U.S.-MEXICO 

BORDER

CBP Action Needed to 

Improve Wait Time 

Data and Measure

Outcomes of Trade 

Facilitation Efforts

Report to the Ranking Member, 

Subcommittee on Immigration, 

Refugees and Border Security, 

Committee on the Judiciary, 

U.S. Senate

July 2013

GAO-13-603

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-13-603, a report to 

Ranking Member, Subcommittee on 

Immigration, Refugees and Border Security, 

Committee on the Judiciary, U.S. Senate.

July 2013

U.S.-MEXICO BORDER

CBP Action Needed to Improve Wait Time Data and 

Measure Outcomes of Trade Facilitation Efforts

Why GAO Did This Study

Trade with Mexico is important to the 

United States’ economy. Most of this 

trade crosses the border by truck, and 

studies have shown that long waits at 

border crossings can negatively affect

the U.S. economy. CBP is responsible 

for securing U.S. borders at ports of 

entry to prevent illegal entry of persons 

and contraband while also facilitating 

legitimate trade and travel. GAO was 

asked to examine CBP data on and 

actions taken to address wait times at

southwest border crossings. This 

report addresses the extent to which

(1) CBP wait time data are reliable for 

public reporting and informing CBP 

decisions, (2) CBP has identified 

infrastructure and staffing needed to 

process current commercial traffic 

volumes, and (3) CBP performance 

measures assess progress toward its 

trade facilitation goal. GAO assessed 

the reliability of CBP’s wait time data;

visited six land border crossings (not 

generalizable, but selected largely for 

high traffic volume); analyzed CBP 

documentation, including needs 

assessments; and interviewed 

stakeholders and CBP officials. 

What GAO Recommends

GAO recommends that CBP (1) 

determine and take steps to help

ensure consistent implementation of 

existing wait time data collection 

methodologies, (2) assess the 

feasibility of replacing current 

methodologies with automated 

methods, (3) document its staff

allocation process and rationale, and 

(4) develop outcome-oriented

performance measures. DHS agreed

with these four recommendations and 

identified steps to address them, 

although the planned actions will not 

address the intent of one.

What GAO Found

Within the Department of Homeland Security (DHS), U.S. Customs and Border 

Protection’s (CBP) data on commercial vehicle wait times—the time it takes to 

travel from the end of the queue to the CBP primary inspection point at land 

border crossings—are unreliable for public reporting and CBP management 

decisions across border crossings. These data—which are collected manually by 

CBP officers—are unreliable because CBP officers inconsistently implement an 

approved data collection methodology, and the methodologies used vary by 

crossing. For example, five of the six crossings GAO visited require observation 

of the end of the queue to estimate wait times, but officials at these crossings 

reported the lines extended beyond their view at times. As a result, these data 

are generally not used by the private sector and are of limited usefulness for CBP 

management decisions on staffing and infrastructure investments. Determining 

and taking steps to help CBP officials overcome challenges to consistent 

implementation of existing methodologies could improve the reliability and 

usefulness of CBP’s current wait time data. CBP officials have identified 

automated wait time data collection technology as the best way to improve data 

reliability. The Department of Transportation (DOT), in coordination with state 

DOTs and CBP, has ongoing pilot projects to use technology to gather more 

reliable wait time data at some border crossings. However, CBP has not 

assessed the feasibility of replacing current methods with automated data 

collection. Doing so, consistent with program management standards, could help 

CBP determine how to best improve data reliability. 

CBP officials report and analyses indicate infrastructure and staff needs, but 

documenting CBP’s staff allocation process could improve transparency and 

facilitate review and validation by CBP and others. CBP officials and analyses 

identify needs for additional infrastructure—such as more lanes—at some 

crossings, and GAO analysis of CBP data on lane use generally supported 

agency views on the extent to which CBP opens lanes at the six crossings GAO 

visited. Further, GAO analysis of lane use and traffic volume data generally 

supported CBP officials’ statements that they open and close primary inspection 

lanes in response to fluctuations in commercial traffic volume. CBP analyses 

identified a need for 3,811 additional officers, and CBP headquarters officials told 

GAO all southwest border ports require additional staff, but CBP field and port 

managers at three of six crossings GAO visited reported having sufficient staff. 

CBP human capital officials reported that they adjust staff allocations across 

locations to better ensure that staff levels match areas of greatest need, but CBP 

has not documented this process, and there is no guidance defining the 

methodology used or factors considered when allocating staff across ports. 

Documenting this process, consistent with internal control standards, could 

improve transparency, helping CBP and others to better ensure that scarce staff 

resources are effectively allocated to fulfill mission needs across ports.

CBP does not have outcome-oriented performance measures to determine the 

extent to which the agency is facilitating trade. The Office of Management and 

Budget and GAO guidance recommend using outcome-oriented measures to 

promote accountability for results. In the absence of such measures, it is difficult 

for the agency or others to gauge CBP’s progress in meeting its stated goal of 

facilitating trade.

View GAO-13-603. For more information, 

contact Rebecca Gambler at (202) 512-8777 

or gamblerr@gao.gov.
Page i GAO-13-603 U.S.-Mexico Border

Letter 1 

Background 7

CBP’s Wait Time Data Are Unreliable for Informing the Public and 

CBP Management Decisions, and CBP Has Not Assessed the 

Feasibility of Automated Data Collection Options 14

CBP Analyses and Officials Identified Some Infrastructure and 

Staff Needs, but the Methodology Used to Allocate Staff across 

Ports of Entry Has Not Been Documented 24

CBP Performance Measures Do Not Reflect Progress in Achieving 

Trade Facilitation Goals 35

Conclusions 39

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 41

Appendix I Results of Studies on the Economic Impact of Wait Times on 

Cross-Border Commerce 44

Appendix II Objectives, Scope, and Methodology 51

Appendix III U.S. Customs and Border Protection’s Capital Investment 

Planning Process 57

Appendix IV Ongoing, Planned, or Completed Land Port of Entry 

Renovation Projects, Fiscal Years 2008 through 2012 61

Appendix V Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month, Fiscal Years 

2008-2012 65

Appendix VI Performance Measures for U.S. Customs and Border 

Protection Activities, Fiscal Year 2013 86

Contents 
Page ii GAO-13-603 U.S.-Mexico Border

Appendix VII Comments from the Department of Homeland Security 89

Appendix VIII GAO Contact and Staff Acknowledgments 93

Tables

Table 1: Infrastructure Needs as Identified in Customs and Border 

Protection (CBP) and General Services Administration 

Assessments (GSA) and by CBP Officials at the Six 

Crossings We Visited 26

Table 2: Studies of the Economic Impact of Commercial Vehicle 

Wait Times on the Southwest Border 47

Table 3: Categories of Criteria Customs and Border Protection 

Uses to Prioritize Land Port of Entry Projects 58

Table 4: Prioritization Rank of Infrastructure Needs at Commercial 

Southwest Border Crossings 58

Table 5: Completed Infrastructure Improvement Projects at 

Southwest Border Land Ports of Entry That Process 

Commercial Vehicle Traffic, Fiscal Years 2008 through 

2012 62

Table 6: Ongoing Infrastructure Improvement Projects at 

Southwest Border Land Ports of Entry That Process 

Commercial Vehicle Traffic as of May 2013 63

Table 7: Planned Infrastructure Improvement Projects at 

Southwest Border Land Ports of Entry That Process 

Commercial Vehicle Traffic, as of May 2013 64

Table 8: Descriptions of Six Selected Crossings including Year Built 

and Renovated, and the Number of Available Commercial 

Lanes, Fiscal Years 2008 through 2012 65

Table 9: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Otay Mesa 

Crossing near San Diego, California, Fiscal Years 2008 

through 2012 69

Table 10: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Mariposa Crossing 

in Nogales, Arizona, Fiscal Years 2008 through 2012 71

Table 11: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Bridge of the 
Page iii GAO-13-603 U.S.-Mexico Border

Americas Crossing in El Paso, Texas, Fiscal Years 2008 

through 2012 72

Table 12: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Ysleta Crossing in 

El Paso, Texas, Fiscal Years 2008 through 2012 74

Table 13: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Columbia 

Solidarity Bridge Crossing in Laredo, Texas, Fiscal Years 

2008 through 2012 76

Table 14: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at World Trade 

Bridge Crossing in Laredo, Texas, Fiscal Years 2008 

through 2012 78

Table 15: U.S. Customs and Border Protection-Focused 

Performance Measures, Fiscal Year 2013 87

Figures

Figure 1: Commercial Vehicles in Line to Enter the United States at 

Otay Mesa near San Diego, California 8

Figure 2: Commercial Vehicle Inspection Process at a Land Port of 

Entry 10

Figure 3: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Selected 

Southwest Border Crossings, Fiscal Years 2008-2012 30

Figure 4: The Otay Mesa Crossing near San Diego, California 66

Figure 5: Commercial Vehicle Primary Inspection Lanes at the 

Mariposa Crossing in Nogales, Arizona 66

Figure 6: The Bridge of the Americas Crossing in El Paso, Texas 67

Figure 7: The Ysleta Crossing in El Paso, Texas 67

Figure 8: The Columbia Solidarity Bridge Crossing in Laredo, Texas 68

Figure 9: The World Trade Bridge Crossing in Laredo, Texas 68

Figure 10: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Otay Mesa 

Crossing near San Diego, California, Fiscal Year 2008 

through 2012 80

Figure 11: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at the Mariposa 

Crossing in Nogales, Arizona, Fiscal Year 2008 through 

2012 81

Figure 12: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at the Bridge of the 
Page iv GAO-13-603 U.S.-Mexico Border

Americas Crossing in El Paso, Texas, Fiscal Year 2008 

through 2012 82

Figure 13: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Ysleta Crossing in 

El Paso, Texas, Fiscal Year 2008 through 2012 83

Figure 14: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at Columbia 

Solidarity Bridge Crossing in Laredo, Texas, Fiscal Year 

2008 through 2012 84

Figure 15: Average Hourly Traffic Volume and Average Hourly 

Percentage of Lanes Open Per Month at World Trade 

Bridge Crossing in Laredo, Texas, Fiscal Year 2008 

through 2012 85
Page v GAO-13-603 U.S.-Mexico Border

Abbreviations

ARRA American Recovery and Reinvestment Act

ATU Advance Targeting Unit

CBP U.S. Customs and Border Protection

CIP capital investment plan

C-TPAT Customs and Trade Partnership Against Terrorism

DHS Department of Homeland Security

DOT Department of Transportation

FAST Free and Secure Trade

FDA Food and Drug Administration

FHWA Federal Highway Administration

FOUO for official use only

GDP gross domestic product

GPRA Government Performance and Results Act

GSA General Services Administration

OA Office of Administration

OFO Office of Field Operations

OMB Office of Management and Budget

SRA Strategic Resource Assessment

WHTI Western Hemisphere Travel Initiative

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Page 1 GAO-13-603 U.S.-Mexico Border

441 G St. N.W.

Washington, DC 20548

July 24, 2013

The Honorable John Cornyn

Ranking Member

Subcommittee on Immigration, Refugees 

 and Border Security

Committee on the Judiciary

United States Senate

Dear Senator Cornyn:

Trade with Mexico, the nation’s third-largest trade partner behind Canada 

and China, is important to the United States’ economic health, and timely 

access to Mexican goods is important to both U.S. manufacturers and 

consumers. The value of goods imported into the United States from 

Mexico has increased over 30 percent in the last 5 years, and in 2012 

imports from Mexico were valued at nearly $278 billion. Most of this trade 

crosses the border by commercial truck, and in 2012 there were over 5 

million truck crossings into the United States from Mexico. Industry 

representatives who rely on commercial vehicles to quickly transport 

goods across the U.S.-Mexico border have raised concerns about long 

waits at border crossings, and several studies have shown that the time 

that commercial vehicles spend waiting to cross into the United States 

from Mexico can have a negative impact on the U.S. economy in terms of 

lost revenue and jobs.

The Department of Homeland Security’s (DHS) U.S. Customs and Border 

Protection (CBP) is the lead federal agency charged with a dual mission 

of keeping terrorists, criminals, and inadmissible aliens out of the country 

while facilitating the flow of legitimate travel and commerce at the nation’s 

borders.1

 

1

The agency’s trade facilitation goals are articulated in DHS’s February 2010 Quadrennial 

Homeland Security Review Report, which outlined a strategic framework for homeland 

security. The two relevant mission goals are to (1) prevent the illegal flow of people and 

goods across U.S. air, land, and sea borders while expediting the safe flow of lawful travel 

and commerce, and (2) ensure security and resilience of global movement systems (which 

includes global trading and transportation networks). See DHS, Quadrennial Homeland 

Security Review Report: A Strategic Framework for a Secure Homeland (Washington, 

D.C.: February 2010).

CBP’s Office of Field Operations (OFO) is responsible for cargo 

and passenger processing activities related to security, trade, 

 
 

Page 2 GAO-13-603 U.S.-Mexico Border

immigration, and agricultural inspection at air, land, and sea ports of 

entry, and CBP’s Office of Administration (OA) is responsible for real 

estate management, including the construction, maintenance, and leasing 

of facilities, such as land ports of entry.2

We previously reported that CBP has faced challenges balancing the 

goals of security and trade facilitation, and some information necessary to 

assess its trade facilitation efforts has not been available.

CBP’s focus has historically been 

on security; however, CBP has also undertaken specific efforts to 

facilitate legitimate travel and trade, such as launching the Free and 

Secure Trade (FAST) program in 2002 to expedite the travel of low-risk 

screened shipments across the border, and publishing border crossing 

wait times on a website to inform public and private sector border 

crossing decisions.

3 Specifically, 

we reported in July 2010 that CBP’s Automated Commercial Environment 

collected data on freight processing but did not differentiate between 

FAST and non-FAST shipments—information needed to help CBP 

determine the extent to which FAST program participants experience 

intended benefits.4

 

2

The General Services Administration (GSA) also has responsibilities related to the 

construction and maintenance of GSA-owned facilities that include land ports of entry. 

Ports of entry are the facilities that provide for the controlled entry into or departure from 

the United States for persons and materials. Specifically, a port of entry is any officially 

designated location (seaport, airport, or land border location) where DHS officers or 

employees are assigned to clear passengers and merchandise, collect duties, and enforce 

customs laws. A single land port of entry may be composed of one or more crossings. For 

example, the Port of Laredo, Texas, headed by a port director, oversees operations at four 

separate border crossings, one rail crossing, and one airport. CBP operates 168 land 

border crossings, 46 of which are located on the southwest border.

We recommended that CBP (1) develop milestones 

for completing enhancement of the database used to capture data on 

FAST program benefits, and (2) conduct a study to determine if program 

benefits are being realized that could help CBP determine what program 

adjustments, if any, are needed. CBP agreed with these

recommendations; took action to collect the needed data; and, as of June 

2013, drafted an evaluation of FAST lanes and commercial traffic at 

select crossings on the northern border to determine whether there is a 

need to expand the usage of FAST lanes. This study is currently under 

3

GAO, Border Security: CBP Lacks the Data Needed to Assess the FAST Program at 

U.S. Northern Border Ports, GAO-10-694 (Washington, D.C.: July 19, 2010).

4

CBP’s Automated Commercial Environment is CBP’s commercial trade processing 

system—one of several databases and tools used by CBP to screen and assign risk levels 

to travelers and cargo entering the United States.
 

Page 3 GAO-13-603 U.S.-Mexico Border

review and CBP expects to fully implement this recommendation by 

December 30, 2013.

You asked us to review what data CBP collects and reports on wait times 

for commercial vehicles at southwest border land ports of entry and 

actions CBP has taken to reduce those wait times. This report addresses 

the following questions:

• To what extent are CBP wait time data reliable for public reporting and 

informing CBP decisions on staffing and infrastructure investments?

• To what extent has CBP identified infrastructure and staffing needed 

to process current commercial traffic volume at select southwest 

border crossings with high traffic volume?

• To what extent do CBP performance measures assess progress 

toward its goal of facilitating trade?

This report also presents information on the results of studies that have 

quantified the economic impact of commercial vehicle wait times on cross 

border commerce. This information, including the methodology used to 

identify these studies, is presented in appendix I.

To inform our analysis of the first and second objectives, we visited six 

border crossings—Bridge of the Americas and Ysleta in El Paso, Texas; 

World Trade Bridge and Columbia Solidarity Bridge in Laredo, Texas; 

Mariposa in Nogales, Arizona; and Otay Mesa near San Diego, 

California—selected based on their commercial traffic volume, geographic 

diversity, and representation of a mix of recent or ongoing infrastructure 

modernization projects. At each location, we interviewed CBP 

management, toured the facility, and convened a roundtable of local 

industry representatives and local government officials. To obtain a range 

of perspectives on commercial vehicle traffic at southwest border 

crossings, we met with representatives of 21 companies and associations 

(who were identified to us as knowledgeable stakeholders representing 

industries that rely on cross-border commerce, including customs 

brokers, trucking companies, and distributors) as well as bridge directors 

and representatives of four local government entities (the Mayors of El 

Paso and San Diego, the Laredo City Manager, and representatives of 

the San Diego Association of Governments) at all four cities we visited or 
 

Page 4 GAO-13-603 U.S.-Mexico Border

by teleconference.5 We also interviewed officials from federal agencies 

involved in securing the border and facilitating trade at land ports of entry. 

Although the results of our site visits and interviews are not generalizable, 

they provided us with perspectives on operations at ports of entry that

accounted for a total of approximately 70 percent of the commercial 

vehicle crossings into the United States from Mexico for fiscal year 2008 

through July 2012. Over the course of our work, we also interviewed other 

stakeholders, including officials from the Mexican Foreign Ministry, 

academics, and representatives of national trade associations, such as 

the American Trucking Associations and the Border Trade Alliance, to 

obtain a broader range of perspectives on commercial vehicle traffic at 

southwest border crossings.6

To address the first objective, we reviewed and analyzed CBP’s policies 

and guidance for calculating and reporting wait times and CBP 

evaluations of its wait time data, including a fiscal year 2008 CBP 

Commercial Wait Times Analysis Report completed by CBP’s Western 

Hemisphere Travel Initiative (WHTI) Office.7

 

5

The San Diego Association of Governments is a public planning, transportation, transit 

construction, and research agency.

We also reviewed CBP’s 

fiscal year 2012 wait time data for the six crossings we visited and 

compared documentary and testimonial evidence of how wait times are 

currently being calculated by officials at land ports of entry on the 

southwest border against CBP policies and guidance to identify any 

discrepancies. We also compared CBP’s policies and guidance with 

6

These organizations and officials were identified to us as knowledgeable stakeholders 

who could provide us with a range of perspectives on commercial vehicle traffic at 

southwest border crossings. The American Trucking Associations is a national trade and 

safety organization representing the U.S. trucking industry. The Border Trade Alliance is a 

nonprofit organization that serves as a forum for participants to address key issues 

affecting trade, travel, and security in North America.

