government-business initiative to build cooperative 

relationships that strengthen and improve overall international supply 

chain and U.S. border security. Its goal is to shift responsibility for cargo 

security onto stakeholders in the supply chain. C-TPAT companies 

commit to meeting security standards in order to use their leverage to 

prevent terrorist organizations from exploiting their supply chains, thereby 

reducing the risk that a terrorist weapon will be introduced into, or 

concealed within, one of their shipments. Central to the security vision of 

C-TPAT is the core principle of increased facilitation for legitimate 

business entities that are compliant traders. In exchange for meeting 

minimum-security standards, cargo of C-TPAT partners is subject to fewer 

inspections upon arrival, thereby making C-TPAT-secured shipments 

move faster and more predictably. 

CBP conducts domestic and foreign site visits to physically review 

companies and to identify both weaknesses and best practices within their 

supply chains. C-TPAT has enabled CBP to leverage supply chain 

security throughout international locations where CBP has no regulatory 

reach. Further, CBP plans to internationalize the C-TPAT core principles 

through cooperation and coordination with the international community. 

C-TPAT is currently pursuing mutual recognition arrangements with 

several foreign partnership programs. 

CBP’s goal is to screen and separate transactions involving known lowrisk trade from the unknown high-risk trade. Ultimately, if C-TPAT 

partners adopt supply chain security best practices, the risk that terrorists 

could exploit their shipments to the United States will be reduced. This 

will allow CBP to focus efforts on higher risk shipments. 

The SAFE Port Act of 2006 codified C-TPAT and requires C-TPAT to 

monitor the timeframes established to complete certain objectives. The 

2008 C-TPAT Annual Plan includes new performance measures to ensure 

compliance with these requirements. The 2007–2012 C-TPAT Strategic 

Plan specifies the goals and objectives for C-TPAT and is aligned with 

and supports CBP’s Strategic Plan for Preventing Terrorist Weapons from 

Entering the United States.

As of May 31, 2008, CBP has certified 8,455 importers, carriers, and 

brokers as C-TPAT partners and completed 8,056 validations. There have 

been 556 suspensions or removals. CBP averages 145 validations per 

month and has 200 positions assigned to C-TPAT. 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 12

From 2003 through 2008, GAO conducted three audits of C-TPAT. These 

audits made 14 recommendations, of which 6 were open as of May 31, 

2008. Of the open recommendations, five are from a GAO report issued 

in April 2008. The open issues relate to improving performance measures, 

improving the validation process, and adding data elements to the records 

management system. 

Container Security Initiative

As a critical element of DHS’ multilayered defense strategy, the Container 

Security Initiative supports the CBP priority mission, which is to prevent 

terrorists and terrorist weapons from entering the United States, while 

facilitating and maintaining legitimate trade. The Container Security 

Initiative has shifted the screening process of containerized maritime 

cargo to an earlier stage in the international maritime supply chain, from 

the domestic ports of entry to the foreign ports of lading. Under the 

initiative, CBP deploys a multidisciplinary team of DHS officers to work 

with the host nation to target containerized maritime cargo that may pose a 

risk of terrorism and to screen containers before they are loaded on vessels 

destined for the United States. DHS officials work with host country 

counterparts to share information and establish security criteria for 

identifying high-risk containers. Foreign customs administrations use 

standard protocols and nonintrusive technologies to examine mutually 

designated high-risk maritime containers before they are shipped to U.S. 

ports. As of May 31, 2008, no implements of terrorism have been 

detected in maritime containerized cargo destined for the United States. 

As of May 31, 2008, CBP has met its goal to implement the initiative at 58 

total ports worldwide to prescreen 85 % of maritime containerized cargo 

destined to the United States. Since CBP met this goal on September 28, 

2007, there are no plans to expand the initiative. CBP works closely with 

the World Customs Organization, the European Union, and the G-8 

countries to adopt standards similar to the Container Security Initiative 

and recommend these standards to their members. Currently, CBP is 

exploring remote targeting, coupled with the use of real-time remote 

imaging of container examinations incorporating a live video feed, to 

monitor the inspection process at the National Targeting Center-Cargo.

CBP is testing performance measures from the Container Security 

Initiative Strategic Plan for 2006–2011 at various ports. The measures 

may be revised based on the pilot evaluation. Targets will be established 

once the measures have been solidified. 

