Department of Homeland Security

Office of Inspector General 

DHS' Strategy and Plans to Counter Small Vessel 


Threats Need Improvement 


OIG-09-100 September 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 September 10, 2009 

Preface 

The Department of Homeland Security Office of Inspector General was established by 

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

General Act of 1978. 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 assesses the efficacy of the Department of Homeland Security’s strategy to 

secure our ports, waterways, and maritime borders from small vessel threats. It is based 

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

observations, and a review of applicable documents. 

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

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

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

express our appreciation to all 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 ...................................................................................................................5


 Improvements Needed in DHS’ Small Vessel Security Strategy ...................................5 


 Programs and Processes Supporting the Strategy ..........................................................9 


DHS Components Not Fully Integrated........................................................................15 


Recommendations.........................................................................................................16


 Management Comments and OIG Analysis .................................................................16 


Appendixes

 Appendix A: Purpose, Scope, and Methodology..........................................................18 


 Appendix B: Management Comments to the Draft Report..........................................20 


 Appendix C: Desirable Characteristics and Elements of an Effective National 


Strategy ...................................................................................................23 


 Appendix D: Small Vessel Security Strategy and Draft Implementation Plan 


Compared Against Desirable Characteristics and Elements...................25 


 Appendix E: Programs Supporting the Small Vessel Security Strategy......................27 


 Appendix F: Major Contributors to This Report .........................................................30 


 Appendix G: Report Distribution .................................................................................31 


Abbreviations 

CBP Customs and Border Protection 


DHS Department of Homeland Security 


GAO Government Accountability Office 


OIG Office of Inspector General 

OIG
 

Department of Homeland Security 

Office of Inspector General

Executive Summary 

A small vessel, such as a commercial fishing vessel or recreational 

boat, can be used as a waterborne improvised explosive device, as 

a platform for conducting an attack, or to smuggle weapons or 

terrorists into the United States. Recognizing the threat, in mid2006, the Department of Homeland Security initiated a working 

group to develop a small vessel security national strategy. In April 

2008, the department published the Small Vessel Security Strategy 

to address these potential threats. The department is also 

developing an Implementation Plan, which is intended to provide 

direction to federal, state, and local agencies on achieving the 

major goals outlined in the Strategy. We reviewed the Small 

Vessel Security Strategy and the draft Implementation Plan to 

determine whether the department has developed a comprehensive 

approach for securing our ports, waterways, and maritime borders 

from small vessel threats. 

Overall, the department has made progress, but more remains to be 

done to provide effective guidance and operate effective programs 

to address small vessel threats. The Strategy addresses two 

desirable characteristics of an effective national strategy as it 

defines the problem, and uses risk assessments to analyze the 

threats. However, the Strategy only partially addresses the 

remaining four characteristics. It partially addresses elements such 

as strategic priorities and milestones, and roles and responsibilities 

of state and local sectors, but it does not address performance 

measures, associated costs or human capital, or accountability and 

oversight frameworks. 

Additionally, critical programs intended to support small vessel 

security may not be operating effectively. Although the 

department recognizes the need to raise public awareness and take 

action to mitigate the risk of small vessel threats, its approach was 

hindered because its components are not fully integrated. As a 

result, the nation’s ports, waterways, and maritime borders remain 

vulnerable to small vessel threats. The department partially 

concurred with our recommendation that it address the missing 

elements in its strategy. The department nonconcurred with our 

recommendation that it evaluate the effectiveness of the programs 

it intends to use to meet the strategy’s goals. 

 DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Background 

The Department of Homeland Security (DHS) recognizes the need 

to address the threats that small vessels pose to the United States. 

Small vessels are categorized as any watercraft of less than 300 

gross tons and used for recreational or commercial purposes, 

regardless of method of propulsion. Small vessels include 

commercial fishing vessels, recreational boats and yachts, towing 

vessels, uninspected passenger vessels, and any other personal or 

commercial vessels involved in U.S. or foreign voyages. With 

95,000 miles of shoreline, 300,000 square miles of waterways, 360 

ports of call, 12,000 marinas, and an estimated 17 million small 

vessels presently operating in U.S. waters, it is extremely difficult 

to distinguish friend from foe. 

DHS has identified four scenarios of gravest concern regarding the 

potential use of small vessels in terrorist-related activities: using a 

small vessel (1) as a waterborne improvised explosive device, (2) to 

smuggle weapons (including weapons of mass destruction) into the 

United States, (3) to smuggle terrorists into the United States, and 

(4) as a waterborne platform for conducting an attack. 

These four scenarios are based on terrorist acts that have involved 

small vessels. For example, in October 2000, Al-Qaeda attacked 

the USS Cole by navigating an explosive-laden small boat 

alongside the destroyer as it was refueling pier side at the port of 

Aden in Yemen. Seventeen U.S. Navy sailors were killed in the 

explosion. (See figure 1.) 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Figure 1. The USS Cole with a large hole in her left side after being struck by 

an Al-Qaeda waterborne improvised explosive device. Photo – Department of 

Defense. 

In October 2002, Al-Qaeda directed an attack by an explosiveladen small boat against the French oil tanker M/V Limburg off the 

coast of Yemen. The attack resulted in a large oil spill and fires on 

board the tanker, and killed one and injured four crew members. 

(See figure 2.) 

Figure 2. M/V Limburg on fire off the coast of Yemen after being struck by an 

Al-Qaeda waterborne improvised explosive device. Photo – DHS. 

In a recent surge of international piracy, terrorists have used small 

vessels to hijack cruise ships, tankers, and other vessels. In 2007, 

206 acts of piracy were committed, and 76 others attempted. In 

September 2008, Somali pirates used three small vessels to 

surround and seize the MV Faina, which was carrying 33 Russian 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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T-72 tanks and other weapons and ammunition. The captain of the 

vessel died during the assault, and the pirates demanded $35 

million for the release of the ship and the crew. (See figure 3.) 