7

CBP reported on the reliability of wait time calculations in its Western Hemisphere Travel 

Initiative, Commercial Wait Times Analysis Final Report, October 2007-September 2008. 

The goal of WHTI is to facilitate entry for U.S. citizens and legitimate foreign visitors while 

strengthening U.S. border security. The WHTI Program Office sponsored this evaluation 

of commercial vehicle wait times to validate the current wait time reporting systems at 

individual crossings and to determine if a national standard for reporting wait times can be 

established. 
 

Page 5 GAO-13-603 U.S.-Mexico Border

criteria in Standards for Internal Control in the Federal Government.

8 Our 

assessment of the reliability of these data is discussed later in this report. 

To determine the status of the Department of Transportation’s (DOT) pilot 

projects to automate wait time data at the southwest border, we 

interviewed officials at DOT’s Federal Highway Administration (FHWA), 

Texas Department of Transportation, and Texas A&M University and 

reviewed documentary evidence they provided, such as written updates 

on the status of certain pilot projects.9 We compared CBP’s plans to 

automate wait times with standards for program management.10

To address the second objective, we reviewed and analyzed CBP and 

General Services Administration (GSA) assessments of land port of entry 

capacity, such as CBP’s Strategic Resource Assessments (SRA), and 

reviewed documentation of CBP’s Workload Staffing Model, used to 

determine staff needs at land ports of entry.11

 

8

GAO, Standards for Internal Control in the Federal Government, 

We also interviewed CBP 

and GSA officials about infrastructure needs at land border crossings and 

how these needs are identified and prioritized. We interviewed CBP 

officials about the agency’s staff allocation policies and processes and 

compared these with criteria in our previous work on human capital 

management and Standards for Internal Control in the Federal 

GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). These standards, issued pursuant to the 

requirements of the Federal Managers’ Financial Integrity Act of 1982, Pub. L. No. 97-255, 

96 Stat. 814, provide the overall framework for establishing and maintaining internal 

control in the federal government. 

9

As described later in this report, automation of wait time data collection relies on RadioFrequency Identification readers to read the unique signals from passing vehicles at 

several points along the border-crossing route. These data points are then automatically 

matched and analyzed to estimate the current wait time at that crossing.

10Project Management Institute, The Standard for Program Management©, Second 

Edition, (Newton Square, Pennsylvania: 2008).

11The SRA is a needs assessment process by which CBP collects and analyzes 

information about the infrastructure at each crossing along the northern and southwestern 

borders, identifies needs, and prioritizes infrastructure improvement projects. CBP officials 

reported conducting these assessments fiscal years 2003 through 2006.
 

Page 6 GAO-13-603 U.S.-Mexico Border

Government.

12

To address the third objective, we reviewed documentation of CBP’s 

fiscal year 2013 performance goals, measures, and reports. We assessed 

CBP’s measures against criteria in Office of Management and Budget 

(OMB) Circular No. A-11 and useful practices GAO previously identified 

to enhance performance management and measurement processes.

We also analyzed CBP data on traffic volume and the 

number of primary lanes open during operating hours at the six crossings 

from fiscal years 2008 through 2012. We selected this time period for our 

data analyses to permit a trend analysis. Our data analyses are not 

generalizable to the entire southwest border, but represent trends at six 

high-volume crossings. To assess the reliability of these data sources, we 

reviewed documentation, interviewed agency officials, electronically 

tested the data, reviewed internal controls, and traced a selection of data 

to source files. We determined that the data were sufficiently reliable for 

the purposes of our report.

13

We also identified studies that quantified the economic impact of 

commercial vehicle wait times on cross-border commerce by searching 

literature and asking relevant interviewees whether they were aware of 

any such studies. We reviewed over 100 identified studies and analyzed 

the 6 studies that determined an economic impact of commercial vehicle 

We also interviewed relevant DHS and CBP officials regarding CBP’s 

current performance measures and the extent to which CBP uses its wait 

time data to measure progress, among other things.

 

12See GAO, A Model of Strategic Human Capital Management, GAO-02-373SP 

(Washington, D.C.: March 2002), and GAO/AIMD-00-21.3.1. The first report describes a 

human capital model we developed that identifies eight critical success factors for 

managing human capital strategically. In developing this model, we built upon GAO’s 

Human Capital: A Self-Assessment Checklist for Agency Leaders, GAO/OCG-00-14G

(Washington, D.C.: September 2000). Among other steps, we also considered lessons 

learned from GAO reports on public and private organizations that are viewed as leaders 

in strategic human capital management and managing for results.

13See OMB Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012). See also GAO, Managing for Results: Strengthening 

Regulatory Agencies’ Performance Management Practices, GAO/GGD-00-10 

(Washington, D.C.: Oct. 28, 1999). In this report we gathered information from 23 federal 

and state organizations that we or other credible sources identified as using or planning to 

use a variety of useful practices to enhance specific aspects of their performance 

management and measurement processes. The organizations, although they had different 

missions, sizes, and organizational structures, said they consistently recognized that 

these practices are important in their efforts to develop a stronger results orientation.
 

Page 7 GAO-13-603 U.S.-Mexico Border

wait times on the southwest border. A more detailed description of our 

methodology and the results of these studies are presented in appendix I.

We conducted this performance audit from July 2012 to July 2013 in 

accordance with 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 objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. Additional details on our scope 

and methodology are contained in appendix II.

In addition to CBP, various agencies have responsibilities for facilitating 

trade at land ports of entry and conducting inspections of commercial 

vehicles. GSA oversees design, construction, and maintenance for all 

ports of entry in consultation with CBP. In consultation with GSA, CBP 

develops an investment plan to manage the modernization of the land 

ports of entry inventory. Within DOT, FHWA provides funding for highway 

and road construction. In addition, the Federal Motor Carrier Safety 

Administration and state DOTs in some states—Arizona, Texas, and 

California on the southwest border—may conduct commercial vehicle 

inspections at or adjacent to land ports of entry to ensure compliance with 

federal and state-specific safety standards. 

In executing its mission, CBP operates 168 land border crossings, which 

vary in size, location, and commercial traffic volume. Of these, 46 

crossings are located on the southwest border, and 24 of these crossings 

process commercial vehicle traffic. The four largest land border ports of 

entry on the southwest border by commercial vehicle traffic volume are 

Laredo, Texas; Otay Mesa, California; El Paso, Texas; and Calexico 

East, California. See figure 1 for a picture of commercial vehicles in line to 

enter the United States at the Otay Mesa border crossing near San 

Diego, California.

Background 

Agencies’ Responsibilities 

at Land Ports of Entry
 

Page 8 GAO-13-603 U.S.-Mexico Border

Figure 1: Commercial Vehicles in Line to Enter the United States at Otay Mesa near 

San Diego, California

Note: This photo was taken on April 22, 2011.

Processing commercial vehicles into the United States at land ports of 

entry involves various steps and requirements.14 First, CBP requires 

carriers to submit electronic lists describing their shipments, known as eManifests, prior to a shipment’s arrival at the border.15

 

14For the purpose of this report, we focused on commercial vehicle traffic, as opposed to 

private vehicle or pedestrian traffic.

Second, CBP 

reviews the e-Manifest using its Automated Commercial Environment 

15The entry document (e-Manifest) contains information about a shipment, including the 

shipment type, conveyance, passenger/crew, and equipment. E-Manifests for FAST 

shipments must be submitted 30 minutes before arrival, and e-Manifests for non-FAST 

shipments must be submitted at least 1 hour before arrival. See 19 C.F.R. § 123.92(a).

Inspections of Commercial 

Vehicles at Land Ports of 

Entry 
 

Page 9 GAO-13-603 U.S.-Mexico Border

database, among others, and assigns a risk level to the shipment.16 Next, 

the commercial vehicle proceeds into the United States and to a primary 

inspection booth at the U.S. port of entry, where a CBP officer reviews 

documentation on the exporter, importer, and goods being transported. If 

the documentation is consistent with CBP requirements and no further 

inspections are required, the truck is allowed to pass through the port. 

Depending on the port of entry, goods imported, or law enforcement 

requirements, CBP may direct the commercial truck to secondary 

inspection. According to CBP, trucks are referred to secondary inspection 

for numerous reasons, such as officer’s initiative, targeted inspection, or 

random inspection.17 Secondary inspection involves more detailed 

document processing and examinations using other methods including 

gamma ray imaging systems and advanced radiation portal monitors or 

unloading and physical inspection.18 Trucks that require secondary 

inspection may be inspected by more than one federal agency, 

depending on their cargo.19

 

16CBP uses various databases and tools, including the Automated Targeting System, 

Automated Commercial Environment, and local Advance Targeting Units (ATU) to screen 

and assign risk levels to travelers and cargo entering the United States. 

See figure 2 for an illustration of the steps in 

the commercial vehicle inspection process at land ports of entry.

17According to CBP, officers select shipments for targeted inspection based on several 

factors. Specifically, shipments may be selected for targeted inspection based on 

information provided by the ATUs, Manifest Review Units, Document Analysis Units, and 

other specialized enforcement units. The ATUs use information from the Automated 

Targeting System or Automated Commercial Environment to review manifest data prior to 

the shipments crossing into the United States. The Manifest Review Units are responsible 

for analyzing manifests, which list in detail the total cargo of shipments. Examples of data 

elements on a manifest include shipper, point and country of origin of goods, export 

carrier, and description of packages and goods. The Document Analysis Units are 

responsible for analyzing fraudulent documents.

18Prior to the primary inspection booths, CBP also screens commercial traffic using 

radiation portal monitors to detect nuclear and radiological materials. Radiation portals are 

capable of detecting various types of radiation emanating from nuclear devices, dirty 

bombs, special nuclear materials, natural sources, and isotopes commonly used in 

medicine and industry. Unlike gamma ray imaging systems—such as CBP’s Vehicle and 

Cargo Inspection System—these devices do not produce images, but are passive 

systems that alert when energy emitted by radioactive sources is detected.

19For example, according to officials with the U.S. Department of Health and Human 

Services’ Food and Drug Administration (FDA), FDA personnel conduct public health 

inspections on incoming commercial vehicles on the southwest border in an effort to 

ensure that food and food products from abroad meet U.S. standards.
 

Page 10 GAO-13-603 U.S.-Mexico Border

Figure 2: Commercial Vehicle Inspection Process at a Land Port of Entry
 

Page 11 GAO-13-603 U.S.-Mexico Border

To facilitate the travel of low-risk screened shipments across the border, 

CBP created the FAST program, which is intended to secure and facilitate 

legitimate trade by providing expedited processing of participants’ 

merchandise in designated traffic lanes at select border crossings, fewer 

referrals to secondary inspections, “front-of-the-line” processing for CBP 

secondary inspections, and enhanced security.20 To be eligible to receive 

the benefits of the FAST program, every link in the supply chain—the 

carrier, the importer, and the manufacturer—is required to be certified 

under the Customs and Trade Partnership Against Terrorism (C-TPAT) 

program and the driver must be preapproved for participation in the FAST 

program.21

CBP defines border wait time as the time it takes for a vehicle to travel 

from the end of the queue—which may be in Mexico or the United States, 

depending on the length of the line—to the CBP primary inspection point 

in the United States. See figure 2 for an illustration of these points in the 

border-crossing process. As a service to the traveling public and the trade 

community, CBP began publicly reporting hourly wait time data through a 

web page on CBP.gov in early 2004, and currently reports these data for 

42 of 46 crossings on the southwest border. CBP began formally 

collecting commercial and private passenger vehicle wait times on a daily 

basis in late September 2001 in response to the delays experienced

immediately after September 11, 2001, when heightened enforcement 

efforts resulted in significant delays at many land border ports of entry. 

Over time, the collection of wait time data evolved as additional crossings 

were added and the amount of information collected was expanded. CBP 

reported that it is important that the trade community have current and 

consistent wait times on the CBP web site, noting that the web site is the 

only source of wait time information at many locations.

 

20Front-of-the-line processing refers to opportunities at some crossings for FAST vehicles 

to begin their secondary inspection before non-FAST vehicles when there is a backup of 

traffic waiting for secondary inspection. 

21C-TPAT is a customs-to-business partnership program that provides benefits to supply 

chain companies that agree to comply with predetermined security measures.

CBP Public Reporting of 

Border Crossing Wait Time 

Data
 

Page 12 GAO-13-603 U.S.-Mexico Border

Some border stakeholders, such as those in the private sector, find “total 

crossing time” to be a more useful measure than CBP’s definition of wait 

time. Unlike CBP’s narrower “wait time” measure, which captures the time 

it takes for a vehicle to travel from the end of the queue to the CBP 

primary inspection point, total crossing time is generally defined as the 

total time elapsed from entering the line in Mexico leading to Mexican 

export inspection through exit from U.S. inspection facilities, including any 

U.S. state-conducted inspections. See figure 2 for an illustration of the 

differences between these two measurements.

CBP has developed a workload staffing model to determine the optimum 

number of CBP officers that each port of entry needs to accomplish its 

mission responsibilities at its land, air, and sea ports of entry. This model 

existed in different versions, beginning in fiscal year 2006. The 

conference report for the fiscal year 2007 DHS appropriations act, 

expressing concern regarding CBP’s ability to align staffing resources to 

mission requirements, directed CBP to submit a resource allocation 

model for staffing requirements that would explain CBP’s methodology for 

aligning staffing levels with threats, vulnerabilities, and workload across 

all mission areas.22 In April 2013, CBP submitted the most recent version 

of its workload staffing model to Congress in response to language in the 

conference and committee reports for the fiscal year 2012 DHS 

appropriations.23

DHS has received appropriations to support increased staffing levels for 

CBP officers on the southwest border over the last 5 fiscal years. For 

example, the conference report accompanying the fiscal year 2009 

supplemental appropriation indicated that it included $30 million to fund 

the hiring of up to 125 CBP officers for the southwest border, and the 

fiscal year 2010 emergency supplemental appropriation for border 

 

22H.R. Rep. No. 109-699, at 126 (2006) (Conf. Rep.). The explanatory statement for the 

fiscal year 2008 consolidated appropriations act noted that CBP had submitted the 

resource allocation model and had developed a workload staffing model to generate 

estimates of staffing needed to meet workload and mission requirements. 

23H.R. Rep. No. 112-331, at 958 (2011) (Conf. Rep.); H.R. Rep. No. 112-91, at 27-28 

(2011); S. Rep. No. 112-74, at 31 (2011).

CBP Staff at Land Border 

Crossings 
 

Page 13 GAO-13-603 U.S.-Mexico Border

security included $29 million for hiring additional CBP officers for 

southwest border land ports of entry.24

CBP and GSA have assessed infrastructure needs at all land border 

crossings over the last 9 fiscal years. From fiscal years 2004 to 2006, 

CBP assessed its complete portfolio of land port of entry facilities and 

identified infrastructure investment needs through its SRA process. The 

SRA includes architectural and analytical assessments of land port of 

entry inspection facilities’ condition and operations as well as relevant 

regional planning data and studies. Appendix III provides more 

information regarding CBP’s SRA process.

GSA has also assessed land port of entry infrastructure needs when 

planning and designing land port of entry renovation projects. For 

example, before undertaking construction, GSA evaluates the design of 

projects to renovate, expand, or construct a new land port of entry using 

its BorderWizardTM program—a program used to simulate projected traffic 

flow through the proposed facility to help identify potential deficiencies, 

such as insufficient primary inspection lanes.25 See appendix IV for more 

information on completed, ongoing, or planned infrastructure 

improvement projects at southwest border land ports of entry for fiscal 

years 2008 through 2012.

 

24H.R. Rep. No. 111-151, at 110 (2009) (Conf. Rep.); Pub. L. No. 111-230, 124 Stat. 

2485, 2485 (2010).

25BorderWizardTM analyses include factors such as projected traffic volume, workload 

processing time, and the proposed infrastructure improvements. The analysis does not 

take into account staffing levels at the port of entry. 

Assessments of Port 

Infrastructure 
 

Page 14 GAO-13-603 U.S.-Mexico Border

CBP policy identifies two methodologies to be used by ports of entry for 

manually calculating wait times for commercial vehicles; however, 

challenges in implementing these methodologies contribute to CBP wait 

time data being of limited usefulness for public reporting and 

management decision making across border crossings. Specifically, CBP 

policy provides port directors two options for manually calculating wait 

times at the border crossings they oversee: (1) line-of-sight and (2) driver 

survey. Port directors for each crossing are to choose which methodology 

to use based primarily on a consideration of the infrastructure layout of 

each crossing. CBP officers at border crossings are to use the first 

methodology when the end of the line is visible via the naked eye or 

camera. In accordance with this methodology, the CBP supervisor at the 

crossing is to estimate wait time based on traffic volume, number of lanes 

open, and where the end of the queue occurs relative to landmarks (i.e., 

foot of bridge, building, or intersection). When the end of the line is not 

visible, CBP policy recommends that officials estimate wait times using 

the second methodology—asking at least five drivers how long they have 

been waiting in the queue, dropping the highest and lowest responses, 

and averaging the rest.

CBP’s October 2007 interim guidance, which prescribes these two

methodologies to calculate wait times, states that “it is critically important 

that all locally posted wait times for ports or crossings are reasonably 

accurate and are uniformly reported by all stakeholders.” In addition, 

CBP’s May 2008 memorandum on land border wait time measurement 

states that “the importance of accurate land border wait time measures 

cannot be understated. Efficient and reliable land border wait time 

measures help to facilitate the movement of people and goods across our 

CBP’s Wait Time Data 

Are Unreliable for 

Informing the Public 

and CBP Management 

Decisions, and CBP 

Has Not Assessed the 

Feasibility of 

Automated Data 

Collection Options

Wait Time Data Are 

Unreliable and of Limited 

Usefulness; CBP Has Not 

Taken Steps to Improve Its 

Current Wait Time 

Estimation Methodology
 

Page 15 GAO-13-603 U.S.-Mexico Border

border and directly impact the economic health of border communities 

and the nation as a whole.” Among the six crossings we visited, Mariposa 

used driver surveys, and the remaining five crossings used line of sight to 

estimate wait times. However, CBP’s wait time data are of limited 

usefulness for public reporting and management decision making across 

border crossings because of three key factors: (1) CBP officers 

inconsistently implemented the line-of-sight methodology; (2) the other 

CBP-approved methodology, driver surveys, is inherently unreliable; and 

(3) CBP officials use different methodologies to calculate wait times 

across land border crossings.26

Inconsistent implementation of line-of-sight methodology: Port 

directors at the five crossings we visited that primarily used the line-ofsight methodology cited implementation challenges resulting in data that 

are not reliable for management decisions and informing the public.27

• At all five of the crossings, the end of the queue at times extended 

beyond the landmarks used in the line-of-sight methodology and none 

had a camera system in place with the capacity to consistently view 

the end of queues. Two crossings—World Trade Bridge and Columbia 

Solidarity Bridge—had camera systems that allowed officials to view 

the queue several miles into Mexico, but CBP officers noted that it 

could not be used to see the end of the queue on hazy and dusty 

days. CBP previously reported in a fiscal year 2008 WHTI program 

office study on the reliability of CBP’s methods for calculating 

commercial vehicle wait times that if officials cannot see the end of 

the line, they cannot accurately gauge the full duration of wait times.