Originally, another goal of the initiative was to equip containers with 

security devices that would communicate evidence of seal tampering. The 

container security devices would register every opening, whether 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 13

legitimate or unauthorized. In a May 2007 letter to Congress, DHS stated 

that although the technology for the desired container security devices did 

not exist, DHS was working with industry to develop it. 

From 2003 through 2008, GAO conducted three audits of Container 

Security Initiative. These audits made nine recommendations, of which 

three were open as of May 31, 2008. The open issues relate to improving 

performance measures, strengthening CBP’s process for evaluating 

initiative teams at overseas ports, and improving information gathered 

about host governments’ examination systems. 

Automated Targeting System (ATS)

CBP has integrated ATS into its multilayered approach to security by 

using it as a tool for researching and targeting high-risk cargo for further 

review or examination. CBP uses ATS as a decision support tool for CBP 

officers working at U.S. ports of entry and at Container Security Initiative 

ports overseas. ATS performs an automated risk assessment of cargo 

information using weighted rules to determine the relative risks. Through 

these rules, ATS alerts the CBP officers to shipments that meet or exceed 

predefined criteria. In addition, ATS can detect significant anomalies by 

electronically matching manifest and entry data to Dun & Bradstreet 

records, law enforcement records, and enforcement data provided by other 

government agencies. 

CBP continuously works to improve the targeting system with new 

technologies, techniques, and data sources. This is necessary because of 

constantly shifting threats and the diversity of international trade. CBP 

has been exploring advanced analytical tools to assess the incorporation of 

additional smart features into ATS. For example, CBP has projects under 

development to implement predictive modeling, anomaly detection, and 

visualization tools that are customized to analyze cargo shipments in ATS. 

As of May 31, 2008, CBP has completed many ATS initiatives to target 

high-risk cargo. A key performance measure for ATS is screening 100 % 

of inbound cargo containers. Screening is defined as a visual or 

automated review of information about goods to determine the presence of 

improperly declared, restricted, or prohibited items and to assess the level 

of threat posed by such cargo. Other performance measures include 

number of shipments, shipments held, percent mitigated, and shipments 

designated intensive. 

From 2003 through 2008, GAO conducted two audits of ATS and DHS 

OIG conducted four. These audits made 25 recommendations, of which 3 

were open as of May 31, 2008. The open issues relate to improving 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 14

documentation of examinations, testing, and threat assessments. 

Currently, the OIG is conducting an audit of ATS. 

Automated Commercial Environment (ACE)

Congress funded ACE in response to the trade community’s concerns that 

federal requirements were outdated, burdensome, and duplicative. The 

ACE system will modernize the targeting, inspection, enforcement, 

revenue collection, and trade statistics processes for all cargo entering and 

leaving the United States. CBP is responsible for enforcing U.S. trade 

laws while simultaneously facilitating legitimate international trade. One 

of CBP’s critical functions is to control cargo and conveyances entering 

and leaving the United States to prevent smuggling of instruments of 

terrorism, narcotics, and illegal aliens, as well as to enforce trade laws and 

collect revenue. CBP’s ability to process the growing volume of imports, 

while improving compliance with trade laws and border security, depends 

heavily on improving the trade compliance process and modernizing 

supporting automated systems. 

CBP began developing ACE in August 2001 and plans to complete 

development by 2012. Once fully implemented, ACE will enable the 

trade community and CBP officers to submit and retrieve import 

transaction data electronically through an intuitive, standards-based,

secure Web portal. The ACE Program Plan has a series of target dates for 

all the processes leading to the completion of the system in 2012. The 

Critical Path Method allows CBP to track the dates and identify whether 

goals are late and what effect delays may have on the milestone dates. 

CBP internally tracks the 15 performance measures listed in the quarterly 

report to Congress to monitor ACE’s progress. 

ACE will support border security by enhancing analysis and information 

sharing with other government agencies. ACE will also provide CBP with 

the means to decide, before a shipment reaches the border, whether the 

shipment should be targeted as a security threat or should be expedited 

because it complies with U.S. laws. ACE will accomplish this by 

consolidating rail and sea shipment manifest and entry data to help 

identify risky shipments; providing a three-dimensional view of 

conveyance stowage plans to help identify unmanifested containers; 

allowing CBP officers to place or remove holds at the container level; 

providing CBP officers with integrated entry, manifest, and risk 

assessment information for informed cargo processing decisions; and 

streamlining the process for placing or removing holds by other 

government agencies. ACE will provide a “single window” for submitting 

trade information to federal agencies that share responsibility for 

facilitating international trade and securing the U.S. supply chain. 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 15

As of May 31, 2008, five high-level ACE processes designed to gather 

cargo information were operational. Performed in concert with ATS, 

these processes provide additional information on electronic truck 

manifests, cargo admissibility, assists in better targeting of cargo, 

controlling and improving cargo release, and provides conveyance 

crossing history. Of the 44 federal agencies that will participate in ACE, 

25 already have access to ACE, with a total of 375 users. 