Figure 3. Using small vessels, Somali pirates armed with rocket-propelled 

grenades and AK-47 assault rifles hijack the MV Faina in September 2008. 

Photo – U.S. Navy. 

In November 2008, terrorists hijacked a Pakistani fishing boat, 

killing the captain and crew. The terrorists then sailed the boat to 

Mumbai, India, where they went ashore in small inflatable boats and 

carried out an attack that killed more than 170 people and held 

India’s financial capital hostage for 3 days. (See figure 4.) 

Figure 4. Eleven terrorists went ashore in inflatable boats and attacked the Taj 

Mahal Hotel in Mumbai, India. Photo – Reuters. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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As these events demonstrate, the threat posed by terrorists 

operating small vessels is daunting. 

In June 2007, the DHS National Small Vessel Security Summit, 

held in Arlington, Virginia, brought together approximately 300 

small vessel maritime stakeholders and top federal, state, and local 

government officials to share concerns about small vessel 

operations, safety, and security. Using recommendations from the 

National Summit, risk management principles, and previous U.S. 

Coast Guard (Coast Guard) and U.S. Customs and Border 

Protection (CBP) analyses of small vessel threats, a DHS working 

group developed the Small Vessel Security Strategy, which DHS 

published in April 2008, to address the risks of small vessels to 

national security. 

The overall objective of the Small Vessel Security Strategy is to 

close security gaps and enhance the small vessel security 

environment. The Strategy lists four major goals for achieving 

small vessel security: 

1.	 Develop and leverage a strong partnership with the small 

vessel community and public and private sectors in order to 

enhance maritime domain awareness. 

2.	 Enhance maritime security and safety based on a coherent 

plan with a layered, innovative approach. 

3.	 Leverage technology to enhance the ability to detect, 

determine the intent of, and when necessary, interdict small 

vessels. 

4.	 Enhance coordination, cooperation, and communications 

between federal, state, local, and tribal partners and the 

private sector, as well as international partners. 

Results of Audit 

Improvements Needed in DHS’ Small Vessel Security Strategy 

DHS has not provided a comprehensive strategy for addressing small 

vessel threats. Neither its Small Vessel Security Strategy nor its draft 

Implementation Plan effectively addresses all the desirable characteristics 

and elements of a national strategy. In addition, the department has not 

evaluated the effectiveness of critical programs that are expected to serve 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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as a foundation for small vessel security and may not be providing 

anticipated results. 

Desirable Characteristics of an Effective National Strategy 

In 2004, the Government Accountability Office (GAO) published 

guidance identifying six desirable characteristics of an effective 

national strategy for combating terrorism.1

 With each characteristic, 

GAO provided examples of elements that national strategies might 

include to ensure that agencies properly address them. Table 1 

summarizes these desirable characteristics and their elements. 

Table 1. Desirable Characteristics and Their Elements 

Desirable Characteristic Brief Description of Elements 

1. Purpose, scope, and 

methodology 

Why the strategy was produced, the scope of its 

coverage, and the process by which it was developed. 

2. Problem definition and 

risk assessment 

The particular national problems and threats that the 

strategy is designed to mitigate. 

3. Goals, subordinate 

objectives, activities, and 

performance measures 

The goals that a strategy is trying to achieve and steps 

to accomplish those goals, as well as the priorities, 

milestones, and performance measures to gauge results. 

4. Resources, investments, 

and risk management 

The cost, sources, and types of resources and 

investments needed to carry out a strategy, as well as 

where resources and investments should be targeted by 

balancing risk reductions and costs. 

5. Organizational roles, 

responsibilities, and 

coordination 

Who will be implementing the strategy, what their 

respective roles will be, and how they will coordinate 

their efforts. 

6. Integration and 

implementation 

How the strategy relates to other strategies’ goals, 

objectives, and activities, as well as to subordinate 

levels of government and their plans for implementing 

the strategy. 

1 Combating Terrorism: Evaluation of Selected Characteristics in National Strategies Related to 

Terrorism (GAO-04-408T, February, 2004). 

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These characteristics are intended to help shape the policies, 

programs, priorities, resource allocations, and standards that 

federal agencies and other stakeholders use to implement their 

national strategies. The guidance is also designed to assist 

agencies in evaluating progress, ensuring accountability, and 

achieving anticipated results from strategy implementation. GAO 

emphasized that it would be useful for agencies to address in their 

strategies all of the characteristics, which logically flow from 

conception to implementation. Appendix C provides additional 

details on each characteristic. 

DHS’ Strategy Does Not Address All Desirable Characteristics 

DHS’ Small Vessel Security Strategy does not effectively address 

all the desirable characteristics in GAO’s guidance for providing 

an effective national strategy, even when supported by the draft 

Implementation Plan. (See Appendix D.) Of the six desirable 

characteristics, the Strategy and Implementation Plan together 

address the first two and partially address the remaining four. 

Characteristics Addressed 

The first two desirable characteristics, which the Strategy 

addresses, provide the foundation for developing specific actions 

to address the problems and risks posed by small vessels. 

Specifically, the DHS Small Vessel Security Strategy addresses the 

following: 

Purpose, scope, and methodology The intent of the Small Vessel 

Security Strategy is to reduce potential security and safety risks 

from small vessels by adopting and implementing a coherent 

system of regimes, awareness, and security operations that strike 

the proper balance between fundamental freedoms, adequate 

security, and continued economic stability. The Strategy describes 

the scope of coverage, identifying the stakeholders involved and 

the Strategy’s relationships to other strategies and plans. The 

Strategy also addresses the DHS working group’s methodology for 

developing the Strategy. 