Specifically:

• At two crossings—World Trade Bridge and Columbia Solidarity 

Bridge—senior field office and port officials noted that there were 

frequently gaps between groups of trucks in the queue and that at one 

of these crossings trucks comingled with private cars on the bridge 

 

26CBP officials responsible for maintaining CBP’s wait time data and others noted that 

they do not maintain information on the wait time calculation methodologies used at each 

crossing. They reported that they would have to ask officials at each crossing to develop 

such a list. 

27CBP officials at three of the five crossings that reported primarily using the line-of-sight 

methodology also reported using the driver survey methodology at times, such as during 

construction or to routinely check their line-of-sight methodology. 
 

Page 16 GAO-13-603 U.S.-Mexico Border

leading up to the primary inspection booths for commercial traffic. 

According to these officials, these factors hinder officers’ ability to 

accurately determine the full duration of wait times as gaps or cars 

between commercial vehicles may make wait times appear to be 

longer or shorter than they actually are.

• At one crossing—Otay Mesa—CBP officers used the line-of-sight 

methodology but did not consider the number of primary inspection 

lanes open, as required by CBP policy.28

Driver survey methodology is unreliable: CBP’s fiscal year 2008 WHTI 

study on the reliability of CBP’s methods for calculating commercial 

vehicle wait times stated that driver surveys have been shown to be 

consistently inaccurate when measuring wait time in part because they 

measure the wait time of travelers currently at the front of the queue, not 

the expected wait time of travelers currently at the end of the queue. As a 

result, if queuing conditions quickly change, the wait times collected using 

this methodology become inaccurate. In addition, Port officials at 

Mariposa used driver surveys as the crossing’s primary method of 

estimating wait times, but noted that the methodology produced unreliable 

wait time data. Senior CBP officials at this crossing reported that officers 

had to use driver surveys to estimate wait times because a curve in the 

road leading up to the crossing obstructs officers’ view of the queue, 

thereby preventing the crossing from using the line-of-sight approach. 

Senior CBP officials at this crossing stated that driver survey is an 

unreliable methodology because of survey bias—drivers may be inclined 

to report longer or shorter wait times than they actually experienced.

The number of lanes open to 

commercial vehicle traffic influences the rate at which traffic moves 

through primary inspection. CBP’s fiscal year 2008 WHTI study on the 

reliability of CBP’s methods for calculating commercial vehicle wait 

times notes that the number of lanes open greatly affects wait time, so 

not considering the number of lanes open limits CBP’s ability to 

accurately estimate wait times using the line-of-sight methodology.

Different methodologies across land border crossings: Port directors 

choose between the two CBP-approved methodologies to estimate wait 

times in accordance with CBP policy; however, OFO and OA 

headquarters officials stated that the use of different methodologies at 

 

28CBP officials at Otay Mesa did not respond to our question about why the number of 

primary inspection lanes was not considered.
 

Page 17 GAO-13-603 U.S.-Mexico Border

crossings precludes comparison of data across locations in making 

management decisions. Although officials at each crossing determine 

which of the two methodologies to use based on the layout of each 

crossing and other local characteristics, the use of different 

methodologies at crossings makes CBP’s wait time data unreliable for 

comparison across southwest border crossings, as they may produce 

different results. OFO and OA headquarters officials told us that because 

of the different methodologies used at different crossings, the wait time 

data are not comparable across crossings and therefore are of limited use 

in making resource allocation decisions.

In light of these challenges in implementing CBP’s approved 

methodologies for estimating wait times, CBP’s wait time data do not 

allow for reliable trend analysis to show the extent of wait times within or 

across southwest border crossings. Industry representatives at two of the 

six crossings we visited reported that, in their view, the actual wait times 

commercial vehicle drivers experienced were often longer than those 

CBP publicly reported. For example, industry representatives at the 

roundtable we convened in Nogales reported their view that wait times, as 

defined by CBP, were at times up to 2 hours longer than those CBP 

publicly reported. Industry representatives at two other crossings reported 

that CBP’s wait time data were generally accurate.29

Wait time data currently reported on CBP’s public website are of limited 

usefulness to inform industry and the public because of the data 

In addition, three 

organizations that commissioned studies to quantify the economic impact 

of wait times at southwest border crossings did not use CBP’s wait time 

data as the basis for their studies but rather collected original wait time 

data by, for example, using cameras to photograph trucks’ license plates 

at various points along the border-crossing routes and then matching 

these photographs to identify the wait time of each vehicle. (See appendix 

I for the results of these studies.) Because of these various limitations, we 

and others cannot use CBP’s wait time data to analyze the extent of 

current wait times across border crossings on the southwest border or 

determine historical trends.

 

29Officials at these two crossings noted that CBP’s wait time data are of limited usefulness 

because they do not capture total crossing time. Industry representatives we met with at 

the remaining two of six crossings indicated the need for a standardized system for wait 

time measurement but did not specifically indicate whether CBP’s wait time data were 

longer or shorter than actual waits they experienced.
 

Page 18 GAO-13-603 U.S.-Mexico Border

limitations we identified and because they do not reflect the total border 

crossing time. None of the industry stakeholders representing 21 

companies and associations we met with over the course of our study 

reported using CBP’s wait time data because they questioned the 

accuracy of the data. Industry representatives at the roundtables we

convened in Nogales, San Diego, and Laredo said that more reliable wait 

time data would be useful to, for example, help businesses improve the 

efficiency of their operations and to make informed decisions including 

where to build new facilities, how much inventory to maintain, when and 

how frequently to send shipments across the border, and when to 

schedule truckers’ or manufacturing plant employees’ shifts. In addition, 

industry representatives at our roundtables in El Paso and San Diego 

noted that they did not use CBP’s wait time data because the data did not 

provide information on the duration of the complete border-crossing 

experience—total crossing time—a more comprehensive measure that 

would be helpful in making business decisions.30

In addition, according to CBP headquarters officials, these wait time data 

are also not sufficiently reliable to inform CBP management decisions—

more specifically, decisions on staffing and infrastructure investments—

and officers at the six crossings we visited told us that they use the wait 

time data in limited ways. At the headquarters level, OFO officials stated 

that because of data limitations, CBP’s wait time data are not useful for 

comparison across crossings and explained that they do not use the data 

as a basis for determining staffing needs or allocating staff across field 

offices but rather rely on CBP’s traffic volume data as a proxy.

A 2008 study 

commissioned by the Department of Commerce also found it was 

important to use a measure of total crossing time to capture the bordercrossing system as a whole, and to account for the fact that wait time 

associated with U.S. primary inspection was not the sole driver of total 

wait time for commercial vehicles. Instead, they reported that delays were 

due to several factors, including many outside U.S. federal control. FHWA 

officials acknowledge the value of total crossing time and are piloting 

projects to automate such data collection.

31

 

30CBP officials report that industry’s interest in total crossing time may present an 

opportunity for CBP to engage in a public-private partnership. 

A senior 

31According to CBP officials and documents, CBP’s workload staffing model does not (1) 

consider CBP’s current wait time data as an input, or (2) assume a certain wait time goal 

because the model is not designed to calculate different results depending on 

performance-related goals, such as meeting wait time service goals.
 

Page 19 GAO-13-603 U.S.-Mexico Border

OFO human capital official explained that the wait time data are not 

systematically compared across ports but ports with known chronic wait 

time problems do get consideration in staff allocation decisions. Similarly, 

OA headquarters officials stated that they do not use wait time data to 

prioritize infrastructure improvement projects because of concerns about 

the reliability of CBP’s wait time data. However, CBP field office and port 

officials reported using their existing wait time data to a limited extent to 

inform management decisions in the field. Specifically, senior CBP 

officials at the six crossings we visited reported using wait time data as 

one of various factors considered when, for example, allocating staff 

across crossings and shifts, overtime decisions, and as support for white 

papers sent to headquarters requesting funding for infrastructure 

improvement projects. CBP officials at the six crossings we visited 

reported that more reliable wait time data would be useful to them in 

making such decisions. For example, CBP officials at each of these 

crossings stated that more reliable wait time data would help them in 

making staffing decisions.

CBP does not have efforts underway or planned to help port officials 

overcome challenges to consistent implementation of existing wait time 

estimation methodologies. For example, CBP has not fully implemented 

recommendations from a fiscal year 2008 CBP study that could help the 

agency implement its current wait time estimation methodologies more 

reliably. In fiscal year 2008, CBP’s WHTI program office studied the 

reliability of CBP’s methods for calculating commercial vehicle wait times 

and identified six recommendations, three of which could, in part, help 

address the limitations discussed above. The recommendations directed 

CBP to, among other things (1) use closed-circuit television cameras to 

measure wait time in real time; (2) provide a standardized measurement 

and validation tool, such as a useful and well-documented benchmarking 

system; and (3) continue to monitor and evaluate applications of 

transportation technologies at the border that allow for better 
 

Page 20 GAO-13-603 U.S.-Mexico Border

measurement and reporting of wait times.32

CBP guidance identifies the importance of reliable wait time 

measurement to facilitate the movement of people and goods across the 

border. Further, Standards for Internal Control in the Federal Government

calls for agencies to establish controls, such as those provided through 

policies and procedures, to ensure the accuracy and timeliness of data. 

Control activities that ensure the prompt, complete, and accurate 

recording of data help to maintain their relevance and value to 

CBP headquarters officials 

from three offices—the office that sponsored the report (Land Border 

Integration), the office in charge of cargo operations (Cargo Conveyance 

and Security), and the office that maintains the agency’s wait time data 

(Planning Program Analysis and Evaluation)—were all unclear as to the 

steps, if any, that had been taken to address the first two 

recommendations and which office was responsible for implementing 

them. With regard to the first recommendation, an official we met with in 

Cargo Conveyance and Security said that some crossings had access to 

cameras that helped them view the end of the line, but this official did not 

know how many crossings on the southern border had cameras for this 

purpose and further stated that there were no plans to expand camera 

availability to improve wait time data reliability. With regard to the second 

recommendation, this Cargo Conveyance and Security official stated that 

CBP had not taken steps to develop a standardized wait time 

measurement and validation tool and had no plans to do so. However, 

CBP officials with Land Border Integration and Planning, Program 

Analysis, and Evaluation stated that CBP had implemented the third 

recommendation by continuing to monitor and evaluate applications of 

transportation technologies in its work with FHWA to pilot projects for 

automating data collection.

 

32In making the first recommendation, the report notes that for various geographical 

reasons it is often difficult for cameras positioned on the U.S. side to provide adequate 

views of queues. Therefore, the report recommends that, where possible, CBP work to 

leverage use of cameras in use by stakeholders on or near land border crossings. With 

regard to the second recommendation to provide a standardized measurement and 

validation tool, the report further specifies that such a tool could include a spreadsheet 

with formulas taking into account the local benchmarks used to identify the end of the line, 

the number of inbound lanes, the average processing time, and the number of open 

primary booths, among other variables, in order to determine wait time. The report also 

included three other recommendations including the following: (1) provide administrative 

support to ensure accurate wait time reporting and reduce CBP officer workload, (2) 

increase the timeliness and frequency of wait time updates on CBP’s website to a 

minimum of 30 minutes or less, and (3) provide video feeds to the CBP website.
 

Page 21 GAO-13-603 U.S.-Mexico Border

management in controlling operations and making decisions. In the near 

term, identifying and carrying out steps that can be taken to help CBP 

officials overcome challenges to consistent implementation of existing 

wait time estimation methodologies—such as implementing past CBP 

recommendations to expand the use of cameras to see the ends of 

queues and providing standardized wait time measurement and validation 

tools—could improve the reliability and usefulness of CBP’s current wait 

time data.

In February 2008, FHWA, in coordination with state DOTs and CBP, 

initiated pilot projects to develop automated wait time data collection 

methods at select southwest border crossings. Automation of wait time 

data collection relies on Radio-Frequency Identification readers to read 

the unique signals from passing vehicles at several points along the 

border-crossing route. These data points are then automatically matched 

and analyzed to estimate the current wait time at that crossing. As of 

March 2013, FHWA and state DOTs in Arizona, California, and Texas 

had eight pilot projects under way or completed to automate and 

standardize calculation of both wait time and total crossing time at eight 

crossings on the southwest border, including projects at each of the six 

crossings we visited.33 Wait time data resulting from some of these pilots 

is currently shared on a publicly available website with updates every 10 

minutes.34 These eight projects were initiated on a crossing-by-crossing 

basis and are in various stages of implementation—one completed and 

seven ongoing. Two additional projects are planned so senior FHWA 

officials expect automated wait time data to be available at 10 crossings 

by 2015 at which point current federal funding commitments for these 

projects end.35

CBP headquarters and field officials, as well as FHWA and a Texas 

Department of Transportation official, cited a range of potential benefits

 

33The completed pilot project was at Otay Mesa (Otay Mesa, California) and the ongoing 

projects are at Pharr (Pharr, Texas), Bridge of the Americas (El Paso, Texas), Ysleta (El 

Paso, Texas), World Trade Bridge (Laredo, Texas), Columbia Solidarity Bridge (Laredo, 

Texas), Veterans (Brownsville, Texas), and Mariposa (Nogales, Arizona). 

34The website is http://bcis.tamu.edu.

35Automation projects are planned at Santa Teresa (Santa Teresa, New Mexico) and 

Camino Real International Bridge (Eagle Pass, Texas).

CBP Has Not Assessed the 

Feasibility of New 

Automation Options
 

Page 22 GAO-13-603 U.S.-Mexico Border

that could result from automating border wait time measurement. CBP’s 

fiscal year 2008 WHTI report found that the long-term solution to 

standardize wait time measurement is to take advantage of automation 

technology. CBP headquarters, field office, and port officials told us that 

automation would reduce the burden on staff of manually collecting wait 

time data and increase staff availability for security efforts and other 

tasks. OFO headquarters officials also stated that automation would 

increase the accuracy, reliability, and timeliness of the wait time data that 

are collected and disseminated. Moreover, they stated that automated 

data would come from a more independent source, and thus the data 

may be perceived by industry organizations as more accurate than CBP’s 

current data. This would reduce the burden on CBP officials to respond to 

queries about their wait time data, according to CBP officials. OFO 

headquarters officials and senior CBP officials at the six crossings we 

visited reported that accurate wait time data would facilitate CBP 

management decisions such as staffing needs, infrastructure investment, 

performance management (such as evaluating efforts to mitigate wait 

times), and operations planning at land ports of entry. In addition, CBP 

officials at four of the six crossings reported automation could provide 

data on CBP’s definition of wait time as well as total border-crossing time. 

This could provide CBP with more holistic information on the complete 

border-crossing experience, thereby improving CBP’s ability to identify 

and address bottlenecks and providing industry stakeholders with more 

useful data to inform their business processes.

At the same time, CBP officials reported limitations of the current 

automation pilot projects. In 2011, CBP commissioned a study to review 

the quality of the data resulting from the Texas-based pilot projects and 

found the automated wait time data were not yet sufficiently accurate for 

CBP’s purposes. In response to these findings, CBP worked with pilot 

project officials to modify the algorithm used to calculate the wait times, 

with the intention to improve the accuracy of the data. Another concern 

raised by CBP officials is that none of the pilots are yet able to 

consistently differentiate between wait times for FAST and non-FAST 

traffic. Not capturing separate wait time data for FAST and non-FAST 

traffic could limit the usefulness for key industry stakeholders and limit 

CBP’s ability to measure whether FAST participants are experiencing 

reduced wait times, as set forth in FAST program goals. FHWA officials 

reported that the technology solutions used in the current pilot projects 

are flexible enough to enable adding more readers to differentiate results 

for FAST and non-FAST traffic, but none of the current pilot projects are 

gathering data for this purpose, and FHWA officials reported that they 

have no plans to conduct additional research on solutions that 
 

Page 23 GAO-13-603 U.S.-Mexico Border

differentiate between FAST and non-FAST traffic. In addition, CBP 

officials note that there are no pilot programs to automate wait time data 

collection at 34 of the 42 southwest border crossings where CBP 

currently reports hourly wait times.

CBP, as the lead agency in collecting and reporting wait time data and 

the sole source of wait time data across the southwest border, does not 

have plans to oversee or manage these automation projects, although 

FHWA and others are anticipating an expanded CBP role once the pilot 

phases conclude. FHWA officials have led the research phase of these 

projects but expect their role to decline as the pilot phases end, and they 

are looking to others to manage these efforts in the longer term. FHWA 

has taken a lead role in the research, testing, and evaluation of wait time

automation technology including fully funding the pilot projects at the 

Bridge of the Americas and Otay Mesa and providing limited financial 

support for others. However, FHWA officials stated that they do not plan 

to fund these projects after the pilot phases end. CBP has coordinated 

with FHWA by, for example, consulting on the algorithms used to project 

wait times, but CBP has not provided funding for the projects on the 

southwest border. CBP officials reported that they do not intend to fund, 

adopt, or otherwise oversee these wait time automation projects once the 

pilot phases supported by FHWA and state DOTs conclude because CBP 

officials stated that they want another entity, such as FHWA or state 

DOTs, to do so. Texas Department of Transportation officials report that 

they are committed to continuing the Texas-based pilot projects in the 

short term, but are looking for another source of funding, possibly CBP or 

others to support the projects in the future. There are no other such 

commitments for the pilots in other states. CBP officials report that they 

are in discussion with FHWA about collaborative approaches to 

continuing these efforts, such as public-private partnerships.