From 2003 through 2008, GAO conducted four audits of ACE and DHS 

OIG conducted six. These audits made 34 recommendations, of which 13 

were open as of June 2008. The open issues relate to implementing an 

accountability framework, minimizing overlap across ACE releases, 

improving risk management, improving reporting, developing policies and 

procedures to improve management, and improving security. 

Secure Freight Initiative (SFI)

CBP is responsible for preventing weapons of mass destruction from 

entering the United States in cargo containers that are shipped from more 

than 700 foreign seaports. The SAFE Port Act calls for testing the 

feasibility of scanning 100 % of U.S.-bound cargo containers using 

nonintrusive imaging equipment and radiation detection equipment at 

foreign seaports. The 9/11 Act requires scanning 100 % of U.S.-bound 

cargo containers by 2012. SFI began as a pilot program at three foreign 

ports (Port of Southampton, U.K.; Port Qasim, Pakistan; and Puerto 

Cortez, Honduras) to test the feasibility of scanning 100 % of U.S.-bound 

containerized cargo.

CBP’s report and testimony to Congress in June 2008 concluded that the 

initial SFI deployments indicate that scanning U.S.-bound maritime 

containers is possible on a limited scale. However, SFI operations in these 

initial locations benefited from considerable host nation cooperation, low 

transshipment rates, and technology and infrastructure costs covered 

primarily by the U.S. government. The total U.S.-bound container volume 

at these three ports from October 12, 2007, to May 25, 2008, was 170,564 

containers. Every year, 11.5 million maritime containers enter the United 

States.

The deployment of container-scanning equipment at each of the SFI ports 

has presented certain operational, technical, logistical, financial, and 

diplomatic challenges that will likely continue to be encountered as SFI 

deploys to additional locations. One challenge has proven particularly 

difficult to overcome: operating these systems in a transshipment port. 

Transshipment is where containers arrive on one ship and depart on 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 16

another without entering or exiting through the port gates. The initial SFI 

pilots have demonstrated that technical and operational solutions are not 

yet available to capture transshipped cargo efficiently. Further, 

technological improvements to next-generation radiation detection and 

imaging equipment will be needed to implement the SFI program 

efficiently and effectively. 

As of May 31, 2008, CBP was expanding SFI to include three additional 

foreign ports (the Modern Terminal in Hong Kong; the Port of Salalah, 

Oman; and the Gamman Terminal in Busan, South Korea) on a limited 

basis to test other challenges to the 100 % scanning goal. CBP chose 

these ports because they present a unique set of challenges and provide 

diverse environments in which to evaluate different options. 

In June 2008, CBP reported to Congress on the legal, logistical, and 

technical challenges facing SFI. Also in June 2008, GAO testified on the 

challenges related to continuing SFI: workforce planning, host nation 

examination practice, performance measurement, resource responsibilities, 

logistics, technology and infrastructure, use and ownership of data, 

consistency with risk management, and reciprocity and trade concerns. In 

addition, GAO started a comprehensive audit of the SFI Pilot Program in 

July 2008. 

World Customs Organization SAFE Framework of Standards

The World Customs Organization, a global intergovernmental 

organization, represents 173 customs administrations responsible for 

processing more than 98 % of all international trade. In 2005, members 

developed a set of voluntary international customs standards, known as the 

World Customs Organization SAFE Framework of Standards, to enhance 

the security of the supply chain and facilitate international trade. In June 

2005, CBP was one of the first international customs organizations to 

submit a Letter of Intent to adopt the SAFE Framework. Full 

implementation of the SAFE Framework entails adoption by all members. 

The SAFE Framework aims to establish customs-to-customs network 

arrangements that will strengthen cooperation among customs 

administrations, enabling them to carry out controls earlier in the supply 

chain. For example, the administration of an importing country can 

request the administration of the exporting country to conduct an 

examination on its behalf. Capacity building and mutual recognition 

arrangement are two core components of World Customs Organization 

activity. The organization has to be flexible to help other countries to 

implement the SAFE framework requirements according to their level of 

development, while at the same time ensuring safe transportation of cargo 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 17

to the United States. The Capacity Building Operational Strategy program 

seeks to deliver the customs services required to support economic 

development in all members. The mutual recognition arrangement is a 

nonbinding document that allows members of one program to receive 

comparable benefits in the other program. Mutual recognition of customsto-business partnership arrangements will benefit both industry and 

government. 