Problem definition and risk assessment The Small Vessel 

Security Strategy addresses the complexities in managing the risks 

posed by small vessels. The Strategy notes that small vessels are 

not centrally registered, are not always proficiently operated, and 

the ability to screen or detect vessel-borne hazards is extremely 

limited. Furthermore, small vessel operators have a tradition and 

expectation of largely unrestricted access to U.S. waterways. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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These complexities present unique challenges in assessing the risks 

posed by small vessels. 

The Strategy identifies four scenarios of gravest concern regarding 

the potential use of small vessels as: 

•	 A waterborne improvised explosive device; 

•	 A conveyance for smuggling weapons, including weapons 

of mass destruction, into the United States; 

•	 A conveyance for smuggling terrorists into the United 

States; or 

•	 A waterborne platform for conducting attacks. 

By defining the problem and assessing the risk, responsible parties 

could tailor approaches to address the needs of specific regions or 

sectors. 

Characteristics Partially Addressed 

The Small Vessel Security Strategy and draft Implementation Plan 

partially address the remaining four desirable characteristics of an 

effective strategy. 

Goals, objectives, activities, and performance measures The 

draft Implementation Plan provides short-term and long-term 

actions for fulfilling the goals outlined in the Small Vessel Security 

Strategy; however, it does not address priorities, milestones, 

performance measures, or progress indicators. Without these 

elements, it is difficult to effectively monitor progress, establish 

accountability, and ensure program success. 

Resources, investments, and risk management The Small Vessel 

Security Strategy only partially addresses this characteristic, as it 

does not sufficiently address detailed information regarding strategic 

costs, human capital, resources, or economic principles. 

Furthermore, the draft Implementation Plan simply categorizes 

funding levels as high, medium, or low without providing any dollar 

amounts, stating only whether an action is or is not currently funded. 

A strategy should address the sources and types of resources and 

investments needed, consider the actual costs associated with 

implementing the strategy, and define where resources and 

investments should be targeted. Without addressing these elements, 

DHS cannot coordinate implementation efforts effectively and 

efficiently across its numerous components. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Organizational roles, responsibilities, and coordination The 

Small Vessel Security Strategy addresses the roles and 

responsibilities of specific federal agencies in some detail, but it 

only partially addresses the roles and responsibilities of state, local, 

private, and international sector partners. Furthermore, the 

Strategy partially addresses the lead, support, and partner roles and 

responsibilities, but does not address any accountability and 

oversight framework, or how conflicts will be resolved. The draft 

Implementation Plan identifies lead federal agencies for each 

proposed action; however, it does not address how the 

implementing agencies will coordinate their efforts. As directed 

by Section 801(b) of the Homeland Security Act of 2002 (Public 

Law 107-296), DHS is required to develop a process for receiving 

meaningful input from states and localities to assist in the 

development of a national strategy “for combating terrorism and 

other homeland security activities.” The Small Vessel Security 

Strategy provides a generic list of functional responsibilities, but it 

does not provide the mechanisms needed to coordinate and 

collaborate on these responsibilities. 

Integration and implementation The Strategy addresses how it 

integrates with other national strategies, but it only partially 

addresses details on specific federal, state, local, or private 

strategies and plans. It does not address and provide 

implementation guidance for state, local, or private strategies and 

plans. By not providing integration guidance, DHS risks 

ineffective and inefficient Strategy implementation. 

Programs and Processes Supporting the Strategy 

The Small Vessel Security Strategy and draft Implementation Plan 

identify existing programs and processes that DHS plans to use to combat 

the risks posed by small vessels. They include America’s Waterway 

Watch, Pleasure Boat Reporting System, and various information-sharing 

processes that the department did not evaluate before including them in 

the solution to the small vessel security threat. These programs and 

processes need improvement to ensure that they are operating effectively 

and providing anticipated results. 

America’s Waterway Watch 

The Small Vessel Security Strategy and draft Implementation Plan 

identify America’s Waterway Watch as a key program to support 

the goal of developing and leveraging strong partnerships with the 

small vessel community to enhance maritime domain awareness. 

The program is intended to serve as a tool for the maritime 

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industries, recreational boating communities, and the public to 

report suspicious and unusual maritime activity via a 24-hour 

hotline. (Appendix E provides a more detailed description of these 

programs and processes.) However, the effectiveness of America’s 

Waterway Watch is limited because it is not widely known to the 

maritime and boating communities, calls are not tracked, and it 

does not fully leverage public participation. 

•	 America’s Waterway Watch is not widely known. Of the 

estimated 13 million registered boaters within the United 

States, only 440,000 received informational brochures sent 

inside national vessel documentation packets. An 

additional 1 million boaters received information on 

America’s Waterway Watch when they renewed their 

vessel’s state registration.2 Therefore, the Coast Guard 

may not have reached out to more than 90% of the 

estimated registered boaters. According to representatives 

from recreational vessel interest groups and national 

associations, the program is not widely known because the 

Coast Guard has not conducted sufficient public outreach. 

In 2007, the America’s Waterway Watch hotline received 

197 calls from the public. This limited public awareness 

inhibits the usefulness of the program. 

•	 America’s Waterway Watch calls are not tracked. Calls to 

the America’s Waterway Watch hotline are routed through 

the National Response Center, where they are screened and 

forwarded to the appropriate authorities in the area where 

the suspicious activity was reported. The National 

Response Center is staffed by Coast Guard personnel who 

monitor the hotline 24 hours a day, 365 days a year. 

However, the National Response Center does not have the 

capability to record the phone numbers that call in, the 

frequency of calls, or the results of the information 

provided. As a result, the Coast Guard is unable to 

determine the overall effectiveness of the America’s 

Waterway Watch program. A method to track the calls and 

their outcome is essential to monitor and evaluate the 

program’s efficiency and effectiveness. 

•	 Citizen’s Action Network. In addition to the America’s 

Waterway Watch, the draft Implementation Plan identifies 

the Citizen’s Action Network as a program that could 

2 America’s Waterway Watch–U.S. Coast Guard’s Maritime Homeland Security Outreach Program (U.S. 

Coast Guard presentation, October 2008). 