CBP officials stated that the agency has not taken action to improve or 

modify its current methods for collecting and reporting wait time data in 

the short-term because officials believe that automated collection of wait 

time data is the most effective way to obtain reliable, standardized data, 

and the current automation projects are still in development. However, 

CBP has not assessed the feasibility of replacing or supplementing 

current methods of manually calculating wait times with the automated 

methods piloted by DOT or other means. Assessing the feasibility could 

include assessing all of the associated costs and benefits, options for how 

the agency will use and publicly report the results of automated data 

collection, the potential trade-offs associated with moving to this new 

system, and other factors such as those influencing the possible 
 

Page 24 GAO-13-603 U.S.-Mexico Border

expansion of automation efforts to the 34 other locations that currently 

report wait times but have no automation project under way. OFO officials 

stated that CBP has not considered assessing the feasibility of 

automating wait time data collection and does not have estimates of 

potential costs or time frames because the pilot projects are still in 

development and CBP management has not committed to automating 

wait time data collection. However, standards for program management 

call for the feasibility of programs to be assessed early on.36 Given that 

CBP officials have stated that automated data collection is the most 

effective method for obtaining standardized and reliable wait time data, 

conducting an assessment of the feasibility of the methods piloted by 

FHWA or other automation methods, in consultation with FHWA and state 

DOTs, could help CBP determine how to best achieve its goal of 

improving the reliability of its publicly reported wait time data.

 

36Project Management Institute, The Standard for Program Management©, Second 

Edition.

CBP Analyses and 

Officials Identified 

Some Infrastructure 

and Staff Needs, but 

the Methodology 

Used to Allocate Staff 

across Ports of Entry 

Has Not Been 

Documented 
 

Page 25 GAO-13-603 U.S.-Mexico Border

CBP analyses and port officials identified needs for additional 

infrastructure—such as more lanes—at some border crossings, and our 

analysis of CBP data on lane use generally supported agency views on 

the extent to which CBP opens lanes at the six crossings we visited. 

Further, our analysis supports CBP officials’ statements that they 

generally open and close primary inspection lanes in response to 

fluctuations in commercial traffic volume, but some port officials cited 

constraints to opening more lanes during times of peak traffic.

CBP and GSA assessments and officials identified current infrastructure 

limitations affecting commercial vehicle processing at three of the six 

crossings we visited. Specifically, CBP and GSA assessments and CBP 

officials cited infrastructure limitations related to an insufficient number of 

primary lanes at Otay Mesa, insufficient space for secondary inspections 

at Otay Mesa and World Trade Bridge, and poor facility layout as well as 

an insufficient number of exit gates at Bridge of the Americas.37 CBP port 

of entry officials for two of the three remaining crossings we visited stated 

that current infrastructure was sufficient to process commercial traffic at 

Columbia Solidarity Bridge and Ysleta. At the last crossing, Mariposa, 

CBP port officials reported that infrastructure would be sufficient once 

GSA’s ongoing project to replace and expand the port is completed in the 

fall of 2014. Table 1 summarizes the infrastructure needs identified in 

CBP or GSA assessments as well as those identified by CBP port officials 

at the six crossings we visited.

 

37Upon arriving at the border crossing, traffic waiting to enter the United States queues up 

in primary inspection lanes that lead to primary inspection booths where a CBP officer 

reviews documentation on the exporter, importer, and goods being transported. If no 

further inspections are required, the vehicle is allowed to enter the United States. 

Secondary inspections occur when a vehicle is referred by the primary line officer for 

further inspection, including gamma ray scans, paperwork, and physical examinations.

CBP Analyses and Officials 

Indicated Need for 

Additional Infrastructure 

at Some Crossings, and 

Our Analysis of Data on 

Primary Lane Use 

Generally Supported These 

Assessments
 

Page 26 GAO-13-603 U.S.-Mexico Border

Table 1: Infrastructure Needs as Identified in Customs and Border Protection (CBP) and General Services Administration 

Assessments (GSA) and by CBP Officials at the Six Crossings We Visited

Name and 

location of 

border 

crossings

Infrastructure needs identified in CBP or GSA 

assessments and reported actions taken to address 

these needs

Infrastructure needs identified by CBP port 

officials 

Otay Mesa: San 

Diego, CA

GSA assessments conducted in 2008 and 2010 predicted 

that commercial vehicle wait times would increase because 

of deficiencies including inadequate primary lanes and 

space to conduct secondary and nonintrusive inspections.a

These most recent assessments found that eight additional 

primary lanes were needed to meet the demands of 

projected commercial traffic volume at the crossing.

CBP port officials reported there is an insufficient 

number of primary lanes and there is insufficient 

secondary inspection space.

Mariposa: 

Nogales, AZ

CBP’s 2005 Strategic Resource Assessment (SRA) 

identified the need for additional secondary inspection 

space, and a 2009 GSA assessment identified the need for 

additional primary inspection lanes, among other 

deficiencies identified. Four primary lanes were added in 

April 2012. 

CBP port officials told us that once the ongoing 

renovation and expansion project is complete in fall 

2014, Mariposa will have no further infrastructure 

needs for commercial vehicle processing.

Bridge of the 

Americas: El 

Paso, TX

CBP’s 2006 SRA found that the crossing was poorly 

configured and that the configuration and placement of 

primary inspection lanes and exit gates created backups and 

bottlenecks that prevented the effective flow of both regular 

commercial traffic and Free and Secure Trade traffic.b Two 

new exit booths were added in 2012 to partially address 

these issues.c CBP and GSA officials have not conducted an 

assessment to determine the extent of reconfiguration 

needed, stating that they conduct such assessments when 

funds become available to do so.

CBP port officials reported the Bridge of the 

Americas currently has sufficient capacity at its 

primary and secondary inspection facilities, but that 

the crossing’s layout and number of exit gates 

adversely affect the flow of traffic. They also stated 

that the crossing is at maximum capacity and if 

commercial traffic increases, as CBP officials 

expect, the crossing will have an insufficient number 

of primary inspection lanes and insufficient 

infrastructure for secondary inspections.

Ysleta: El Paso, 

TX

CBP’s 2006 SRA identified an inadequate number of 

primary inspection lanes to process commercial traffic during 

peak times and reported that the placement of exit gates 

contributes to congestion within the facility. These 

deficiencies were addressed when GSA completed a 

renovation that included adding two primary inspection lanes 

in October 2008 and reconfiguring the site. 

CBP port officials stated that the port had a sufficient 

number of primary lanes and sufficient infrastructure 

for secondary inspections to process commercial 

traffic.

Columbia 

Solidarity Bridge: 

Laredo, TX

CBP’s 2006 SRA did not identify any infrastructure 

deficiencies that would limit the crossing’s ability to process 

commercial traffic.

CBP port officials stated that the crossing had a 

sufficient primary and secondary capacity to process 

commercial traffic. 

World Trade 

Bridge: Laredo, 

TX

CBP’s 2006 SRA reported a need to expand primary and 

secondary inspection infrastructure. Seven primary 

inspection lanes were added in 2011; CBP and GSA officials 

have not conducted an assessment to determine the extent 

to which secondary facilities need to be expanded. CBP and 

GSA officials stated that they conduct such assessments 

when funds become available to do so.

CBP port officials stated that seven primary lanes 

were added in 2011, but insufficient space to 

conduct secondary and nonintrusive inspections 

results in congestion.

Source: GAO analysis of CBP and GSA documents and CBP officials’ statements.
 

Page 27 GAO-13-603 U.S.-Mexico Border

Notes: Primary inspections are conducted by a CBP officer at a primary inspection booth. Secondary 

inspections occur when a vehicle is referred for further inspection, including gamma ray scans, 

paperwork, and physical examinations.

a

Nonintrusive inspection includes the use of gamma ray technologies to detect contraband in 

commercial trucks.

b

CBP initiated the Free and Secure Trade (FAST) program in 2002 to expedite the travel of known 

low-risk screened shipments across the border. Seventeen out of the 24 land border crossings on the 

southwest border have dedicated FAST lanes to expedite FAST traffic.

c

According to CBP officials, this infrastructure improvement project at the Bridge of the Americas was 

funded out of the Office of Field Operations’ operating budget at a cost of approximately $264,500.

Further, our analysis of CBP data on lane use generally supported CBP

officials’ statements regarding the extent to which CBP officials open 

existing primary inspection lanes at the six crossings we visited. The 

number of primary inspection lanes available and open at each crossing 

was frequently cited by CBP and industry officials as a critical variable 

affecting wait times for commercial vehicles and, further, as evidence of 

whether a crossing’s primary lane infrastructure was sufficient to process 

current traffic volumes. For example, at all the locations we visited, 

industry representatives expressed concern that CBP had an insufficient 

number of primary inspection lanes to process current traffic volumes or 

was not fully utilizing existing lanes.38

• In fiscal year 2012, lane use data for two of the six crossings we 

visited suggest that these crossings—Otay Mesa and Mariposa—

were at times operating at or near full capacity, as reported by agency 

officials. In fiscal year 2012, Otay Mesa opened an hourly average of 

82 to 89 percent of its primary inspection lanes per month. At 

Mariposa, our analysis of lane use data for the first half of fiscal year 

2012, prior to the addition of four new primary inspection lanes in April 

2012, showed that during months of peak traffic, port officials opened 

To determine the extent to which 

CBP was opening its existing primary inspection lanes, we analyzed CBP 

data on the average hourly percentage of primary inspection lanes open 

per month during operating hours over the last 5 fiscal years (October 

2007-September 2012). This analysis showed the following:

 

38For example, industry representatives and Mexican officials in Laredo, Texas told us 

that seven new primary inspection lanes were added at the World Trade Bridge in 2011 to 

reduce wait times for commercial vehicles, but the new lanes were often not opened.
 

Page 28 GAO-13-603 U.S.-Mexico Border

an hourly average of between 80 and 84 percent of Mariposa’s 

primary lanes per month.39

• The average hourly percentage of primary lanes open per month at 

the remaining four crossings we visited—Bridge of the Americas, 

Ysleta, Columbia Solidarity Bridge, and World Trade Bridge—were all 

lower.40

Our analysis also supports CBP officials’ statements that they generally 

open and close primary inspection lanes in response to fluctuations in 

commercial traffic volume—a practice CBP calls active lane 

management; however, some port officials cited constraints in opening 

more lanes during times of peak traffic. Port officials at all six crossings 

we visited reported that they consider commercial traffic volume, among 

other factors, when deciding to open and close primary inspection lanes. 

We compared trends in CBP’s data on lane use and commercial traffic 

volume and found that the two were generally consistent at five of the six 

crossings we visited, supporting CBP officers’ statements that they 

generally open more lanes when traffic volume rises and close lanes 

when traffic decreases.

This generally supported CBP officials’ statements that they 

have the capacity to open more primary inspection lanes at these 

crossings. 

41

 

39Mariposa is a major crossing for agricultural products and therefore has high seasonal 

variability in commercial traffic volume. Prior to the addition of new primary inspection 

lanes, the peak months in fiscal year 2012 were January, February, March, and April, 

when average monthly commercial vehicle traffic volume exceeded that of nonpeak 

months by approximately 20 percent. The monthly average percentage of lanes opened 

on average per hour for the nonpeak months in fiscal year 2012, prior to the opening of 

new lanes on April, 30 2012—October 2011 to December 2011—ranged from 61 to 79 

percent. Following the addition of new lanes in April 2012, this rate dropped to a monthly 

average of between 41 and 48 percent. However, it is important to note that this period 

(May-September 2012) is generally a period of low traffic volume, which, together with the 

availability of four new lanes, may account for this decrease.

However, CBP officials at one of these five 

crossings—World Trade Bridge—explained that other factors kept them 

from opening all primary inspection lanes during periods of high traffic. 

Specifically, these officials said that bottlenecks would form if all primary 

40In fiscal year 2012, the average monthly percentage of primary lanes open on average 

per hour at these crossings was 39-79 percent at Bridge of the Americas, 27-48 percent at 

Ysleta, 36-38 percent at Columbia Solidarity Bridge, and 48-58 percent at World Trade 

Bridge. 

41Our analysis does not indicate whether CBP is maximizing use of its lanes, but rather 

allows us to observe how closely the average hourly traffic volume per month corresponds 

to the average number of hourly lanes open per month.
 

Page 29 GAO-13-603 U.S.-Mexico Border

lanes were opened, causing congestion throughout the facility because of 

limited space at secondary inspection.42 The one crossing where the lane 

use and commercial traffic volume did not appear to track as closely was 

Columbia Solidarity Bridge. However, CBP officials at Columbia Solidarity 

Bridge explained that traffic volumes and wait times there were so low 

that they generally did not need to open or close lanes in response. 

Figure 3, an interactive graphic, summarizes our analysis and includes 

additional information for each of the six crossings we selected.

 

42In addition, CBP officials at the World Trade Bridge said they previously had insufficient 

staff to open all primary lanes during the midday rush but they have since added 20 new 

staff, which allowed them to add a new shift in January 2013 to minimize the effect of 

officer lunch breaks on their ability to open primary lanes. Because this initiative is 

relatively new, it is too early to assess its impact on lane utilization.
Page 30 GAO-- 860H[LFR%RUGHU

Source: GAO analysis of CBP data; CBP (photos).

Texas

Arizona New Mexico

Oklahoma

Progreso Los Indios

Pharr

Rio Grande City

Roma

World Trade Bridge

Presidio

Columbus

Mariposa Douglas

Naco Sasabe

Lukeville

Tecate Calexico-East

Santa Teresa

Del Rio

Eagle Pass Bridge II

California Nevada

San Luis II

Los Tomates

Border crossing with commercial vehicle inspection lanes

Interstate highway

Legend

Bridge of the Americas

Otay Mesa 

Ysleta

Columbia Solidarity Bridge

Interactive graphic Figure 3: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per 

Month at Selected Southwest Border Crossings, Fiscal Years 2008-2012

Click on the highlighted border crossings for more information. Click on the X to close. For a printer friendly version please see appendix V.
 

Page 31 GAO-13-603 U.S.-Mexico Border

CBP officials at headquarters and in the field cited various ways they are 

working to address infrastructure limitations given challenges caused by 

budgetary and geographic constraints, among others. In regard to 

budgetary constraints, CBP and GSA officials stated that GSA has not 

received funding to conduct additional expansion projects in the last 2 

fiscal years, and as a result, they have not been able to execute new 

projects to address infrastructure needs at land ports of entry on the 

southwest border. GSA officials reported that the agency has used 

alternative funding sources to pay for prioritized infrastructure projects.43

For example, GSA and CBP officials reported using funds from the city of 

Laredo to support the expansion of primary inspection lanes at the World 

Trade Bridge crossing in 2011.44 In regard to geographic constraints, port 

officials at the Bridge of the Americas stated that the urban area around 

that crossing limits opportunities to expand the crossing’s footprint. 

Officials with the city of El Paso told us that they are promoting a plan to 

divert all commercial traffic to the nearby Ysleta crossing because it has 

greater capacity to process commercial traffic and a larger footprint that 

can accommodate future expansion. CBP field office and port officials 

stated that they support this plan. In another example, CBP officials at 

headquarters and in the field reported participating in binational working 

groups in an effort to address the infrastructure limitations of ports of 

entry along the southwest border. For example, senior CBP officials 

reported participating in the U.S.-Mexico Joint Working Committee to 

develop regional master plans to better ensure the development of a wellcoordinated land transportation and infrastructure planning process along 

the border.45

 

43According to GSA and CBP officials, GSA has statutory authority under 40 U.S.C. § 

3175 to accept gifts from the private sector to fund expenses such as infrastructure 

renovation, but CBP does not have this authority. These officials also reported that GSA 

has accepted private sector gifts to fund the construction or renovation of land ports of 

entry. 

44This primary lane expansion project was primarily funded by the city of Laredo. The city 

provided $7.5 million, GSA provided $1.3 million, and CBP provided $1.6 million.

45Regional border master plans are comprehensive long-range plans to identify and 

prioritize port of entry infrastructure needs and projects within a defined area. These plans 

represent binational stakeholder efforts to (1) prioritize port of entry and related 

transportation projects leading to ports of entry, (2) inform decision making, (3) allocate 

limited funding sources, and (4) ensure continued dialogue and coordination on future 

infrastructure needs and projects. In the near future, six regional border master plans will 

have been completed in California (1), Arizona (1), New Mexico (1), and Texas (3).
 

Page 32 GAO-13-603 U.S.-Mexico Border

CBP’s workload staffing model—CBP’s primary tool for determining the 

number of CBP officers needed at the nation’s air, land, and sea ports—

found that additional CBP officers are needed to meet CBP’s mission 

requirements. CBP submitted the most recent version of its workload 

staffing model to Congress in response to language in the conference 

and committee reports for the fiscal year 2012 DHS appropriations.46

According to CBP documents submitted to Congress, the workload 

staffing model found that 3,811 additional CBP officers are needed to 

meet CBP’s mission requirements in fiscal year 2014.47

In addition, CBP field and port officials at three of the six crossings we 

visited reported having insufficient staff to process commercial traffic. 

Specifically, CBP field office and port officials reported insufficient staff at 

the World Trade Bridge, Columbia Solidarity Bridge, and Mariposa 

crossings and noted that insufficient staff at these crossings contributed 

to commercial vehicle wait times and reduced their ability to conduct 

secondary inspections, among other effects.48

 

46H.R. Rep. No. 112-331, at 958 (2011) (Conf. Rep.); H.R. Rep. No. 112-91, at 27-28 

(2011); S. Rep. No. 112-74, at 31 (2011) and Department of Homeland Security, U.S. 

Customs and Border Protection, Resource Optimization at Ports of Entry: Fiscal Year 

2012 Report to Congress (Washington, D.C.: April 10, 2013).

Officials at the remaining 

three crossings—Otay Mesa, Bridge of the Americas, and Ysleta—

reported having a sufficient number of staff to process commercial traffic. 

However, senior OFO headquarters officials reported that all southwest 

47 We did not evaluate CBP’s workload staffing model as part of this review; however, we 

did review CBP documentation of the model. CBP officials and documentation indicated 

that the workload staffing model’s purpose is to inform CBP budget decisions, such as the 

development of CBP budget requests, as well as its staffing allocation process. In 

addition, CBP documentation also indicated that the model’s methodology assesses 

staffing needs based on workload data, processing times, and complexity. To arrive at the 

number of full-time-equivalent officers needed to complete the work, the model assumes a 

baseline number of hours per year are available for a CBP officer to focus on core mission 

work. The model then calculates the volume of core mission work using transactional data 

for each business process that CBP officers carry out—e.g., number of truck primary 

exams, number of truck container nonintrusive inspection exams, and so forth. CBP then 

uses data on the level of effort in minutes or hours expended each time an officer 

performs these activities to calculate the volume per hour, per inspection booth, per 

officer, and the equivalent officer hours to accomplish the mission.

48More specifically, CBP officials at these crossings told us that because of staffing 

shortages, they have had to reassign CBP officers from secondary inspection and other 

activities such as K-9 patrols to open additional primary lanes during periods of high traffic 

volume.

CBP Cites Need for 

Additional CBP Officers to 

Process Commercial 

Traffic at Some Crossings 

but Documentation Could 

Increase Transparency of 

Staff Allocations across 

Locations 
 

Page 33 GAO-13-603 U.S.-Mexico Border

border land ports of entry require additional staff to perform at optimal 

levels.