As of May 31, 2008, 152 of 173 World Customs Organization members 

had signed the Letter of Intent to implement the SAFE Framework of 

Standards to Secure and Facilitate Global Trade. Also, more than 60 

administrations have entered the implementation phase. The United States 

has not fully implemented the SAFE Framework; CBP is on step five of 

the six-step process. In addition, the United States is supporting 10 

partner nations in implementing diagnostic tools for surveying port and 

trade security. 

International Ship and Port Facility Security Code 

The International Ship and Port Facility Security Code is an amendment to 

the United Nations International Maritime Organization’s International 

Convention for the Safety of Life at Sea. The code prescribes minimumsecurity requirements for governments, shipping companies, shipboard 

personnel, and port and facility personnel to detect security threats and 

take preventive measures against security incidents affecting ships or port 

facilities used in international trade. The DHS Secretary is required to 

assess the effectiveness of the antiterrorism measures maintained at 

foreign ports from which foreign vessels depart to the United States.

The Coast Guard, through the International Port Security Program, 

encourages multilateral discussions with nations to exchange information 

and best practices. This program aligns MTSA’s implementation and 

enforcement requirements with the International Ship and Port Facility 

Security Code and other international maritime security standards. This 

alignment directly supports the National Strategy for Maritime Security 

and the National Plan to Achieve Maritime Domain Awareness. The 

International Port Security Program further supports the Coast Guard’s 

effort to safeguard the international transportation system by working 

closely with international trading partners to promote reasonable and 

consistent implementation of the code. 

The International Port Security Program’s strategic goal is to reduce risk 

to the national maritime transportation system by working with foreign 

maritime trading partners to strengthen antiterrorism measures in overseas 

ports. The Coast Guard plans to set conditions for entry of vessels 

arriving from ports with inadequate antiterrorism measures, improve port 
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 18

security capacity, and improve maritime governance both domestically 

and abroad. The Coast Guard also plans to visit all trading partner nations 

at least once a year, with a more formal visit at least every other year.

Country visits will be scheduled based on a variety of factors, including 

the prioritized country list, Headquarters’ programmatic and policy 

concerns, the Area Commander’s priorities and concerns, results of prior 

visits, political considerations, and a country’s receptivity to receiving a 

visit. When the Coast Guard finds that a country’s antiterrorism measures 

are inadequate, the Coast Guard imposes conditions of entry on vessels 

from that country’s ports to mitigate the risk to the United States. To date, 

the Coast Guard has imposed conditions of entry on nine countries. 

As of May 31, 2008, International Port Security Program managers stated 

that the budget was adequate based on the current resources and personnel 

available to conduct visits. The program has 63 positions assigned. In 

accordance with the Department of Homeland Security Appropriations 

Act, 2007, program management expects to continue to conduct foreign 

port visits on a 2-year recurring cycle. The Coast Guard has completed 

the first round of visits in more than 140 countries and has commenced the 

second round of visits.

Maritime Domain Awareness 

Maritime Domain Awareness is the understanding of anything associated 

with the global maritime domain that could affect the security, safety, 

economy, or environment of the United States. It is a key component of 

an active, layered maritime defense that supports the President’s National 

Strategy for Maritime Security. No one country, department, or agency 

can achieve effective awareness; only through unity of effort can the 

security, safety, economic, and environmental objectives associated with 

Maritime Domain Awareness be achieved. 

Maritime Domain Awareness will help to safeguard U.S. systems of 

transportation when legacy information and intelligence systems are 

integrated with current and emerging intelligence capabilities. This 

integration will fuse information into a common operational picture 

available to maritime operational commanders and accessible throughout 

the global maritime community of interest. The Coast Guard was the 

primary DHS lead in creating and developing the National Strategy, the 

National Plan to Achieve Maritime Domain Awareness, and the National 

Concept of Operations (CONOPS) for Maritime Domain Awareness. This 

National Concept of Operations lists various short-term goals for 0 to 5 

years, midterm goals for 6 to 10 years, and long-term goals for 11 to 20 

years.
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

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Recognizing that numerous existing facilities already contribute to 

Maritime Domain Awareness, the National CONOPS established the 

Stakeholder Board to lead the overall national effort and designated 

Enterprise Hubs to coordinate information flow for the respective subject 

areas. Enterprise Hubs are existing organizations within DHS and the 

Department of Defense that already possess subject matter expertise, a 

preponderance of the requisite authorities, and knowledge of associated 

capabilities and procedures. Employing these coordinated information 

collection and sharing capabilities will maximize near-real time awareness 

of maritime threats. The CONOPS established an interagency leadership 

structure to coordinate and unify efforts. The governance structure 

consists of a Stakeholder Board co-chaired by the directors from the 

Global Maritime Intelligence Integration board and the Global Maritime 

Situational Awareness board.