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support the Strategy’s goal of developing and leveraging a 

strong partnership with the small vessel community. The 

Citizen’s Action Network seeks to leverage the general 

public’s active participation. It differs from America’s 

Waterway Watch in that it acquires information from 

vetted, trained members in addition to the general public. 

The Citizen’s Action Network can track both the outcomes 

of the information provided and the degree of member 

participation, and therefore can evaluate the overall 

effectiveness of the program. The draft Implementation 

Plan states that the Coast Guard has plans for a pilot 

program to expand and combine public outreach programs, 

but the pace of development is slow due to resource 

constraints. Coast Guard officials in the field, however, 

conducted a cost-benefit analysis to support the conclusion 

that the Citizen’s Action Network program could be 

implemented nationwide with few to no additional 

resources. 

Because of minimal public awareness, inability to track calls, and 

limited participation, the America’s Waterway Watch program is 

unable to effectively support the Small Vessel Security Strategy’s 

goals. DHS should evaluate the Citizen’s Action Network 

program and its usefulness as a possible best practice to better 

leverage the public’s participation and maritime domain 

awareness. 

Pleasure Boat Reporting System 

The Small Vessel Security Strategy states that DHS should use 

data gathered from the Pleasure Boat Reporting System program to 

improve data analysis capabilities to target high-risk small vessels. 

CBP administers the Pleasure Boat Reporting System program, 

which requires small vessel boaters traveling from a foreign 

country to self-report their arrival to the United States 

immediately. However, both the Strategy and CBP officers state 

that the Pleasure Boat Reporting System is ineffective and the data 

it gathers are not accurate. Specifically, the Strategy states, 

During Fiscal Year 2006, only 70,000 boater foreign 

arrivals were recorded in the U.S. Customs and Border 

Protection (CBP) Pleasure Boat Reporting System (PBRS), 

based on boater self-reporting. Conservative estimates 

suggest that these reporting figures represent only a 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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fraction of the actual international boater traffic, especially 

given the ease with which boaters operate in these waters. 

In January 2009, CBP provided OIG with total small vessel arrival 

data for the past 3 fiscal years pulled directly from the Pleasure 

Boat Reporting System (see table 2). 

Table 2. PBRS Small Vessel Arrivals 

Fiscal Years Small Vessel Arrivals 

2006 50,3043 

2007 56,277 

2008 52,595 

Previously, CBP analyzed the Pleasure Boat Reporting System 

program and determined that only 10% to 25% of boaters actually 

self-report their arrivals when returning from foreign ports. Based 

on a conservative estimate of 25% and the total number of arrivals 

recorded in 2008, approximately 160,000 vessels did not selfreport in 2008. This results in a large amount of unrecorded data; 

more important, these undocumented arrivals could lead to a 

potentially large number of dangerous people and things illicitly 

entering the country using small vessels. 

Boaters may not be self-reporting because: (1) they are unaware of 

reporting requirements, (2) they experience extended waits and 

processing times, and (3) they experience inconsistent 

consequences regarding the failure to report. 

According to CBP Office of Field Operations officials, current 

outreach efforts do not reach millions of small vessel boaters, and 

many boaters may not be aware of the self-reporting requirements. 

In one city, outreach efforts include CBP officers visiting local 

yacht clubs and marinas and attending local boat shows to promote 

the Pleasure Boat Reporting System program, as well as updating 

signs posted at 600 marinas. Despite these efforts to increase 

public outreach, the number of reported arrivals remains low. 

3

 CBP Office of Field Operations, Planning, Program Analysis and Evaluation Measurements Branch 

provided small vessel arrival data as of January 15, 2009. For FY 2006, the Small Vessel Security Strategy 

states that 70,000 arrivals were recorded. CBP officials were unable to explain the difference between the 

Pleasure Boat Reporting System data provided to OIG and the data presented in the Strategy. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Boaters who know the reporting requirements may be deterred 

from self-reporting because CBP cannot always quickly and 

effectively process arrivals, thereby causing long delays. For 

example, at one of the ports visited, the Pleasure Boat Reporting 

System office has limited staff. CBP states that because of the 

limited number of CBP officers manning the phone lines in this 

office, boaters may experience extended waiting and processing 

times. These delays deter numerous boaters from calling in to 

report their arrival, and many who do call hang up without 

completing the reporting process. 

Last, CBP’s policies regarding its response to the failure to report 

foreign boat arrivals may need strengthening. Under the Tariff Act 

of 1930, any operator of a small vessel operator who fails to report 

immediately the vessel's arrival is liable for a civil penalty of 

$5,000 for the first violation and $10,000 for each subsequent 

violation, and the small vessel used in connection with the 

violation(s) may be seized.4 Further, under 19 U.S.C. 1436(c), the 

vessel operator may be subject to criminal penalties if the failure to 

report the vessel's arrival was intentional. However, CBP’s 

policies allow officers the discretion to issue first time violators a 

warning letter. CBP officers said that in FY 2008, one port issued 

137 warning letters to first-time violators. Without the consistent 

application of more serious consequences, small vessel boaters 

may not feel compelled to self-report, and the Pleasure Boat 

Reporting System will continue to have inaccurate data to target 

high-risk small vessels. 

To improve small vessel operations data, the draft Implementation 

Plan lists numerous short- and long-term actions for improving the 

methods of data gathering. One action includes requiring small 

vessel operators traveling to the United States from a foreign 

seaport to provide notice of arrival 1 hour prior to departure from 

an overseas port. Although this may help alert CBP officers of 

incoming vessels, without addressing the issues of public 

awareness, processing delays, and inconsistent enforcement of 

serious consequences, these actions may be ineffective in meeting 

the Small Vessel Security Strategy’s goals. 