CBP headquarters and field office officials cited efforts to mitigate the 

effect of reported staffing shortages on ports’ ability to process 

commercial vehicle traffic. CBP officials reported that these staffing 

shortages, caused in part by budget constraints and the time needed to 

train and assign new CBP officers, challenged their ability to increase the 

numbers of officers at the ports of entry. Specifically, CBP officials 

reported that since fiscal year 2009, CBP has not received sufficient 

funding to hire the number of CBP officers that it requires at land ports of 

entry. In response to budgetary constraints, CBP headquarters officials 

reported working to identify alternative funding strategies as well as 

reviewing user fees to ensure they effectively support operations. For 

example, DHS’s fiscal year 2014 congressional budget request included a 

proposed increase for 1,877 fee-funded full-time-equivalent positions in 

addition to a funding increase of approximately $210 million for 1,600 

additional CBP officers. In response to staffing shortages related to the 

length of time it takes for new CBP officers to complete required training 

and to be available for duty at their assigned ports of entry, CBP 

headquarters officials reported considering the extent that new CBP 

officers have completed their training and are available for duty when 

allocating staff. They further reported actively working to adjust staff 

allocations across locations to better ensure that staffing levels are 

matched to areas of greatest need. For example, a senior OFO official 

reported prioritizing allocations to field offices with the highest 

discrepancy between current staffing levels and workload staffing model 

results when developing fiscal year 2012 annual staffing allocation. 

Finally, port officials at all six crossings we visited reported using overtime 

to mitigate the effect of any staffing shortages on ports’ capacity to 

process commercial traffic. For example, port officials in El Paso said that 

using overtime pay was an effective and efficient solution to provide 

increased coverage to process commercial traffic during peak times on 

weekdays and on weekends.49

 

49Officials with the Port of El Paso, for example, stated that Mexican and U.S. business 

practices generally result in peak times for commercial traffic that require increased 

staffing for only 2 hours or so in the morning and afternoon, but union requirements state 

that CBP officers must work in uninterrupted 8-hour shifts. Senior CBP officials also 

reported that the use of overtime allows coverage of peak times without hiring additional 

staff that are not needed to cover a full shift.

However, officials at the Otay Mesa port of 
 

Page 34 GAO-13-603 U.S.-Mexico Border

entry noted that the availability of overtime funds has decreased because 

of budget constraints in recent years.50

In fiscal year 2013, CBP revised its process to allocate available CBP 

officers to its field offices, ports of entry and border crossings. However, 

CBP has not yet documented this process or its methodology, including 

the factors and underlying rationale considered in making staff allocation 

decisions. A senior official in CBP’s Human Capital Division reported that 

CBP’s most recent staff allocation process consisted of the following six 

steps: (1) OFO’s Human Capital Division obtained the workload staffing 

model’s findings to determine the number of officers ideally needed to 

meet the expected workload; (2) Human Capital Division staff conducted 

a “gap analysis” by comparing the model’s findings to current staff levels 

to identify the locations with the greatest gap between current and the 

staff levels identified by the workload staffing model; (3) Human Capital 

Division staff drafted a proposed staff allocation that realigned staff to 

those field offices with the greatest gap; (4) OFO leadership made 

adjustments to the proposal based on institutional priorities including 

mission, priorities, and threats before approving the allocation; (5) on 

receiving approval from leadership, OFO staff communicated the 

authorized staffing levels to each field office; and (6) the field offices then 

allocated their authorized staff to the individual ports of entry under their 

purview. However, this official explained that this process is not 

documented and there is no guidance clearly defining this methodology, 

the factors considered, or the rationale for making staff allocation 

decisions.

OFO Human Capital officials acknowledged the need to document this 

process and stated that they had not yet done so because, historically, 

such decisions were made informally and the current, more formalized 

process is still evolving. In addition, these officials noted that the last 

fiscal year was the first time OFO used the process described above and 

they planned to make further changes to the process within the next 2 

fiscal years.

 

50CBP’s Fiscal Year 2012 Resource Optimization at Ports of Entry report states that 

OFO’s overtime budget has decreased by 8.2 percent from fiscal year 2008 through fiscal 

year 2013, thereby lessening the agency’s ability to use overtime as a means of 

leveraging existing resources.
 

Page 35 GAO-13-603 U.S.-Mexico Border

Best practices for strategic workforce planning identified by GAO 

emphasize the importance of ensuring that the methodology underlying 

staffing decisions is well documented.51 Standards for Internal Control in 

the Federal Government also calls for clear documentation of policies and 

procedures that are readily available for examination.52 These standards 

state that such control activities are an integral part of an entity’s 

accountability for stewardship of government resources and achieving 

effective results. Without documented policies and procedures including 

its rationale and factors considered in allocating staff, OFO’s staff 

allocation process lacks transparency and is therefore difficult for CBP 

officials or others to review and validate. As a result, CBP and its 

stakeholders do not have reasonable assurance that its staffing 

processes most effectively and efficiently allocate scarce resources to 

fulfill mission needs across ports.

In fiscal year 2013, CBP identified 28 performance measures to assess 

and report on progress toward CBP’s security and trade facilitation 

goals.53

 

51See 

Nine measures were selected by DHS as Government 

Performance and Results Act (GPRA) measures (these are also called 

strategic measures within the department); 15 management measures 

are used to inform agency decisions on program priorities and resource 

allocation, and to monitor progress and performance; and 4 operational 

measures are maintained by OFO to capture former GPRA measures that 

GAO-02-373SP. 

52See GAO/AIMD-00-21.3.1.

53As mentioned previously, the agency’s trade facilitation goals are articulated in DHS’s 

February 2010 Quadrennial Homeland Security Review Report, which outlined a strategic 

framework for homeland security. DHS’s two goals related to trade facilitation are (1) 

prevent the illegal flow of people and goods across U.S. air, land, and sea borders while 

expediting the safe flow of lawful travel and commerce, and (2) ensure security and 

resilience of global movement systems. See DHS, Quadrennial Homeland Security 

Review Report: A Strategic Framework for a Secure Homeland. 

CBP Performance 

Measures Do Not 

Reflect Progress in 

Achieving Trade 

Facilitation Goals
 

Page 36 GAO-13-603 U.S.-Mexico Border

OFO continues to use internally.54

Two of these 28 performance measures address the level of participation 

in CBP’s trade facilitation programs but none gauge the impact of CBP’s 

trade facilitation efforts. Of the 28 measures, 26 are focused on security, 

enforcement, and compliance with trade laws, and 2 are focused on the 

agency’s trade facilitation goals. These 2 measures include (1) the 

percent of cargo by value imported to the United States by participants in 

CBP trade partnership programs, and (2) the percent increase in travelers 

to the United States enrolled in a Trusted Traveler program.

(See appendix IV for a list of CBP’s 

fiscal year 2013 performance measures.)

55 These 2 

measures can serve as indicators of the level of participation in CBP 

trade facilitation programs, such as FAST, and thus are important for CBP 

to track, but they do not provide information on whether these programs 

are facilitating trade because they do not measure desired outcomes for 

the programs.56 OMB defines outcome as an event or condition that is of 

direct importance to the intended beneficiaries or the public, such as 

facilitated trade.57

 

54Pub. L. No. 103-62, 107 Stat. 285 (1993). GPRA seeks to improve the management of 

federal programs, as well as their effectiveness and efficiency, by establishing a system 

under which agencies set goals for program performance and measure their results. 

Specifically, GPRA requires executive agencies to prepare multiyear strategic plans, 

annual performance plans, and annual performance reports. The GPRA Modernization 

Act of 2010, Pub. L. No. 111-352, 124 Stat. 3866 (2011), amended GPRA to establish a 

framework aimed at taking a more crosscutting and integrated approach to focusing on 

results and improving government performance. Under this framework, organizational 

components of agencies, such as CBP, are not treated separately; rather, agencies are to 

work with their components to identify priorities, goals, and performance indicators relative 

to the mission and strategic objectives of the agency. See OMB Circular No. A-11, Section 

200.1 (2012). In fiscal year 2013, DHS has designated 84 GPRA performance 

measures—9 of which focus on CBP efforts.

DHS’s Quadrennial Homeland Security Review Report 

55The percent of cargo by value imported to the United States by participants in CBP trade 

partnership programs is a GPRA or strategic measure, and the percent increase in 

travelers to the United States enrolled in a Trusted Traveler program is a CBP operational 

measure. CBP’s Trusted Traveler programs provide expedited travel for preapproved, lowrisk travelers through dedicated lanes and kiosks. FAST is one of several such programs.

56According to CBP, the intended benefits to participants in the FAST trade partnership 

program include (1) access to dedicated lanes for greater speed and efficiency in 

processing transborder shipments; (2) reduced number of inspections resulting in reduced 

delays at the border; (3) priority, front-of-the-line processing for CBP inspections; and (4) 

enhanced supply chain security while promoting the economic prosperity of the United 

States, Canada, and Mexico.

57This definition of outcome comes from OMB Circular No. A-11, Preparation, Submission, 

and Execution of the Budget (Washington, D.C.: June 26, 2008).
 

Page 37 GAO-13-603 U.S.-Mexico Border

stated that DHS would improve measurement of desired mission 

outcomes and the contribution of programs, activities, and resources to 

them. OFO and OA officials stated that CBP’s existing performance 

measures imply that trade will be facilitated through increased 

participation in trade partnership programs rather than by directly 

measuring the desired outcomes. More specifically, OFO and OA officials 

stated that the measure percent of cargo by value imported to the United 

States by participants in CBP trade partnership programs implies that 

trade will be facilitated through participation in the programs, rather than 

directly measuring the desired outcomes of shorter wait times, for 

example. Similarly, OFO and OA officials told us that the measure 

percent increase in travelers to the United States enrolled in a Trusted 

Traveler program is not intended to capture the benefits to the program 

participants or trade facilitation, but, rather, is primarily an internal 

program measure that captures progress toward CBP’s goal of growing 

enrollment in Trusted Traveler programs, including FAST.

DHS and CBP officials stated that they have not developed more 

performance measures for trade facilitation primarily because key 

stakeholders, including DHS leadership and Congress, have not pushed 

for this, and trade facilitation measures are difficult to develop. DHS and 

CBP officials reported that they have more performance measures 

focused on security and enforcement because these have been more of a 

focus for stakeholders than trade facilitation. In addition, CBP officials 

report that they have not created outcome-oriented measures for trade 

facilitation because the results of their trade facilitation efforts are difficult 

to capture in one or two measures. OFO and OA officials told us that it 

can be hard to articulate trade facilitation to external stakeholders 

because trade facilitation means different things to different stakeholders, 

each with its own interests. However, these same concerns could apply to 

outcome-oriented measures for CBP’s security and enforcement efforts, 

and CBP has developed an outcome-oriented measure in that area—the 

land border interdiction rate for major violations. OFO and OA officials 

told us that this measure is the single best outcome measure for security, 

though they note that it is limited to passenger vehicles.58

 

58OFO and OA officials explained that there is no such measure for commercial vehicles 

because the commercial environment is much more complex with more layers of review 

and the threshold that triggers an examination is much lower in the commercial setting.

In addition, 

OMB guidance states that proxy measures that are closely tied to the 

desired outcome can be used to indirectly measure program outcomes 
 

Page 38 GAO-13-603 U.S.-Mexico Border

when programs are difficult to measure because data are not available.59

In the absence of outcome-oriented or proxy measures, CBP’s ability to 

identify and publicly report the impact of the agency’s trade facilitation 

programs is limited. OFO and OA officials reported that as a result of not 

having more outcome-oriented measures for trade facilitation, the agency 

is less prepared to identify and report the positive impact of its trade 

facilitation efforts to the public, and industry representatives we met with 

noted a lack of information on the impact of CBP’s trade facilitation 

efforts. CBP officials at headquarters and in the field have stated that 

participation in the FAST program has resulted in shorter wait times for 

program participants, but Border Trade Alliance officials and industry 

representatives at two of the roundtables we held raised concerns that 

FAST program participants were not receiving these benefits and were 

unclear about the impact of this particular trade facilitation program.

Potential outcome-oriented measures or proxy measures for trade 

facilitation could include, for example, measures to determine the extent 

to which CBP trusted shipper programs have met their goal, such as the 

percentage of time FAST traffic waits a certain percentage less time than 

regular commercial traffic or the ratio of FAST to non-FAST referrals to 

secondary inspection.

OMB and our guidance recommend the use of outcome-oriented 

performance measures to promote accountability for results. Our 

guidance states that leading organizations promote accountability by 

establishing results-oriented outcome goals and corresponding measures 

by which to gauge progress.60

 

59Office of Management and Budget, Performance Measurement Challenges and 

Strategies, (Washington, D.C.: June 18, 2003).

This guidance further states that 

measuring performance allows organizations to track the progress they 

are making toward their goals and gives managers critical information on 

which to base decisions for improving their progress. More specifically, 

we identified establishing performance goals and measures to better 

translate activities into results as a useful practice to enhance 

performance management and measurement processes, and we have 

previously issued guidance that agencies should identify and use 

60See, for example, GAO, Executive Guide: Effectively Implementing the Government 

Performance and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).
 

Page 39 GAO-13-603 U.S.-Mexico Border

outcome goals wherever possible to reflect the results of their activities.61

In addition, OMB guidance encourages the use of outcome measures 

because they are much more meaningful to the public.62 In the absence 

of meaningful outcome-oriented performance measures, or proxy 

measures, for trade facilitation—such as measures capturing whether 

FAST participants are receiving their intended benefits of quicker 

processing time and fewer inspections—it is difficult for CBP, decision 

makers, and other stakeholders to gauge CBP progress in achieving the 

agency’s stated trade facilitation goals.

Trade between Mexico and the United States is important to the United 

States’ economic health, and the value of goods imported into the U.S. 

from Mexico is on the rise. The length of time commercial vehicles wait in 

line at the border affects this trade activity. However, CBP’s current wait 

time data are unreliable, limiting the extent to which CBP can use wait 

time data across border crossings to inform management decisions about 

infrastructure investment and staffing allocation and industry stakeholders 

can rely on publicly reported data. Taking steps to help CBP port officials 

implement CBP’s existing mechanisms for collecting wait time data, 

consistent with agency guidance, could improve data reliability and 

usefulness for these purposes. Moreover, assessing the feasibility of 

options for automating wait time data consistent with program 

management standards could help CBP consider ways to reduce port 

officials’ current burden in manually collecting the data and provide CBP 

with more reliable and comprehensive data it can use to identify and 

address challenges to trade facilitation.

 

61See GAO, Managing for Results: Strengthening Regulatory Agencies’ Performance 

Management Practices, GAO/GGD-00-10 (Washington, D.C.: Oct. 28, 1999). In this report 

we gathered information from 23 federal and state organizations that we or other credible 

sources identified as using or planning to use a variety of useful practices to enhance 

specific aspects of their performance management and measurement processes. The 

organizations, although they had different missions, sizes, and organizational structures, 

said they consistently recognized that these practices are important in their efforts to 

develop a stronger results orientation. See also The Results Act: An Evaluator’s Guide to 

Assessing Agency Annual Performance Plans, (GAO, GGD.10.1.20 (Washington, D.C.: 

April 1998).

62See OMB Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012). See also OMB, Performance Measurement Challenges 

and Strategies (Washington, D.C.: June 18, 2003).

Conclusions 
 

Page 40 GAO-13-603 U.S.-Mexico Border

CBP’s ability to meet its mission goals—including both security and trade 

facilitation—are affected by its allocation of staff across the southwest 

border, among other things. In the absence of transparency about the 

methodology and process by which CBP allocates staff resources across 

ports of entry, it is difficult for CBP and others to evaluate whether 

existing staff have been allocated to most effectively address CBP’s 

mission needs. Documenting CBP’s staff allocation methodology in 

accordance with best practices for strategic workforce planning could help 

better position CBP to ensure that it is allocating its staff efficiently and 

effectively across ports of entry and border crossings.

In addition, it is difficult for CBP or others to gauge the agency’s progress 

in meeting its trade facilitation goal because CBP does not have 

outcome-oriented measures for its trade facilitation efforts. Developing 

outcome-oriented, or proxy, performance measures that capture the 

impact of CBP’s trade facilitation efforts, consistent with OMB and our 

guidance, could help CBP officials, Congress, and other stakeholders 

better assess the effectiveness of CBP’s trade facilitation programs in 

supporting the agency’s overall mission and goals.

We recommend that the Commissioner of CBP take four actions.

To improve the usefulness of southwest border crossing wait time data for 

informing public and management decisions, the Commissioner of CBP 

should take the following two actions:

• Identify and carry out steps that can be taken to help CBP port 

officials overcome challenges to consistent implementation of existing 

wait time estimation methodologies. Steps for ensuring consistent 

implementation of these methodologies could include, for example, 

implementing the fiscal year 2008 WHTI report recommendations to 

use closed-circuit television cameras to measure wait time in real time 

and provide a standardized measurement and validation tool.

• In consultation with FHWA and state DOTs, assess the feasibility of 

replacing current methods of manually calculating wait times with 

automated methods, which could include assessing all of the 

associated costs and benefits, options for how the agency will use 

and publicly report the results of automated data collection, the 

potential trade-offs associated with moving to this new system, and 

other factors such as those influencing the possible expansion of 

Recommendations for 

Executive Action
 

Page 41 GAO-13-603 U.S.-Mexico Border

existing automation efforts to the 34 other locations that currently 

report wait times but have no automation projects under way.

To better ensure that CBP’s OFO’s staffing processes are transparent 

and to help ensure CBP can demonstrate that these resource decisions 

have effectively addressed CBP’s mission needs, we recommend that the 

Commissioner of CBP document the methodology and process OFO 

uses to allocate staff to land ports of entry on the southwest border, 

including the rationales and factors considered in making these decisions.

To facilitate transparency and performance accountability for its trade 

facilitation programs and meeting CBP’s goal of balancing its trade and 

security missions, we recommend that the Commissioner of CBP develop 

outcome-oriented performance measures or proxy measures to capture 

the impact of CBP’s trade facilitation efforts, such as measures to 

determine the extent to which CBP trusted shipper programs have met 

their goals.

We provided a draft of this report to DHS, GSA, DOT, the Department of 

Commerce, and the Department of Health and Human Services for their 

review and comment. GSA, DOT, the Department of Commerce, and 

Department of Health and Human Services did not have any comments 

on the draft of the report. DHS provided written comments, which are 

summarized below and reproduced in full in appendix VII. In the written 

comments, DHS concurred with our four recommendations and discussed 

actions to address them. However, the actions DHS identified will not 

address the intent of one of these recommendations. DHS also provided 

technical comments, which we incorporated, as appropriate.