Maritime Domain Awareness can be achieved by improving U.S. ability to 

collect, fuse, analyze, display, and disseminate actionable information and 

intelligence to operational commanders. This plan advocates enhanced 

and innovative collection of intelligence, the integration of correlated open 

source information, and the incorporation of automated algorithms to 

assist human analytic efforts. The primary method for information 

sharing, situational awareness, and collaborative planning will be a 

national maritime common operational picture. This picture will provide a 

uniform source and display of data that is transferred to a near-real time, 

virtual information grid to be shared by all federal, state, and local 

agencies with maritime interests and responsibilities—except when 

limited by security, policy, or regulations. Within the next few years, a 

user-defined operational picture will be implemented. 

Establishing the Stakeholder Board in December 2007 was the first step in 

meeting the numerous near- and long-term goals set by the National Plan 

to Achieve Maritime Domain Awareness and the National CONOPS. At 

one time, the Coast Guard Maritime Domain Awareness staff responsible 

for Coast Guard’s input into these documents included 30 personnel. 

However, its numbers have since been reduced to fewer than five full-time 

employees as duties have been picked up by the Stakeholder Board and 

other Coast Guard divisions. 

GAO is currently preparing an audit report for its audit of Coast Guard 

efforts to achieve Maritime Domain Awareness. 

Advanced Spectroscopic Portal Program

DNDO’s mission is to complete a global nuclear detection architecture 

that includes developing nuclear and radiation detection technologies.

One such technology is the Advanced Spectroscopic Portal, a next-
Appendix C 

Status of Programs and Systems from the DHS Plan 

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Page 20

generation passive detection radiation portal monitor using spectroscopic 

analysis to distinguish between special nuclear materials used to construct 

nuclear weapons (such as highly enriched uranium) and naturally 

occurring radioactive material (NORM). The joint DNDO-CBP program 

seeks to design, acquire, and test Advanced Spectroscopic Portals and to 

deploy them at CBP ports of entry as part of a multilayered system of 

radiation detection.

Ultimately, DNDO hopes that the Advanced Spectroscopic Portal program 

will improve radiological and nuclear detection and identification while 

minimizing impact on legitimate commerce. Currently, CBP’s standard 

scanning procedure begins with a primary screen in which CBP officers 

pass the cargo through polyvinyl toluene (PVT) radiation portal monitors. 

However, PVT cannot distinguish between different radiological isotopes.

Both special nuclear materials and NORMs such as granite, ceramics, and 

cat litter can trigger a radioactivity alert. If the alarm sounds, CBP 

officers conduct a secondary inspection. These secondary inspections take 

approximately 15 minutes to complete. The Port of Los Angeles had 500 

to 600 false alarms per day in which the secondary inspection determined 

that the radioactive material was a NORM. The Advanced Spectroscopic 

Portal’s potential to differentiate among radioactive isotopes would reduce 

time and resources lost to false alarms. 

On September 11, 2006, DNDO and CBP released the Radiation Portal 

Monitor Project Execution Plan (PEP). The PEP defines the overall 

project objectives, work scope, schedules, costs, and required funding for 

deploying radiation portal monitors, including Advanced Spectroscopic 

Portals, and calls for the construction of 1,034 portals. However, DNDO 

is updating the Joint DNDO/CBP Deployment Strategy to deploy 717 

Advanced Spectroscopic Portals by July 31, 2013. Once the new strategy 

is approved, a new version of the PEP will be published that coincides 

with the joint deployment strategy. 

As of May 31, 2008, the Advanced Spectroscopic Portal program had 41 

government and contract staff assigned, and the current program manager 

said that the program is appropriately staffed. The Advanced 

Spectroscopic Portal program has evolved through numerous performance 

specification versions as the developing technology has matured. The 

current version is in a performance testing phase, with planned completion 

in fall 2008.