As a result, the Pleasure Boat Reporting System program is not 

providing complete data for targeting high-risk small vessels, and 

may be ineffective for countering small vessel threats as required 

4 19 U.S.C. 1436(b), Tariff Act of 1930 – Penalties for violations of arrival, reporting, entry, and clearance 

requirements. 

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in the Small Vessel Security Strategy and draft Implementation 

Plan. 

Information-Sharing Processes 

The Small Vessel Security Strategy states that because of the large 

number of small vessels operating in the maritime domain, it is 

“virtually impossible for any single government entity at any level 

to have sufficient information, resources, expertise, or statutory 

authority to address the spectrum of potential risks related to small 

vessels.”5

 The Strategy calls for leveraging the department’s 

current capabilities for coordinating, cooperating, and 

communicating information on small vessel threats among all 

stakeholders in an effective and timely manner. However, some of 

the DHS systems used to share information may not be accessible 

to all DHS components, thus limiting their ability to effectively 

share information. 

CBP administers TECS6

, one of the largest law enforcement 

databases operated by DHS. It provides storage and access to 

personally identifiable information that is collected through other 

government databases. 

Although TECS is available to many federal, state, and local 

agencies, it is not readily available to the Coast Guard, the largest 

maritime law enforcement entity. Currently, the Coast Guard has 

limited access to the information housed in the database, and it 

does not regularly add new information obtained through its vessel 

interdictions. Instead, the Coast Guard uses another database, the 

Maritime Information for Safety and Law Enforcement system, to 

store the information it obtains during small vessel interdictions. 

Although the Coast Guard shares its data through the Maritime 

Information for Safety and Law Enforcement among its own 

offices, CBP and other law enforcement agencies do not have 

expeditious access to the Coast Guard system. The disconnect 

between the Maritime Information for Safety and Law 

Enforcement and TECS, and the department’s methods for 

inputting, storing, and retrieving information, may restrict the 

ability of CBP, the Coast Guard, and other law enforcement 

agencies to counter small vessel threats. Without addressing these 

limitations, the department is not leveraging its capabilities for 

5 Small Vessel Security Strategy (DHS, April 2008). 6

 TECS is not an acronym. 

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coordinating, cooperating, and communicating information 

effectively. 

DHS Components Not Fully Integrated 

Although DHS recognized the need to increase public awareness and take 

action to mitigate the risks posed by small vessels, DHS’ approach was 

hindered because its components are not fully integrated. In addition, the 

working group tasked with developing the strategy decided not to follow 

all the guidance available in GAO’s desirable characteristic report. 

In mid-2006, the DHS Office of Policy set up a working group to develop 

a small vessel security national strategy. The working group determined 

that better public outreach was necessary to educate the public and garner 

its support in combating the small vessel threat. Therefore, they began 

their efforts to engage stakeholders, and in June 2007, DHS sponsored the 

first National Small Vessel Security Summit. The summit brought 

together approximately 300 stakeholders and federal observers to discuss a 

range of issues involving the security risks posed by small vessels in the 

U.S. maritime domain. After the summit, the working group continued to 

develop the Strategy, which was published in April 2008. 

The working group’s members cut across multiple DHS components and 

organizations but did not feel empowered to make departmental decisions 

while developing the Strategy. For example, the working group decided 

that the Strategy and Draft Implementation Plan would not set specific 

performance measures on the components, nor would they specifically 

define costs or human capital requirements associated with the Strategy. 

Working group members also stated that they considered the GAO 

desirable characteristics and elements standards but determined that not all 

the elements applied to the Small Vessel Security Strategy. In some 

instances the working group determined that it was not the appropriate 

forum to discuss or address recommended elements. 

Although it is difficult to ensure that all national strategies are able to 

provide details on each and every characteristic, the guidance should be 

considered a best practice. National strategies that contain all of these 

characteristics increase their usefulness as guidance for policy and 

decision-makers in allocating resources and balancing homeland security 

priorities. 

Finally, the working group relied on each component to vet the programs 

and processes presented to the working group in support of the Strategy. 

However, the working group did not verify the information to ensure that 

the programs and processes were operating effectively before including 

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them as part of an overall solution because they determined that each 

component was solely responsible for the information they provided. 

Until a comprehensive approach is fully evaluated, developed, and 

implemented, the United States will remain vulnerable to the threats posed 

by small vessels. Without fully evaluating and mitigating these 

weaknesses in the programs and processes supporting the Strategy, DHS 

may not achieve its goal of protecting our nation against dangerous people 

and addressing critical opportunities to identify and prevent terrorist acts. 

Recommendations 

We recommend that DHS develop a more comprehensive small 

vessel security strategy by: 

Recommendation #1: Addressing the desirable characteristics 

and elements missing from its Strategy and draft Implementation 

Plan. 

Recommendation #2: Evaluating the effectiveness of programs 

intended to support small vessel security before including them as 

part of a solution to improve security against the small vessel 

threats. 

Management Comments and OIG Analysis 

We obtained written comments on our draft from the Assistant 

Secretary, Office of Policy, the U.S. Coast Guard Commandant, 

and the Acting Commissioner, U.S. Customs and Border 

Protection on behalf of DHS. The department submitted technical 

comments and corrections, and raised the issue that some 

information within the report may require restricted public access. 

We reviewed the report and made changes to ensure the accuracy 

of the information. We also reviewed the report and coordinated 

with the department to resolve sensitivity comments and to ensure 

the report was publicly releasable in its entirety. There is no need 

for the report to be restricted to For Official Use Only (FOUO). 

We have included a copy of the comments in their entirety at 

Appendix B. In the comments, DHS partially concurred with 

recommendation 1 and did not concur with recommendation 2. 

The following is an evaluation of DHS’ comments. 