DHS agreed with our first recommendation that CBP identify and carry 

out steps to help CBP port officials overcome challenges to consistent 

implementation of existing wait time estimation methodologies. In written 

comments, DHS officials explained that if funding is available, CBP has a 

goal to automate the estimation and reporting of border wait times. To this 

end, they plan to establish an internal and external stakeholder group and 

identify the best candidate technologies to pilot. These steps will help 

further CBP’s longer-term plans to automate wait time data collection, but 

do not address the intent of our recommendation that CBP take steps to 

help port officials more consistently implement existing manual wait time 

estimation methodologies.

Agency Comments 

and Our Evaluation
 

Page 42 GAO-13-603 U.S.-Mexico Border

DHS agreed with our second recommendation that CBP assess the 

feasibility of replacing current methods of manually calculating wait times 

with automated methods. In commenting on a draft of this report, DHS 

officials noted that CBP has taken some steps to assess options for 

automating wait time data collection at northern and southern land border 

crossings and provided us with supplemental documents that included 

rough cost estimates for piloting, deploying, and maintaining automation 

technology. Based on this information, DHS requested that we consider 

this recommendation closed. While DHS has taken positive initial steps to 

address this recommendation, DHS should complete additional feasibility 

analysis to fully address the intent of our recommendation and better 

position the agency to decide whether and how to automate data 

collection. For example, DHS written comments stated that the feasibility 

of financing, funding, and operating automation technology is “reduced.” 

More detailed and comprehensive cost analysis—such as estimating and 

comparing the costs of different technology solutions and analyzing 

potential funding sources—could help CBP assess the feasibility of wait 

time automation. In addition, DHS officials noted in their written 

comments that CBP has not yet identified the best technologies to pilot. 

Determining the best technology, if any, for use at each border crossing 

could influence the overall feasibility of planned automation across 

southwest border land ports of entry. 

With regard to our third recommendation that CBP document the 

methodology and process OFO uses to allocate staff to land ports of 

entry, DHS agreed and stated that CBP will develop and document a 

standardized process for allocating CBP officers that includes

assumptions, factors, and concerns to guide the decision-making 

process. If implemented effectively, these actions should meet the intent 

of our recommendation.

With regard to our fourth recommendation that CBP develop outcomeoriented performance measures or proxy measures to capture the impact 

of CBP’s trade facilitation efforts, DHS concurred and stated that they 

plan to create a team of subject matter experts from OFO trade-related 

programs to identify at least two outcome measures or acceptable proxy 

measures for trade facilitation. They also noted plans to collaborate with 

private sector entities in order to identify metrics of greatest concern. If 

implemented effectively, these actions should meet the intent of our 

recommendation.

We are sending copies of this report to the Departments of Homeland 

Security, Commerce, Transportation, and Health and Human Services; 
 

Page 43 GAO-13-603 U.S.-Mexico Border 

and the General Services Administration. The report is also available at 

no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-8777, or at GamblerR@gao.gov. Contact points for our 

Office of Congressional Relations and Public Affairs may be found on the 

last page of this report. GAO staff who made major contributions to this 

report are listed in appendix VIII. 

Sincerely yours, 

Rebecca Gambler 

Director 

Homeland Security and Justice Issues 
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce 

Page 44 GAO-13-603 U.S.-Mexico Border

To determine what is known about the economic impact of wait time on 

cross-border commerce, we identified and analyzed relevant studies.1 We 

searched academic, government, and other literature published from 

January 1, 2000, to June 30, 2012, to capture a wide array of recently 

published literature, and asked all relevant interviewees—including 

officials with the Department of Homeland Security’s (DHS) U.S. Customs 

and Border Protection (CBP), Department of Commerce, trade 

associations, private industry, and academics—whether they were aware 

of any such studies.2 We reviewed over 100 identified studies and 

narrowed our focus to the 6 studies that determined an economic impact 

of commercial vehicle wait times on the southwest border. We 

interviewed officials at the organizations that sponsored each of the 

qualifying studies to better understand the methodologies and limitations. 

We then analyzed the studies by comparing their methodologies with best

practices for economic impact studies, including cost-benefit criteria in 

Office of Management and the Budget (OMB) Circular A-94 and 

comparing and contrasting the studies’ scopes, methodologies, and 

findings.3

 

1

Throughout this report, we use Customs and Border Protection’s definition of wait time—

the time it takes for a vehicle to travel from the end of the queue to the primary inspection 

point in the United States.

2

We conducted both subject and key word literature searches utilizing more than 20 

subject-specific bibliographic databases to systematically scan and identify academic, 

government, and other sources. Other sources scanned include gray literature—informally 

published written material—and government sources. We searched all sources for 

scholarly and peer-reviewed material, government reports, trade and industry articles, 

association and think tank publications, and working papers. As with any such literature 

search, there are a number of limitations to consider. This scan is a sample and does not 

attempt to review all published or gray literature on this topic. Attempting to scan all 

published and gray literature would be an immense task, and searching bibliographic 

databases represents a transparent and well-documented proxy for what is being 

expressed across the broader subject community. We recognize that there is a lag time in 

ideas and research findings making their way into the indexing of bibliographic databases 

as well as a growing amount of peer-reviewed material being retracted. 

3

OMB Circular A-94 Revised, Guidelines and Discount Rates for Benefit-Cost Analysis of 

Federal Programs (Washington, D.C.: Oct. 29, 1992).

Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 45 GAO-13-603 U.S.-Mexico Border

An April 2013 CBP-commissioned study found that reduced waits at 

select border crossings would result in benefits to the U.S. economy in 

terms of increased gross domestic product (GDP) and jobs.4 This study, 

conducted by the National Center for Risk and Economic Analysis of 

Terrorism, estimates the benefit of adding one CBP officer to select 

border land and air border crossings—assuming these added staff would 

each open one additional primary inspection lane—in terms of reduced 

waits and resulting benefits to the U.S. economy. The study found, for 

example, that at seven of the biggest southwest border commercial 

vehicle crossings, having one additional staff member open one 

additional primary inspection lane during the 8 most congested hours of 

the day would result in wait time reductions ranging from 1.5 minutes to 

7.2 minutes for commercial vehicle traffic during those hours. The study 

then estimated that over the course of a year, these wait time reductions 

for commercial vehicles at these seven crossings would lead to direct 

economic benefits of $915,000 in GDP (in 2011 dollars) and 9.3 

additional jobs.5

However, we identified three limitations to consider regarding the reported 

economic benefits. First, this study estimated the benefits of this change 

but not the costs. CBP officials state that the study was not intended to be 

a cost-benefit analysis and noted that the types of costs that would have 

CBP officials report that they plan to use the results of 

this study to demonstrate the benefit of adding CBP officers. These 

officials report that CBP has typically demonstrated its benefit in terms of 

number of seizures and arrests, for example, but this study will permit 

CBP to show an officer’s trickledown effect on the U.S. economy.

 

4

National Center for Risk and Economic Analysis of Terrorism Events, The Impact on the 

U.S. Economy of Changes in Wait Times at Port of Entry, April 4, 2013, a report prepared 

for DHS. The National Center for Risk and Economic Analysis of Terrorism Events is a 

university-based center of excellence funded by the Office of University Programs of the 

Science and Technology Directorate of DHS. The Center’s mission is to improve U.S. 

security through research and development of models and tools to evaluate risks, costs, 

and consequences of terrorism and natural and manmade hazards, and to guide 

economically viable investments in homeland security. 

5

For the six commercial vehicle crossings we visited in the course of our study—Bridge of 

the Americas and Ysleta in El Paso, Texas; World Trade Bridge and Columbia Solidarity 

Bridge in Laredo, Texas; Mariposa in Nogales, Arizona; and Otay Mesa near San Diego, 

California—CBP’s study found that having one additional staff member open one 

additional primary inspection lane during the 8 most congested hours of the day would 

result in wait time reductions ranging from 1.5 minutes to 6.3 minutes and would lead to 

direct economic benefits of $645,000 in GDP (in 2011 dollars) and 6.5 additional jobs. The 

estimated number of jobs created does not include the CBP officers added.

CBP Study Estimated the 

Effect of Additional Staff 

at Ports of Entry on Wait 

Times and the U.S. 

Economy 
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 46 GAO-13-603 U.S.-Mexico Border

to be considered in a cost-benefit analysis include staff salaries, 

inspection booth and lane maintenance, and equipment. Second, the 

study assumes that one additional primary processing lane is available to 

be opened during the busiest 8 hours of the day. However, CBP officials 

report that at some crossings they already open all primary inspection 

lanes during peak hours. Therefore, this assumption is unrealistic or 

would require CBP investment in additional primary inspection lanes. 

Third, the study used CBP’s reported wait time data for fiscal year 2012, 

which, as described earlier in this report, we determined are not 

sufficiently reliable for analysis across crossings, among other things.6

Officials who conducted this study told us that they did not test the 

reliability of CBP’s wait time data but found the basic data pattern 

plausible and therefore determined that the data were sufficiently reliable 

for their analysis.

Five other studies, one of which was commissioned by DHS, have 

quantified the effects of commercial vehicle wait times on cross-border 

commerce and also found evidence of lost revenue and jobs. The studies’ 

findings are not comparable because of their differing scopes and 

methodologies, but they estimate direct impacts ranging from $452 million 

in the San Diego area to $1.9 billion across five cities with major border 

crossings. All five studies have limitations that may have led to an 

overstatement of the economic impacts of wait times. In particular, four of 

these studies used economic multipliers to quantify the effect of wait time 

delays on the U.S. economy. As stated in OMB Circular A-94, these 

secondary effects should not be used when measuring social benefits or 

costs. Rather, the reported effects should be limited to direct effects only. 

Therefore, we included only the direct impacts in our summary of these 

studies. The five studies’ findings and limitations are summarized in table 

2. 

 

6

CBP staff at each crossing manually collect and report hourly wait time data into CBP’s 

Border Wait Time Administrative Tool.

Other Commissioned 

Studies Reported That 

Wait Times Directly Affect 

the U.S. Economy, 

Resulting in Lost Revenue 

and Jobs
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 47 GAO-13-603 U.S.-Mexico Border

Table 2: Studies of the Economic Impact of Commercial Vehicle Wait Times on the Southwest Border

Study name

Economic Impacts of 

Wait Times at the San 

Diego-Baja California 

Border, Final Reporta

Improving Economic 

Outcomes by Reducing 

Border Delays: 

Facilitating the Vital 

Flow of Commercial 

Traffic Across the U.S.-

Mexico Borderb

Goods 

Movement 

Border 

Crossing 

Study and 

Analysisc

Economic Benefits 

of Expanding the 

Border-Crossing for 

Commercial 

Vehicles at the 

Mariposa Crossing 

in Nogales, Arizonad

El Paso Regional 

Ports of Entry 

Operations Plane

Date published January 19, 2006 Never officially published, 

but March 2008 version 

released

June 6, 2012 June 2007 June 2011

Commissioned 

by

San Diego Association of 

Governments

California Department of 

Transportation, District 

11

Department of 

Commerce’s International 

Trade Administration

Southern 

California 

Association of 

Governments

U.S. Department of 

Homeland Security, 

Private Sector Office

Texas Department 

of Transportation

Commercial 

vehicle border 

crossings 

included in 

study 

Otay Mesa and Tecate 

crossings at the border of 

San Diego County and 

the Mexican state of Baja 

California 

Crossings at:

• Laredo, Texas (World 

Trade Bridge and 

Columbia Solidarity 

Bridge)

• El Paso, Texas 

(Bridge of the 

Americas and Ysleta)

• San Diego, California 

(Otay Mesa)

• Hidalgo, Texas (Pharr 

Reynosa International 

Bridge)

• Nogales, Arizona 

(Mariposa)

Calexico East in 

Imperial County, 

California

Mariposa Crossing in 

Nogales, Arizona

Bridge of the 

Americas and 

Ysleta in El Paso, 

Texas and Santa 

Teresa in Santa 

Teresa, New 

Mexico
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 48 GAO-13-603 U.S.-Mexico Border

Study name

Economic Impacts of 

Wait Times at the San 

Diego-Baja California 

Border, Final Reporta

Improving Economic 

Outcomes by Reducing 

Border Delays: 

Facilitating the Vital 

Flow of Commercial 

Traffic Across the U.S.-

Mexico Borderb

Goods 

Movement 

Border 

Crossing 

Study and 

Analysisc

Economic Benefits 

of Expanding the 

Border-Crossing for 

Commercial 

Vehicles at the 

Mariposa Crossing 

in Nogales, Arizonad

El Paso Regional 

Ports of Entry 

Operations Plane

Period studied 2005 2008 2011 2003-2006 2010-2035 (period 

forecast)

Wait time data 

used

A sample of Otay Mesa 

wait time data collected 

by Batelle for the 

Department of 

Transportation’s Federal 

Highway Administration 

in July 2001f

Original wait time data 

collected using highresolution cameras.g

CBP’s historical wait time 

data were used to 

annualize and extrapolate 

the observed wait timesh

Total wait time was 

defined as the time 

elapsed from entering the 

line in Mexico leading to 

Mexican inspection 

through exit from U.S. 

inspection facilities, 

including any U.S. stateconducted inspections. 

The authors note that this 

represents an expanded 

definition of wait time. 

Original wait 

time data 

collected using 

high-resolution 

cameras.g

CBP’s historical wait 

time datah

supplemented with 

interviews with local 

businesses and a 

field study of wait 

times and traffic flows

at Mariposa.

CBP wait time 

data for April 24, 

2010, was 

modeled and 

forecast through 

2035.

Findings of 

direct effects

In 2005, delays in freight 

movement resulted in a 

total direct loss of $452 

million in output, $99 

million in labor income 

losses, and 2,117 jobs 

lost.

In 2008, commercial 

vehicle wait times at these 

five crossings resulted in 

$1.9 billion in direct 

economic loss, 4,939 jobs, 

and a labor income loss of 

$322 million.

In 2011, delays 

in both 

northbound and 

southbound 

commercial 

vehicle traffic at 

the Calexico 

East border 

crossing 

resulted in 

economic 

losses of $49 

million and 334 

jobs in Imperial 

County, 

California, and 

losses of $98 

million and 

1,000 jobs in the 

state of 

California.

A 50 percent 

reduction in wait time 

for commercial 

vehicles is expected 

to result in a direct 

increase in output of 

$2.9 million and 

create 25 jobs per 

year.

In 2010 the 

regional economy 

lost $90 million 

and 2,551 jobs. 

Assuming no 

changes in current 

infrastructure or 

operations (nobuild scenario), by 

2035, waits are 

estimated to reach 

11 hours, which 

would contract the 

regional economy 

by $54 billion and 

cause a net loss of 

857,000 jobs.
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 49 GAO-13-603 U.S.-Mexico Border

Study name

Economic Impacts of 

Wait Times at the San 

Diego-Baja California 

Border, Final Reporta

Improving Economic 

Outcomes by Reducing 

Border Delays: 

Facilitating the Vital 

Flow of Commercial 

Traffic Across the U.S.-

Mexico Borderb

Goods 

Movement 

Border 

Crossing 

Study and 

Analysisc

Economic Benefits 

of Expanding the 

Border-Crossing for 

Commercial 

Vehicles at the 

Mariposa Crossing 

in Nogales, Arizonad

El Paso Regional 

Ports of Entry 

Operations Plane

Study 

limitations

Model included multiplier effects which, per the Office of Management 

and Budget’s Circular A-94, should not be included in the cost-benefit 

analysis. Therefore, we included only the direct effects in our summary.

Model calculates the economic impact of the full length of the wait time, 

implying that the alternative is a wait of zero minutes. This alternative is 

an implausible scenario since some wait time and associated economic 

loss will always exist. It is not clear what the optimal level of wait time is, 

but if the optimal wait time were 20 minutes, for example, then 

economic losses should be estimated based on the difference between 

the estimated wait time and 20 minutes rather than on the full wait time.

Model included 

multiplier effects that, 

per the Office of 

Management and 

Budget’s Circular A94, should not be 

included in the costbenefit analysis. 

Therefore, we 

included only the 

direct effects in our 

summary.

For 2010, the 

model calculates 

the economic 

impact of the full 

length of the wait 

time, implying that 

the alternative is a 

wait of zero 

minutes. This 

alternative is an 

implausible 

scenario since 

some wait time 

and associated 

economic loss will 

always exist. It is 

not clear what the 

optimal level of 

wait time is, but if 

the optimal wait 

time were 20 

minutes, for 

example, then 

economic losses 

should be 

estimated based 

on the difference 

between the 

estimated wait 

time and 20 

minutes rather 

than on the full 

wait time. The 

economic impact 

for the period 2011 

through 2035 is 

calculated using 

the 2010 wait time 

as a baseline.

Study uses CBP 

data that we found 

not reliable for the 

purposes of this 

study.h 

Study calibrates 

wait time data 

based on 1 day of 

high traffic volume.
Appendix I: Results of Studies on the 

Economic Impact of Wait Times on CrossBorder Commerce

Page 50 GAO-13-603 U.S.-Mexico Border

Study name

Economic Impacts of 

Wait Times at the San 

Diego-Baja California 

Border, Final Reporta

Improving Economic 

Outcomes by Reducing 

Border Delays: 

Facilitating the Vital 

Flow of Commercial 

Traffic Across the U.S.-

Mexico Borderb

Goods 

Movement 

Border 

Crossing 

Study and 

Analysisc

Economic Benefits 

of Expanding the 

Border-Crossing for 

Commercial 

Vehicles at the 

Mariposa Crossing 

in Nogales, Arizonad

El Paso Regional 

Ports of Entry 

Operations Plane

Forecast 11-hour 

wait in 2035 does 

not take into

account travelers’ 

sensitivity to wait 

time with respect 

to the value or 

purpose of their 

trip. 