Before deploying the Advanced Spectroscopic Portal system, the DHS 

Secretary must certify that the system is a significant improvement in 

operational effectiveness over existing equipment. DNDO expects the 

Secretary to certify the system by fall 2008, with operational deployment 
Appendix C 

Status of Programs and Systems from the DHS Plan 

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Page 21

following shortly thereafter. CBP plans to complete the operational 

deployment of the Radiation Portal Monitor system with both PVT and 

Advanced Spectroscopic Portal systems by the end of 2014. 

From 2006 through 2007, GAO issued three reports related to the 

Advanced Spectroscopic Portal. These audits made eight 

recommendations, of which five were open as of May 31, 2008. DNDO 

disagreed with two of the five open recommendations. The open issues 

relate primarily to conducting cost-benefit analyses and realistic testing of 

the portals. In September 2008, GAO issued a report which made three 

recommendations relating to cost issues. Currently, GAO has an audit of 

Advanced Spectroscopic Portal in progress relating to nuclear detection 

architecture, testing, and cost. GAO provided the preliminary results of 

this audit in Congressional testimony in September 2008. 

Cargo Advanced Automated Radiography System 

The Cargo Advanced Automated Radiography System is a nextgeneration nonintrusive inspection system that would detect both 

conventional contraband and high-Z materials within cargo. High-Z 

materials are elements with high atomic numbers, including both special 

nuclear materials and materials that can be used to shield them. Thus, the 

system would be able to distinguish between low-density nonthreat 

materials, such as aluminum and foodstuffs, and high-density materials. 

These characteristics would improve CBP’s ability to identify concealed 

and shielded special nuclear materials. Furthermore, this technology 

would automate the image processing required to detect high-density 

objects. This ability can be combined with the current ability to detect 

low-density contraband with little impact on CBP operators. With these 

advances, CBP and DNDO hope that the Cargo Advanced Automated 

Radiography System will enhance security while minimizing impact on 

legitimate commerce. 

In September 2006, DNDO awarded three concept-of-design contracts for 

a 2-year development period. In 2008, major changes to the Cargo 

Advanced Automated Radiography System strategy were implemented in

response to evolving DHS requirements, concurrent efforts in the 

commercial market, and difficulties in developing the technology. CBP 

and DNDO established the Joint Integrated Non-Intrusive Inspection 

program and working group to coordinate future development and testing 

of systems, including the Cargo Advanced Automated Radiography 

System. By June 2008, the working group had met four times, and the 

DNDO had five staff assigned to the project.
Appendix C 

Status of Programs and Systems from the DHS Plan 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 22

As of June 2008, the acquisition requirements were removed from the 

three system contracts. However, program management is still negotiating 

the contract modification for the remaining research and development. 

The three contracts for the system have either been completed or are 

approaching the critical design review phase.

The strategic benefits of the system course correction will be to establish a 

baseline detection capability for all hardware and software before entering 

any large-scale acquisition programs in the future. The FY 2008 planned 

accomplishments include initiating a test campaign to fully characterize 

the ability of commercially available nonintrusive inspection systems to 

manually detect shielded nuclear material. The FY 2009 goals include 

completion of developmental tests and evaluations of the system 

prototypes and a cost-benefit analysis of the entire program. 

DNDO and CBP seek to design, develop, and test the system and to 

deploy the technology at CBP ports of entry as part of a multilayered 

system of radiation detection. Eventually, the system will be used to scan 

containers for high-Z materials at all CBP ports of entry, but as of May 31, 

2008, the program remains in development and testing. 
Appendix D 

Chart – National Planning Structure as Related to the International Cargo Supply Chain 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 23

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Appendix E 

Major Contributors to This Report 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 24

Paul Wood, Director for Trade Operations 

Gene Wendt, Audit Manager 

Elizabeth Garcia, Auditor in Charge 

Victoria Phan, Program Analyst 

Victor Leung, Program Analyst 

Andrew Smith, Program Analyst 

Corneliu Buzesan, Program Analyst 
Appendix F 

Report Distribution 

DHS’ Plan for Implementing Secure Systems of Transportation 

Page 25

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

Commissioner, Customs and Border Protection 

OIG Liaison, Customs and Border Protection 

Commandant, Coast Guard 

OIG Liaison, Coast Guard

Director, Domestic Nuclear Detection Office

OIG Liaison, Domestic Nuclear Detection Office 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4199, 

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

OIG HOTLINE 

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

misconduct relative to department programs or operations: 

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

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• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

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