Management Comments to Recommendation #1: DHS partially 

concurs with the OIG’s recommendation to address the desirable 

characteristics and elements missing from its Strategy and 

Implementation Plan. DHS acknowledges that some of the six 

desirable characteristics of an effective national strategy could be 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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addressed more fully in the Strategy. DHS acknowledges that 

performance metrics for federal, state, local, tribal, and private 

sector initiatives as well as associated costs were not addressed in 

great detail in the Strategy. DHS plans to work to more fully 

address these elements in the execution of the Implementation 

Plan. DHS noted that many of the desirable characteristics were 

indeed addressed in the Strategy. 

OIG Analysis: We consider DHS’ proposed actions partially 

responsive to the recommendation. We acknowledged in our 

report that the Strategy addresses the first two desirable 

characteristics as it defines the problem, and uses risk assessments 

to analyze the threats. However, as illustrated at Appendix D, the 

Strategy only partially addresses the remaining four characteristics 

because it explicitly cites some, but not all, of the elements of the 

remaining four characteristics. The designation “partially 

addresses” can be used for a strategy that addresses few of the 

elements of a characteristic and a strategy that addresses most of 

the elements of a characteristic, but not all. To have a more robust 

and effective strategy, DHS should work to more fully address 

these elements, as appropriate. This recommendation will remain 

unresolved and open until DHS provides evidence that it 

considered the missing elements and addressed them, as 

appropriate, in the Strategy. 

Management Comments to Recommendation #2: DHS does not 

concur with the recommendation to evaluate the effectiveness of 

programs intended to support small vessel security before 

including them as part of a solution to improve security against the 

small vessel threats. DHS stated that the agencies that submitted 

specific actions for the implementation plan considered their 

effectiveness to support small vessel security in view of the 

Strategy. 

OIG Analysis: We consider this recommendation open and 

unresolved. The interagency working group was unable to provide 

evidence that the programs or actions submitted by the agencies 

had been evaluated. Further, during the course of the review, we 

identified weaknesses in these programs that could hinder their 

effectiveness in combating the small vessel threat. We ask that 

DHS reconsider its response to our recommendation and advise us 

of plans and strategies for its implementation. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Appendix A 

Purpose, Scope, and Methodology 

Our objective was to determine the effectiveness of DHS’ 

approach for improving national maritime security against small 

vessel threats. To achieve our audit objective, we reviewed the 

DHS Small Vessel Security Strategy, draft Implementation Plan, 

and selected programs used to support the Small Vessel Security 

Strategy. 

We observed operations carried out in support of small vessel 

security in various ports, and we interviewed personnel at the U.S. 

Coast Guard Intelligence Coordination Center in Suitland, MD. 

We interviewed U.S. Coast Guard personnel in the Offices of 

Vessel Activities, Boating Safety Division, and America’s 

Waterway Watch Program. We also interviewed U.S. Customs 

and Border Protection personnel in the offices of Pleasure Boat 

Reporting System Program, Intelligence and Operations 

Coordination, and Air & Marine Operations. We met with state 

and local law enforcement officials to discuss communication, 

coordination, and cooperation efforts regarding small vessel 

security. 

We reviewed prior DHS OIG, GAO, and Homeland Security 

Institute reports discussing maritime security and national 

strategies related to terrorism. 

We reviewed the Small Vessel Security Strategy and draft 

Implementation Plan and compared them to the desirable 

characteristics and supporting elements of an effective national 

strategy as set forth in GAO’s report, Combating Terrorism: 

Evaluation of Selected Characteristics in National Strategies 

Related to Terrorism.7 (See Appendix D.) 

To ensure consistency, we used GAO’s definitions to determine 

the extent to which the Small Vessel Security Strategy satisfied 

each of the six desirable characteristics. 

We conducted our audit at DHS, Coast Guard, and CBP 

headquarters in Washington, DC. We also performed fieldwork at 

two ports. We conducted this performance audit between August 

2008 and January 2009 in accordance with generally accepted 

government auditing standards. Those standards require that we 

plan and perform the audit to obtain sufficient, appropriate 

7 Combating Terrorism: Evaluation of Selected Characteristics in National Strategies Related to 

Terrorism (GAO-04-408T), February 2004. 

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Appendix A 

Purpose, Scope, and Methodology 

evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the 

evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

We would like to thank the Coast Guard, CBP, and DHS Office of 

Policy for the cooperation and courtesy they extended to our staff 

during this audit. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Appendix B 

Management Comments to the Draft Report 

Page 20
 
 

Appendix B 

Management Comments to the Draft Report 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement
 

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Appendix B 

Management Comments to the Draft Report 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement
 

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Appendix C 

Desirable Characteristics and Elements of an Effective National Strategy 

Based on heightened concerns about terrorism and homeland 

security, GAO published a set of standards containing six desirable 

characteristics for an effective national strategy.8 These desirable 

characteristics are intended to help shape the policies, programs, 

priorities, resource allocations, and standards that would enable 

federal agencies and other stakeholders to implement the strategies 

and achieve the identified results. The six desirable characteristics 

contain 40 specific supporting elements that, when properly 

addressed in a national strategy, provide guidance for developing 

and implementing the strategy, improve management’s abilities to 

set policy and direct resources, and ensure accountability of all 

stakeholders at all levels of government. 

The six desired characteristics are as follows: 

(1) Purpose, scope, and methodology 

(2) Problem definition and risk assessment 

(3) Goals, subordinate objectives, activities, and performance 

measures 

(4) Resources, investments, and risk management 

(5) Organizational roles, responsibilities, and coordination 

(6) Integration and implementation 

We compared the Small Vessel Security Strategy against each 

desirable characteristic and its supporting elements. (See 

Appendix D). 

The Strategy could obtain one of three potential scores of 

“addresses,” “partially addresses,” or “does not address” for each 

desirable characteristic. 

•	 The Strategy “addresses” a characteristic when it explicitly 

cites all the elements of a characteristic, even if it lacks 

specificity and details and thus could be improved. 