Source: GAO analysis of published studies. 

a

HDR/HLB Decision Economics Inc., Economic Impacts of Wait Times at the San Diego-Baja 

California Border, Final Report, a report prepared at the request of the San Diego Association of 

Governments and California Department of Transportation, District 11, January 19, 2006. 

b

Accenture, Improving Economic Outcomes by Reducing Border Delays: Facilitating the Vital Flow of 

Commercial Traffic across the U.S.-Mexico Border (Draft), a study prepared for the Department of 

Commerce’s International Trade, March 2008. Department of Commerce officials told us that the 

study was not given interagency clearance so was not published but, rather, was made public in 

response to a subsequent Freedom of Information Act request.

c

HDR Decision Economics, Goods Movement Border Crossing Study and Analysis (Final Report), a 

report prepared for the Southern California Association of Government, June 6, 2012.

d

RTI International, Economic Benefits of Expanding the Border-Crossing for Commercial Vehicles at 

the Mariposa Crossing in Nogales, Arizona (Final Report), a report prepared for the U.S. Department 

of Homeland Security, Private Sector Office, June 2007.

e

Cambridge Systematics, Inc., El Paso Regional Ports of Entry Operations Plan (Final Report), a 

report prepared for the Texas Department of Transportation, June 2011.

f

Battelle is a nonprofit research and development organization that focuses on science and 

technology research for the national security, health and life sciences, and energy and environmental 

industries. The wait time data it collected for the Department of Transportation’s Federal Highway 

Administration are referenced in Evaluation of Travel Time Methods to Support Mobility Performance 

Monitoring –Otay Mesa, Office of Freight Management and Operations, Federal Highway 

Administration, April 2002.

g

High-resolution cameras were used to record photographs of the trucks’ license plates at various 

points along the crossing route. These photographs were then matched to identify crossing times per 

vehicle.

h

As described previously in this report, we reviewed CBP’s wait time data and determined that the 

data were not reliable for some purposes such as comparison across border crossings.
Appendix II: Objectives, Scope, and 

Methodology

Page 51 GAO-13-603 U.S.-Mexico Border

This report addresses the following questions:

• To what extent are CBP wait time data reliable for public reporting and 

informing CBP decisions on staffing and infrastructure investments?

• To what extent has CBP identified infrastructure and staffing needed 

to process current commercial traffic volume at southwest border 

crossings with high traffic volume?

• To what extent do CBP performance measures address progress 

toward its goal of facilitating trade?

This report also presents information on the results of studies that have 

quantified the economic impact of commercial vehicle wait times on 

cross-border commerce. This information, including the methodology 

used to identify these studies, is presented in appendix I.

To inform our analysis of the first and second objectives, we visited six 

crossings at four land ports of entry: Bridge of the Americas and Ysleta at 

El Paso, Texas; World Trade Bridge and Columbia Solidarity Bridge at 

Laredo, Texas; Mariposa at Nogales, Arizona; and Otay Mesa near San 

Diego, California. We selected these crossings based on their commercial 

traffic volume, and geographic diversity, and to include representation of 

crossings with a mix of recent or ongoing infrastructure modernization 

projects. At each location, we interviewed CBP management, toured the 

facility, and convened a roundtable of local industry representatives and 

local government officials. To obtain a range of perspectives on 

commercial vehicle traffic at southwest border crossings, we met with 

representatives of 21 companies and associations (who were identified to 

us as knowledgeable stakeholders) representing industries that rely on 

cross-border commerce including customs brokers, trucking companies, 

and distributors), as well as bridge directors and representatives of four 

local government entities (the Mayors of El Paso and San Diego, the 

Laredo City Manager, and representatives of the San Diego Association 

of Governments) at all four cities we visited or by teleconference.1

 

1

The San Diego Association of Governments is a public planning, transportation, transit 

construction, and research agency.

Because we focused on four land ports of entry with six commercial 

vehicle crossings, our findings are not generalizable to the entire 

southwest border. However, the ports we visited accounted for, in total, 

Appendix II: Objectives, Scope, and 

Methodology 
Appendix II: Objectives, Scope, and 

Methodology

Page 52 GAO-13-603 U.S.-Mexico Border

approximately 70 percent of the commercial vehicle crossings into the 

United States from Mexico in fiscal years 2008 through July 2012. Over 

the course of our work, we also interviewed officials from agencies 

involved in securing the border and facilitating trade at land ports of entry, 

including officials from CBP’s Office of Administration and Office of Field 

Operations, the General Services Administration (GSA), the Department 

of Transportation’s (DOT) Federal Highway Administration and Federal 

Motor Carrier Safety Administration, the Department of Commerce 

(Commerce), the Department of Health and Human Service’s Food and 

Drug Administration, and the Department of State. We also interviewed 

other stakeholders, including officials from the Mexican Foreign Ministry, 

academics, and representatives of national trade associations, including 

the American Trucking Associations and the Border Trade Alliance, to 

obtain a broader range of perspectives on commercial vehicle traffic at 

southwest border crossings.2

To address the first objective, we reviewed and analyzed CBP’s policies 

and guidance for calculating and reporting wait times to determine the 

source of these data and the agency’s control over these data. We 

interviewed CBP headquarters officials about the wait time data, including 

data quality, data entry protocols, quality assurance procedures, and any 

steps taken to improve the reliability of these data. We also interviewed 

officials at the six crossings we visited about how they collect and report 

wait time data. We reviewed CBP documents evaluating the quality of 

CBP’s wait time data on the southwest border, including a fiscal year 

2008 CBP Commercial Wait Times Analysis Report.

3

 

2

These organizations and officials were identified to us as knowledgeable stakeholders 

who could provide us with a range of perspectives on commercial vehicle traffic at 

southwest border crossings. The American Trucking Associations is a national trade and 

safety organization representing the U.S. trucking industry. The Border Trade Alliance is a 

nonprofit organization that serves as a forum for participants to address key issues 

affecting trade, travel, and security in North America.

We compared 

documentary and testimonial evidence of how wait times are currently 

being calculated by officials at land ports of entry on the southwest border 

3

CBP reported on the reliability of wait time calculations in its Western Hemisphere Travel 

Initiative (WHTI), Commercial Wait Times Analysis Final Report, October 2007 – 

September 2008. The goal of WHTI is to facilitate entry for U.S. citizens and legitimate 

foreign visitors while strengthening U.S. border security. The WHTI Program Office 

sponsored this evaluation of commercial vehicle wait times to validate the current wait 

time reporting systems at individual crossings and to determine if a national standard for 

reporting wait times can be established. 
Appendix II: Objectives, Scope, and 

Methodology

Page 53 GAO-13-603 U.S.-Mexico Border

against CBP policies and guidance to identify any discrepancies. We 

reviewed CBP’s data and reports on wait times for the six crossings for 

fiscal year 2012. In addition, to obtain non-CBP perspectives on CBP’s 

methods for calculating wait times and the quality and usefulness of 

CBP’s wait time data, we interviewed DOT officials, local officials, industry 

groups, and a Mexican official.4 We compared CBP’s policies and 

procedures for collecting and maintaining wait times data with criteria in 

Standards for Internal Control in the Federal Government.

5 According to 

the assessment, the usefulness of the wait time data is limited and the 

reliability of the data is not insufficient for certain purposes, such as for 

comparisons across ports. To determine how CBP officials use the 

agency’s wait time data to inform management decisions, we analyzed 

CBP guidance, policy, and other documents as well as interviewed CBP 

officials from headquarters and the six crossings to determine the extent 

to which wait times are a factor in CBP staff allocation decisions and 

infrastructure investment requests and decisions. To determine the status 

of DOT’s pilot projects to automate wait time data at the southwest 

border, we interviewed officials at DOT’s Federal Highway Administration, 

Texas Department of Transportation, and Texas A&M University and 

reviewed documentary evidence they provided. We compared evidence 

of CBP’s stated plans to automate wait times with criteria on standards for 

program management.6

To address the second objective, we reviewed and analyzed CBP and 

GSA assessments of land port of entry condition and capacity, such as 

CBP’s Strategic Resource Assessments and GSA’s BorderWizardTM

 

 

4

We selected these non-CBP stakeholders to provide us with a range of perspectives on 

commercial vehicle traffic at southwest border crossings. The results of these interviews 

are not generalizable but rather provide context for CBP officials’ perspectives on these 

issues.

5

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). These standards, issued pursuant to the 

requirements of the Federal Managers’ Financial Integrity Act of 1982, Pub. L. No. 97-255, 

96 Stat. 814, provide the overall framework for establishing and maintaining internal 

control in the federal government.

6

Project Management Institute, The Standard for Program Management©, Second 

Edition, (Newton Square, Pennsylvania: 2008).
Appendix II: Objectives, Scope, and 

Methodology

Page 54 GAO-13-603 U.S.-Mexico Border

reports.7 We also interviewed CBP and GSA officials about infrastructure 

needs at land border crossings and how these needs are identified and 

prioritized. We reviewed documentation of CBP’s workload staffing 

model, which is used to determine staff needs at land ports of entry, and 

interviewed CBP officials about the agency’s staff allocation policies and 

processes and compared these with criteria in our previous work on 

human capital management and Standards for Internal Control in the 

Federal Government.

8 In addition, we conducted an analysis of CBP’s 

hourly data on traffic volume and number of primary lanes open at the six 

selected crossings to determine the extent to which CBP has utilized 

primary lanes for commercial vehicle traffic from fiscal years 2008 through 

2012. We selected this 5-year period to provide a sufficiently long time 

period for trend analysis. As our analysis focused on identifying trends in 

routine commercial vehicle traffic by crossing, we included both Free and 

Secure Trade (FAST) and non-FAST traffic volume and lanes, but 

excluded hazardous materials traffic.9

 

7

The strategic resource assessment is a needs assessment process by which CBP 

collects and analyzes information about the infrastructure at each crossing, identifies 

needs, and prioritizes infrastructure improvement projects along the northern and southern 

borders. CBP officials reported conducting these assessments fiscal years 2003 through 

2006. BorderWizardTM analyses serve as a decision-making resource/reference for GSA 

and assist GSA in planning and designing land ports of entry. 

To ensure data reliability, we did 

not include any records on traffic volume or lanes open that fell outside 

CBP’s reported hours of operation. In addition, within the reported hours 

of operation, we included the data in our analysis for any given hour if 

CBP provided records for both traffic volume and lanes open. We 

conducted this analysis for the six crossings we visited; thus our findings 

are not generalizable to the entire southwest border. However, these six 

crossings processed approximately 70 percent of commercial vehicle 

8

For prior work on human capital management see GAO, A Model of Strategic Human 

Capital Management, GAO-02-373SP (Washington, D.C.: March 2002), and 

GAO/AIMD-00-21.3.1. This report describes a human capital model we developed that 

identifies eight critical success factors for managing human capital strategically. In 

developing this model, we built upon GAO’s Human Capital: A Self-Assessment Checklist 

for Agency Leaders (GAO/OCG-00-14G, September 2000). Among other steps, we also 

considered lessons learned from GAO reports on public and private organizations that are 

viewed as leaders in strategic human capital management and managing for results. See 

also GAO, Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1

9

CBP initiated the FAST program in 2002 to expedite the travel of low-risk screened 

shipments across the border. Many land border crossings have dedicated FAST lanes to 

expedite FAST traffic.
Appendix II: Objectives, Scope, and 

Methodology

Page 55 GAO-13-603 U.S.-Mexico Border

traffic coming into the United States from Mexico for fiscal year 2008 

through July 2012. To assess the reliability of these data, we reviewed 

relevant documentation; interviewed knowledgeable agency officials; and 

electronically tested for missing data during hours of operation, outlier 

records outside of hours of operation, and obvious errors (such as data 

records showing traffic being processed when no lanes were reportedly 

open). We also reviewed related internal controls and traced a selection 

of data to source files. We determined that the data were sufficiently 

reliable for the purposes of our report.

In addition, to address the second objective, we asked CBP officials at 

headquarters, field offices, and ports of entry about (1) the sufficiency of 

staffing levels and infrastructure capacity to process the current volume of 

commercial traffic at the six crossings we visited, (2) CBP assessment 

and consideration of any staffing or infrastructure gaps when making 

resource allocation decisions, (3) CBP actions and plans to address any 

of these gaps, and (4) any challenges to effectively responding to any 

gaps that CBP identified. We also discussed CBP processes for 

determining staff needs at land ports of entry and allocating staff to the 

ports of entry. We then compared CBP’s staffing policies and processes 

with criteria in our previous work on human capital management and 

Standards for Internal Control in the Federal Government.

10

To address the third objective, we reviewed documentation of CBP’s 

fiscal year 2013 performance goals, measures, and reports. We then 

assessed CBP’s measures against criteria in OMB Circular No. A-11 and 

useful practices GAO previously identified to enhance performance 

management and measurement processes to determine the extent to 

which CBP’s existing performance measures capture progress toward 

In addition, 

we discussed CBP’s workload staffing model and how it has been used to 

inform staffing processes with CBP officials responsible for the model. In 

addition, we interviewed relevant GSA, state, and local officials, as well 

as nongovernmental stakeholders regarding any coordinated efforts to 

identify, prioritize, and implement infrastructure improvements at land 

ports of entry on the southwest border.

 

10See GAO-02-373SP and GAO/AIMD-00-21.3.1.
Appendix II: Objectives, Scope, and 

Methodology

Page 56 GAO-13-603 U.S.-Mexico Border

goals and incorporate successful practices.11

We also identified studies that quantified the economic impact of 

commercial vehicle wait times on cross-border commerce by searching 

literature and asking relevant interviewees whether they were aware of 

any such studies. We reviewed over 100 identified studies and analyzed 

the six studies that determined an economic impact of commercial vehicle 

wait times on the southwest border. A more detailed description of our 

methodology and the results of these studies are presented in appendix I.

We also interviewed 

relevant DHS and CBP officials about CBP’s current performance 

measures, the adequacy of these measures, their perspectives on the 

balance between the agency’s security and trade facilitation goals, and 

the extent to which CBP uses its wait time data to measure progress.

We conducted this performance audit from July 2012 to July 2013 in 

accordance with 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 objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 

11See OMB Circular No. A-11, Preparation, Submission, and Execution of the Budget

(Washington, D.C.: Aug. 3, 2012). See also GAO, Managing for Results: Strengthening 

Regulatory Agencies’ Performance Management Practices, GAO/GGD-00-10

(Washington, D.C.: Oct. 28, 1999). In this report we gathered information from 23 federal 

and state organizations that we or other credible sources identified as using or planning to 

use a variety of useful practices to enhance specific aspects of their performance 

management and measurement processes. The organizations, although they had different 

missions, sizes, and organizational structures, said they consistently recognized that 

these practices are important in their efforts to develop a stronger results orientation.
Appendix III: U.S. Customs and Border 

Protection’s Capital Investment Planning 

Process

Page 57 GAO-13-603 U.S.-Mexico Border

This appendix describes CBP’s reported process for identifying and 

prioritizing its infrastructure investment needs at land ports of entry on the 

northern and southwestern land borders. 

According to CBP documents, CBP identifies and prioritizes the 

infrastructure needs of land ports of entry through a six-part process that 

culminates in a 5-year-plan.1 The Department of Homeland Security 

Appropriations Act for fiscal year 2009 required beginning in fiscal year 

2010 and every year thereafter, that CBP’s annual budget submission for 

construction include, in consultation with GSA, a detailed 5-year plan for 

all federal land port of entry projects with a yearly update of total 

projected future funding needs.2

1. Strategic Resource Assessments

This process, known as the capital 

investment plan (CIP), includes gathering data through Strategic 

Resource Assessments (SRA), scoring identified needs at each land port 

of entry using data and information gathered from the SRA, conducting a 

sensitivity analysis on the initial ranking of needs, assessing projects’ 

feasibility and risk, using the information gathered from the previous steps 

in the process to develop and issue CBP’s 5-year capital investment plan, 

and assessing the CIP process. Each step is described in further detail 

below.

According to CBP, the first stage in the CIP is to conduct SRAs, which 

are infrastructure needs assessments intended to gather and present 

data to support the prioritization of CBP’s facility projects on a national 

level. The SRA includes internal and external stakeholder input, 

workload and personnel forecasts, space capacity analyses, 

architectural evaluation of port facilities, and recommended options to 

meet current and future space needs.

 

1

Department of Homeland Security, U.S. Customs and Border Protection, Land Port of 

Entry Modernization: Promoting Security, Travel and Trade Fiscal Year 2012 Report to 

Congress, (Washington, D.C.: June 2012).

2

Pub. L. No. 110-329, div. D, 122 Stat. 3652, 3658 (2008). The fiscal year 2010 DHS 

appropriation included the same language. See Pub. L. No. 111-83, 123 Stat. 2142, 2148 

(2009). In fiscal year 2012, the DHS appropriation included similar language but also 

required that the projected future funding needs be delineated by land port of entry. See

Pub. L. No. 112-74, div. D., 125 Stat. 943, 949 (2011). The fiscal year 2011 continuing

resolution and the fiscal year 2013 DHS appropriation did not include this language. See

Pub. L. No. 112-10, 125 Stat. 38, 140; Pub. L. No. 113-6, div. D, 127 Stat. 342, 346.

Appendix III: U.S. Customs and Border 

Protection’s Capital Investment Planning 

Process
Appendix III: U.S. Customs and Border 

Protection’s Capital Investment Planning 

Process

Page 58 GAO-13-603 U.S.-Mexico Border

2. Capital Project Scoring 

Once CBP has completed the SRAs, the agency scores the 

infrastructure needs of each land port of entry by the criticality of its 

need for modernization using the data collected by the SRA. This 

score is calculated by combining the data collected in the SRA with 60 

distinct criteria within the predefined four categories (see table 3), 

adjusted to reflect the relative weight of each category. For example, 

factors CBP considers under the Personnel and Workload Growth 

category include current and projected commercial vehicle traffic 

volume as well as the current peak and projected number of 

inspections personnel over the next 10-year period.

Table 3: Categories of Criteria Customs and Border Protection Uses to Prioritize 

Land Port of Entry Projects

Category Weight (by percent)

Mission and Operations 35 

Security and Life Safety 25 

Space and Site Deficiencies 25 

Personnel and Workload Growth 15 

Source: U.S. Customs and Border Protection.

Table 4 summarizes the priority rank assigned to the SRA-identified 

infrastructure needs at land ports of entry on the southwest border that 

process commercial vehicle traffic. The crossings are listed below in order 

of their ranking relative to CBP’s entire portfolio of land ports of entry on 

northern and southwestern borders, including facilities that process bus, 

commercial, passenger, pedestrian, and rail traffic.

Table 4: Prioritization Rank of Infrastructure Needs at Commercial Southwest 

Border Crossings 

Crossing and location Overall rank

Tornillo: Fabens, Texasa 14

Bridge of the Americas: El Paso, Texasb 15

Roma, Texas 22

Douglas, Arizona 31

Mariposa: Nogales, Arizonaa, b 34

Progreso, Texas 35

San Luis, Arizonac 48

Ysleta: El Paso, Texasb, c 53

Del Rio, Texasc 61
Appendix III: U.S. Customs and Border 

Protection’s Capital Investment Planning 

Process

Page 59 GAO-13-603 U.S.-Mexico Border

Crossing and location Overall rank

Los Tomates: Brownsville, Texas 65

Columbus, New Mexico 66

Otay Mesa, Californiab, c 96

Presidio, Texas 102

World Trade Bridge: Laredo, Texasb, c 106

Naco, Arizona 109

Santa Teresa, New Mexicoa 112

Lukeville, Arizona 116

Sasabe, Arizona 117

Eagle Pass Bridge II: Eagle Pass, Texasd 126

Pharr, Texas 129

Colombia Solidarity Bridge: Laredo, Texasb 132

Los Indios, Texas 134

Starr-Camargo Bridge: Rio Grande City, Texas 144

Tecate, California 150

Calexico East, California 151

Source: GAO analysis of CBP documents.