•	 The Strategy “partially addresses” a characteristic when it 

explicitly cites some, but not all, of the elements of a 

characteristic. The designation “partially addresses” can entail 

a wide variation between a strategy that addresses most of the 

elements of a characteristic and a strategy that addresses few of 

the elements of a characteristic. 

•	 The Strategy “does not address” a characteristic when it does 

not explicitly cite or discuss any elements of a characteristic, 

and/or any implicit references to the characteristics or elements 

are either too vague or too general. 

8

 GAO-04-408T, February 2004. 

DHS’ Strategy and Plans to Counter Small Vessel Threats Need Improvement 

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Appendix C 

Desirable Characteristics and Elements of an Effective National Strategy 

Desirable 

Characteristic Brief Description Example of Elements 

Purpose, scope, and 	 Addresses why the 

methodology	 strategy was produced, 

the scope of its coverage, 

and the process by which 

it was developed. 

•	 Statement of broad or narrow purpose, as appropriate 

•	 How it compares and contrasts with other national strategies 

•	 Major functions, mission area, or activities it covers 

•	 Principles or theories that guided its development 

•	 Impetus for strategy (e.g., statutory requirement or event) 

•	 Process to produce strategy (e.g., interagency task force; state, local, or 

private input) 

•	 Definition of key terms 

Problem definition 	 Addresses the particular • Discussion or definition of problems, their causes, and operating 

and risk assessment 	 national problems and environments 

threats toward which the • Risk assessment, including an analysis of threats and vulnerabilities 

strategy is directed. • Quality of data available (e.g., constraints, deficiencies, and 

“unknowns”) 

Goals, subordinate 

objectives, 

activities, and 

performance 

measures 

Resources, 

investments, and 

risk management 

Organizational 

roles, 

responsibilities, and 

coordination 

Addresses what the 

strategy is trying to 

achieve and steps to 

achieve those results, as 

well as the priorities, 

milestones, and 

performance measures to 

gauge results. 

Addresses what the 

strategy will cost, the 

sources and types of 

resources and 

investments needed, and 

where resources and 

investments should be 

targeted by balancing 

risk reductions and costs. 

Addresses who will be 

implementing the 

strategy, what their roles 

will be compared to 

others, and mechanisms 

for them to coordinate 

their efforts. 

•	 Overall results desired (i.e., “end state”) 

•	 Hierarchy of strategic goals and subordinate objectives 

•	 Specific activities to achieve results 

•	 Priorities, milestones, and outcome related performance measures 

•	 Specific performance measures 

•	 Process for monitoring and reporting on progress 

•	 Limitations on progress indicators 

•	 Resources and investments associated with the strategy 

•	 Types of resources required (e.g., budgetary, human capital, 

information technology, research and development, contracts) 

•	 Sources of resources (e.g., federal, state, local, and private) 

•	 Economic principles (e.g., balancing benefits and costs) 

•	 Resource allocation mechanisms (e.g., grants, in kind services, loans, 

or user fees) 

•	 “Tools of government” (e.g., mandates or incentives to spur action) 

•	 Importance of fiscal discipline 

•	 Linkage to other resource documents (e.g., federal budget) 

•	 Risk management principles 

•	 Roles and responsibilities of specific federal agencies, departments, or 

offices 

•	 Roles and responsibilities of state, local, private, and international 

sectors 

•	 Lead, support, and partner roles and responsibilities 

•	 Accountability and oversight framework 

•	 Potential changes to current organizational structure 

•	 Specific processes for coordination and collaboration 

•	 How conflicts will be resolved 

Integration and 	 Addresses how a national • Integration with other national strategies (horizontal) 

implementation	 strategy relates to other • Integration with relevant documents from implementing organizations 

strategies’ goals, (vertical) 

objectives, and activities, • Details on specific federal, state, local, or private strategies and plans 

and to subordinate levels • Implementation guidance of government and their •	 Details on subordinate strategies and plans for implementation plans to implement the (e.g., human capital and enterprise architecture) strategy. 

Source: GAO-04-408T, February 2004. 

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Appendix D 

Small Vessel Security Strategy and Draft Implementation Plan Compared Against 

Desirable Characteristics and Elements 

Desirable Characteristics and Elements Not 

Addressed 

Partially 

Addressed Addressed 

Purpose, scope, and methodology–Addressed 

Statement of broad or narrow purpose, as appropriate X 

How it compares and contrasts with other national strategies X 

Major functions, mission areas, or activities it covers X 

Principles or theories that guided its development X 

Impetus for strategy (e.g., statutory requirements or event) X 

Process to produce strategy (e.g., interagency task force; state, local, or 

private input) X 

Definition of key terms X 

Problem definition and risk assessment–Addressed 

Discussion or definition of problems, their causes, and operation 

environment X 

Risk assessment, including an analysis of threats and vulnerabilities X 

Quality of data available (e.g., constraints, deficiencies, and “unknowns”) X 

Goals, subordinate objectives, activities, and performance measures–Partially Addressed 

Overall results desired (i.e., “end-state”) X 

Hierarchy of strategic goals and subordinate objectives X 

Specific activities to achieve results X 

Priorities, milestones, and outcome-related performance measures X 

Specific performance measures X 

Process for monitoring and reporting on progress X 

Limitation on progress indicators X 

Resources, investments, and risk management–Partially Addressed 

Costs associated with strategy X 

Human capital associated with strategy X 

Information technology associated with the strategy X 

Research and development associated with the strategy X 

Sources of resources (e.g., federal, state, local, and private) X 

Economic principles (e.g., balancing benefits and costs) X 

Resource allocation mechanisms (e.g., grants, in-kind services, loans or user 

fees) X 

“Tools of government” (e.g., mandates or incentives to spur action) X 

Importance of fiscal discipline X 

Linkage to other resource documents (e.g., federal budget) X 

Risk management principles X 

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Appendix D 

Small Vessel Security Strategy and Draft Implementation Plan Compared Against 

Desirable Characteristics and Elements 

Desirable Characteristics and Elements Not 

Addressed 

Partially 

Addressed Addressed 

Organizational roles, responsibilities, and coordination–Partially Addressed 

Roles and responsibilities of specific federal agencies, departments, or offices X 

Roles and responsibilities of state, local, private, and international sectors X 

Lead, support, and partner roles and responsibilities X 

Accountability and oversight framework X 

Potential changes to current organizational structure X 

Specific process for coordination and collaboration X 

How conflicts will be resolved X 

Integration and implementation–Partially Addressed 

Integration with other national strategies (horizontal) X 

Integration with relevant documents from implementing organizations (vertical) X 

Details on specific federal, state, local, or private strategies and plans X 

Implementation guidance X 

Details on subordinate strategies and plans for implementation (e.g., human 

capital and enterprise architecture) X 

Totals 13 8 19 

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Appendix E 

Programs Supporting the Small Vessel Security Strategy 

America’s Waterway Watch 

U.S. Coast Guard Commandant Instruction 16618.8 established the 

America’s Waterway Watch program on February 10, 2005. The 

program’s purpose is to raise national awareness among those who 

work, live, or recreate on or near the water of suspicious activity 

that might indicate threats to our country’s homeland security. 

Individuals can report suspicious and unusual activity via the 24­

hour hotline, 1-877-24WATCH (1-877-249-2824). Calls to the 

hotline are routed through the National Response Center, where 

they are screened and forwarded to the appropriate authorities in 

the area where the suspicious activity was reported. The National 

Response Center is staffed by Coast Guard personnel who monitor 

the hotline 24 hours a day, 365 days a year. 

Citizen’s Action Network 

Coast Guard District 13 created the Citizen’s Action Network 

program in 1999 to formally engage waterfront citizens, 

businesses, and organizations in providing a homeland security 

resource. In the Puget Sound area, the Citizen’s Action Network is 

composed of more than 300 vetted members, including citizen, 

business, tribal, Canadian, and Coast Guard Auxiliary partners. 

The Coast Guard actively trains and educates Citizen’s Action 

Network members and recruits many into the ranks of the Coast 

Guard Auxiliary. Citizen’s Action Network members can contact 

the Coast Guard to report suspicious activity by calling the Coast 

Guard Auxiliary office, the America’s Waterway Watch hotline, or 

the District 13 office directly. Coast Guard District 13 can contact 

Citizen’s Action Network members through phone calls, pagers, 

text messages, e-mails, and a web community. 

Pleasure Boat Reporting System 

CBP administers the Pleasure Boat Reporting System. This 

program was designed to process the arrival of small vessels to the 

United States from foreign ports, as required by law.9 The 

Pleasure Boat Reporting System program requires small vessel 

operators to telephone the local office to report the operator’s 

personal identifying information, the vessel name, and the vessel 

registration number, as well as any passengers’ personal 

identifying information. 

9 19 U.S.C. 1433, 1434, Tariff Act of 1930 – Entry; vessels. 

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Appendix E 

Programs Supporting the Small Vessel Security Strategy 

CBP officers operating the Pleasure Boat Reporting System 

program can either clear small vessel operators and their 

passengers verbally on the telephone or require them to report in 

person within 24 hours to a Private Vessel Designated Reporting 

Location for a face-to-face inspection. These reporting locations 

include official CBP ports of entry, Pleasure Boat Reporting 

System call-in centers, and certain locations to which CBP officers 

will travel to meet and process small vessel operators as necessary. 

Boaters may be asked to report to one of these locations if a CBP 

officer deems it necessary based on the information provided. 

The Tariff Act of 1930 requires that any small vessel operator 

arriving from a foreign port who fails to report as required be liable 

for a fine of $5,000 for the first violation and $10,000 for each 

subsequent violation, and any small vessel used in connection with 

any such violation to be subject to seizure and forfeiture 

Currently, CBP officers operate the Pleasure Boat Reporting 

System program in 20 field offices, with 128 Private Vessel 

Designated Reporting Locations throughout the continental United 

States, Hawaii, and Alaska. 

Maritime Information for Safety and Law Enforcement 

The Maritime Information for Safety and Law Enforcement system 

is an internal Coast Guard database used to record all Coast Guard 

activities. Personnel enter data manually into the system, but 

information from other law enforcement databases cannot be crosslinked or automatically downloaded into the Coast Guard system. 

Coast Guard personnel can search records in the Maritime 

Information for Safety and Law Enforcement system, providing 

users with vessel details, owner information, and past vessel 

interdiction records. “Lookout reports” can be added to the 

records of previously stopped vessels to alert boarding officers 

with information obtained during past interdictions. These 

“lookout reports” are added only by Coast Guard personnel and are 

not shared with any other law enforcement databases. 

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Appendix E 

Programs Supporting the Small Vessel Security Strategy 

TECS 

TECS is a Department of the Treasury legacy system now 

managed by CBP Office of Field Operations. It connects 

thousands of databases and provides controlled access to 

personally identifiable information that is collected through other 

government databases. 

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Appendix F 

Major Contributors to This Report 

Paul Wood, Director 

Yesi Starinsky, Audit Manager 

Andrew Smith, Auditor in Charge 

Christopher Byerly, Program Analyst 

Mathew Noll, Program Analyst 

Gwendolyn Priestman, Program Analyst 

Marissa Weinshel, Program Analyst 

Corneliu Buzesan, Program Analyst 

Gary Alvino, Independent Referencer 

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Appendix G 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

Acting 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 

Respective Under Secretary 

U.S. Coast Guard Director 

CBP Director 

U.S. Coast Guard Liaison 

CBP Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

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

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

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misconduct relative to department programs or operations: 

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DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

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