Notes: Each crossing’s rank is relative to all crossings on both borders regardless of the type of traffic 

processed at the facility. 

This list includes only ports of entry on the southwest border in existence at the time of CBP’s 

completion of the SRA process: December 5, 2005. As a result, crossings built to address needs 

identified in the SRA, such as constructing San Luis II to address needs identified at San Luis, are not 

included on this list. 

a

Crossing where the General Services Administration (GSA) has an ongoing infrastructure project as 

of May 2013.

b

Crossing we selected for site visit.

c

Crossing where GSA completed an infrastructure project(s) in fiscal years 2008-2012.

d

GSA plans to undertake an infrastructure project at Eagle Pass II in fiscal year 2013.

3. Sensitivity Analysis

CBP applies a sensitivity analysis of the initial ranking to determine if 

the results should consider factors unaccounted for through the 

standard SRA process, such as any unique regional conditions; 

bilateral planning and international partner interests; or interests of 

other U.S. federal, state, or local agencies. According to CBP officials, 

recent examples of factors CBP has considered include the 

identification of new manufacturing developments immediately 

adjacent to an existing land port of entry facility that would increase 

the demand for commercial processing capacities, facility damage 

resulting from floods that occurred after the SRA was completed in 

2006, and the development of new land port of entry facility proposals 
Appendix III: U.S. Customs and Border 

Protection’s Capital Investment Planning 

Process

Page 60 GAO-13-603 U.S.-Mexico Border

in the same transportation region as an existing facility. CBP officials 

report that this information helps CBP identify additional drivers, 

constraints, and legislative mandates that may change the critical 

needs ranking.

4. Risk and Feasibility Assessments

In this phase, CBP coordinates with key project stakeholders such as 

GSA to evaluate the feasibility and risk associated with project 

implementation including environmental, cultural, and historic 

preservation requirements as well as land acquisition requirements. 

Additionally, according to senior CBP officials, CBP considers the 

likelihood of obtaining the necessary resources to fund the proposed 

project. 

5. 5-Year Capital Investment Plan

Once CBP has taken the previous steps, it uses the information and 

analyses to develop its capital investment plan, in coordination with 

GSA. CBP and GSA update the capital investment plan annually, 

taking into account any changes in DHS’s mission and strategy, the 

changing conditions at land ports of entry, and any other factors 

discovered in the course of projects already under way. With each 

update, CBP identifies which projects are of highest priority. GSA then 

works with CBP to identify which projects may be considered for nearterm design and construction funding, which require an initial or 

updated feasibility study, or which require further evaluation to 

account for issues such as environmental and local community 

concerns. 

6. Assessment of the CIP Methodology

In response to expected budget constraints and as a general 

revalidation of its existing planning cycle, according to CBP Office of 

Administration officials and CBP documents, CBP is revisiting the 

process it uses to develop the 5-year plan. Although the assessment 

is in development, CBP aims to better incorporate up-front 

stakeholder involvement, place additional emphasis on state and local 

government-driven master planning fed by regional trend analyses, 

adopt a consistent and comprehensive communications approach, 

evaluate alternative funding mechanisms, assess broader 

programmatic needs, and target high-impact and lower-cost 

investments.
Appendix IV: Ongoing, Planned, or Completed 

Land Port of Entry Renovation Projects, Fiscal 

Years 2008 through 2012

Page 61 GAO-13-603 U.S.-Mexico Border

The tables in this appendix summarize infrastructure improvement 

projects that CBP and GSA officials reported were completed from fiscal 

year 2008 through 2012 at southwest border land ports of entry that 

process commercial traffic as well as infrastructure improvement projects 

GSA and CBP reported to be ongoing or in planning or design phases as 

of May 2013.1 GSA’s Federal Buildings Fund included $564 million for 

land port of entry infrastructure improvement projects in fiscal years 2008 

through 2010 and none in fiscal years 2011 and 2012. In addition, the 

American Recovery and Reinvestment Act (ARRA) of 2009 allocated 

$300 million for the GSA-owned land ports of entry that is being used to 

provide design or construction funds to seven new or ongoing capital 

projects.2

Table 5 summarizes the five infrastructure improvement projects GSA 

completed at southwest border land ports of entry that process 

commercial traffic in the period of fiscal years 2008 through 2012. Three 

of these projects were at crossings we visited—World Trade Bridge in 

Laredo, Texas; Ysleta in El Paso, Texas; and Otay Mesa near San Diego, 

California.

CBP officials reported that the completed projects presented in 

table 4 cost a total of approximately $115 million and estimates that 

ongoing and planned projects to renovate these land ports of entry, 

presented in table 5, will cost approximately $370 million.

 

1

We included projects completed or in development over the last 5 fiscal years to provide 

a perspective on the most recent projects completed or under way. We excluded smallscale projects, such as the addition of two exit booths at the Bridge of Americas in El 

Paso, Texas, in 2012, because these projects are primarily funded out of CBP’s Office of 

Field Operation’s operation budget—not GSA’s Federal Building Fund or American 

Reconstruction and Recovery Act.

2

Pub. L. No. 111-5, 123 Stat. 115, 149. Two of the seven GSA-owned land port of entry 

ARRA-funded projects were for crossings that process commercial traffic on the 

southwest border: Mariposa in Arizona, and Santa Teresa in New Mexico. The remainder 

of the funds were for crossings that are located on the northern border or do not process 

commercial traffic. In addition, ARRA also allocated another $420 million to modernize 31 

existing land crossings owned by CBP. See 123 Stat. at 162. However, all but three of 

these projects were for crossings on the northern border, and none of the projects were 

for crossings on the southwest border that process commercial traffic.

Appendix IV: Ongoing, Planned, or 

Completed Land Port of Entry Renovation 

Projects, Fiscal Years 2008 through 2012
Appendix IV: Ongoing, Planned, or Completed 

Land Port of Entry Renovation Projects, Fiscal 

Years 2008 through 2012

Page 62 GAO-13-603 U.S.-Mexico Border

Table 5: Completed Infrastructure Improvement Projects at Southwest Border Land Ports of Entry That Process Commercial 

Vehicle Traffic, Fiscal Years 2008 through 2012

Project title

Infrastructure 

improvement project 

description Location 

Sources (both federal 

and nonfederal) and 

amounts of funding 

provided for the project

Total project 

cost

Date of 

completion

Del Rio

Land Port of Entry 

Modernization 

Project 

This project was a 

complete port replacement 

and expansion. 

Del Rio, Texas GSA Federal Buildings 

Fund–$24 million,

CBP Appropriations–$4.3 

million 

$28.3 million June 2009

San Luis II Land 

Port of Entry 

Construction Project

This project constructed a 

new port, San Luis II. The 

project redirected 

commercial traffic from the 

San Luis I crossing to the 

new San Luis II crossing to 

improve commercial traffic 

flow and processing 

capacity.

San Luis II, 

Arizona 

GSA Federal Buildings 

Fund–$42 million,

CBP Appropriations–$7.6 

million 

$49.6 million October 2010

Laredo III: World 

Trade Bridge Land 

Port of Entry 

Commercial Lane 

Expansion Project

The project added seven 

new commercial primary 

inspection lanes and a 

bypass lane to facilitate 

traffic flow and increase 

commercial processing 

capacity.

Laredo Bridge 

III: World 

Trade Bridge, 

Texas

City of Laredo funding-$7.5 

million,

GSA Repairs & Alterations

Appropriations–$1.3 

million, CBP 

Appropriations–$1.6 million

$10.4 million April 2011

Ysleta Commercial 

Lane Expansion 

Project 

The project added two 

commercial primary 

inspection lanes to 

increase processing 

capacity and reconfigured 

the site to create direct 

access to the Texas 

Department of 

Transportation safety 

inspection facility. 

Ysleta, Texas GSA Federal Buildings 

Fund–$20.2 million,

CBP Appropriations–$3.6 

million 

$23.8 million May 2009

Otay Mesa Land 

Port of Entry 

Commercial Lane 

Realignment 

Projects 

The project improved the 

curvature of the existing 

commercial lanes and 

added Free and Secure 

Trade (FAST) technology 

to booths to facilitate traffic 

flow and increase 

commercial processing 

capacity, improved 

commercial traffic flow, and 

increased processing 

capacity.

Otay Mesa, 

California

California Department of 

Transportation–$2.6 

million,

CBP Appropriations–$0.5 

million

$3.1 million December 2009
Appendix IV: Ongoing, Planned, or Completed 

Land Port of Entry Renovation Projects, Fiscal 

Years 2008 through 2012

Page 63 GAO-13-603 U.S.-Mexico Border

Project title

Infrastructure 

improvement project 

description Location 

Sources (both federal 

and nonfederal) and 

amounts of funding 

provided for the project

Total project 

cost

Date of 

completion

Total all projects 

fiscal years 2008 

through 2012

GSA appropriations: 

$87.5 million

CBP appropriations: 

$17.6 million 

Non-federal sources: 

$10.1 million

$115.2 million

Source: GAO analysis of GSA and CBP documents and officials’ statements.

Table 6 summarizes the three ongoing GSA infrastructure improvement 

projects at southwest border land ports of entry that process commercial 

traffic as of May 2013.

Table 6: Ongoing Infrastructure Improvement Projects at Southwest Border Land Ports of Entry That Process Commercial 

Vehicle Traffic as of May 2013

Project title

Infrastructure 

improvement project 

description

Location 

(specific border 

crossing 

affected)

Sources (both federal 

and nonfederal) and 

amounts of funding to 

be provided for the 

project

Estimated total 

project cost

Expected date of 

completion

Tornillo-Guadalupe 

Land Port of Entry 

Modernization 

Project 

The project is to replace 

and expand the existing 

facility including adding 

two commercial lanes 

capacity to the currently 

passenger-only port.

Tornillo: 

Guadalupe, Texas

GSA Federal Buildings 

Fund–$95.9 million,

CBP Appropriations–

$14.3 million

$79.6 milliona Summer 2013

Nogales West—

Mariposa Land Port 

of Entry 

Modernization 

Project 

This project is to replace 

and expand the existing 

facility, including major 

outbound infrastructure 

improvements and 

adding four commercial 

inspection lanes.

Nogales West: 

Mariposa, Arizona

GSA Federal Buildings 

Fund–$9.8 million 

(design), GSA ARRA–

$182.7 million, CBP 

ARRA Savings–$10.5 

million,b

CBP Appropriations–

$36.5 million

$239.5 million Fall 2014

Santa Teresa Land 

Port of Entry Lane 

Expansion Project

This project is to expand 

the facility, including an 

additional commercial 

processing lane. 

Santa Teresa, 

New Mexico

ARRA Savings–$10 

million

CBP Reimbursable 

Work Authorization–

$1.3 millionc

 

$11.3 million February 2013
Appendix IV: Ongoing, Planned, or Completed 

Land Port of Entry Renovation Projects, Fiscal 

Years 2008 through 2012

Page 64 GAO-13-603 U.S.-Mexico Border

Project title

Infrastructure 

improvement project 

description

Location 

(specific border 

crossing 

affected)

Sources (both federal 

and nonfederal) and 

amounts of funding to 

be provided for the 

project

Estimated total 

project cost

Expected date of 

completion

Total fiscal years 

2008 through 2012

GSA appropriations: 

$105.7 million

ARRA: $203.2 million

CBP appropriations: 

$50.8 million

CBP Reimbursable 

Work Authorization: 

$1.3 million

$330.4 million

Source: GAO analysis of GSA and CBP documents and officials’ statements.

a

According to GSA officials, Congress appropriated about $95.9 million for the Tornillo-Guadalupe 

project, and the total project cost is expected to be $79.6 million or less.

b

These funds were derived from unused ARRA funds that were reprogrammed to other projects 

because of savings or changes to the original projects.

c

Reimbursable Work Authorizations are established to capture and bill the costs of altering, repairing, 

renovating, or providing services in space managed by GSA, over and above the basic operations 

financed through rent.

Table 7 summarizes the one planned infrastructure improvement project 

at a southwest border land port of entry that processes commercial traffic.

Table 7: Planned Infrastructure Improvement Projects at Southwest Border Land Ports of Entry That Process Commercial 

Vehicle Traffic, as of May 2013

Project title

Infrastructure 

improvement project 

description

Location 

(specific border 

crossing 

affected)

Sources (both federal 

and nonfederal) and 

amounts of funding to 

be provided for the 

project

Estimated total 

project cost

Expected start 

date 

Eagle Pass II 

Commercial Lane 

Realignment Project

The project is to 

improve the curvature 

of the two existing 

commercial lanes to 

facilitate traffic flow and 

increase commercial 

processing capacity.

Eagle Pass II, 

Texas

City of Eagle Pass–$6.6 

million, CBP Repairs & 

Alterations budget–$0.4 

million

$7 million Summer to fall 

2013

Project total $7 million $7 million

Source: GAO analysis of GSA and CBP documents and officials’ statements.

. 
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 65 GAO-13-603 U.S.-Mexico Border

This appendix provides additional information on the average hourly 

traffic volume and average hourly percentage of lanes open per month at 

selected crossings, for fiscal years 2008 through 2012. Table 8 describes, 

for each of six selected land border crossings on the southwest border 

that process commercial vehicle traffic, (1) the year the crossing was built 

and last renovated, and (2) the number of primary inspection lanes for 

commercial vehicles in fiscal years 2008 through 2012. Figures 4 to 9 

illustrate the layout of five of the six selected crossings and the primary 

inspection lanes of the remaining crossing for which CBP was not able to 

provide an aerial photo. Tables 8 through 13 provide the average hourly 

traffic volume, per month and the average hourly percentage of lanes 

opened, per month, at each of six selected crossings that process 

commercial vehicle traffic on the southwest border for the period fiscal 

years 2008 through 2012.1

Table 8: Descriptions of Six Selected Crossings including Year Built and Renovated, and the Number of Available 

Commercial Lanes, Fiscal Years 2008 through 2012

Figures 10 through 15 graphically depict the 

average hourly traffic volume and average hourly percentage of lanes 

open per month for each of the six selected crossings.

Crossing name

Year built/last 

renovation Number of lanes available

Otay Mesa: San Diego, California 1984/2009 • 10 commercial lanes available from October 1, 2007, to September 30, 

2012

Mariposa: Nogales, Arizona 1976/2014a • 4 commercial lanes available from October 1, 2007, to April 29, 2012

• 8 commercial lanes available from April 30, 2012, to September 30, 2012

Bridge of the Americas: El Paso, 

Texas

1967/2003 • 6 commercial lanes available from October 1, 2007, to September 30, 

2012

Ysleta: El Paso, Texas 1991/2009 • 6 commercial lanes available from October 1, 2007, to October 20, 2008

• 8 commercial lanes available from October 21, 2008, to September 30, 

2012

Columbia Solidarity: Laredo, 

Texas

1991/NA • 8 commercial lanes available from October 1, 2007, to September 30, 

2012

World Trade Bridge: Laredo, 

Texas

2000/2011 • 8 commercial lanes available from October 1, 2007, to April 14, 2011

• 15 commercial lanes available from April 15, 2011, to September 30, 

2012

Source: GAO analysis of CBP data.

 

1

We selected these six crossings based on their commercial traffic volume, geographic 

diversity, and representation of a mix of recent or ongoing infrastructure modernization 

projects. 

Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes 

Open Per Month, Fiscal Years 2008-2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 66 GAO-13-603 U.S.-Mexico Border

a

Mariposa is currently undergoing renovation. CBP officials report that these renovations are 

expected to be complete in fiscal year 2014.

Figure 4: The Otay Mesa Crossing near San Diego, California

Figure 5: Commercial Vehicle Primary Inspection Lanes at the Mariposa Crossing in 

Nogales, Arizona
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 67 GAO-13-603 U.S.-Mexico Border

Figure 6: The Bridge of the Americas Crossing in El Paso, Texas

Figure 7: The Ysleta Crossing in El Paso, Texas
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 68 GAO-13-603 U.S.-Mexico Border

Figure 8: The Columbia Solidarity Bridge Crossing in Laredo, Texas

Figure 9: The World Trade Bridge Crossing in Laredo, Texas
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 69 GAO-13-603 U.S.-Mexico Border

Table 9: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at Otay Mesa Crossing near San Diego, California, Fiscal Years 

2008 through 2012

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 227 70

November 2007 229 83

December 2007 209 80

January 2008 190 83

February 2008 214 86

March 2008 229 83

April 2008 237 77

May 2008 246 74

June 2008 241 72

July, 2008 242 76

August 2008 233 73

September 2008 234 71

October 2008 229 71

November 2008 194 76

December 2008 178 80

January 2009 165 71

February 2009 168 67

March 2009 171 67

April 2009 187 72

May 2009 191 79

June,2009 202 80

July 2009 197 79

August 2009 197 78

September 2009 209 81

October 2009 221 81

November 2009 214 84

December 2009 194 83

January 2010 174 77

February 2010 195 80

March 2010 213 84

April 2010 219 84

May 2010 217 82

June 2010 223 85
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 70 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2010 213 83

August 2010 212 82

September 2010 219 83

October 2010 215 81

November 2010 220 79

December 2010 188 80

January 2011 185 78

February 2011 202 83

March 2011 210 85

April 2011 212 84

May 2011 208 86

June 2011 227 89

July 2011 216 88

August 2011 216 88

September 2011 220 86

October 2011 226 86

November 2011 224 83

December 2011 189 85

January 2012 197 85

February 2012 206 83

March 2012 224 84

April 2012 223 82

May 2012 234 85

June 2012 232 88

July 2012 223 88

August 2012 230 89

September 2012 230 89

Source: GAO analysis of CBP data.
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 71 GAO-13-603 U.S.-Mexico Border

Table 10: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at Mariposa Crossing in Nogales, Arizona, Fiscal Years 2008 

through 2012 

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 87 45

November 2007 114 64

December 2007 123 71

January 2008 137 71

February 2008 146 71

March 2008 150 70

April 2008 156 77

May 2008 166 94

June 2008 128 95

July 2008 102 46

August 2008 102 40

September 2008 96 39

October 2008 119 48

November 2008 127 56

December 2008 123 59

January 2009 137 73

February 2009 133 67

March 2009 132 63

April 2009 136 63

May 2009 131 70

June 2009 128 66

July 2009 91 55

August 2009 89 49

September 2009 93 46

October 2009 119 52

November 2009 127 60

December 2009 131 73

January 2010 151 80

February 2010 157 78

March 2010 161 80

April 2010 166 90

May 2010 174 90

June 2010 146 95
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 72 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2010 102 87

August 2010 101 63

September 2010 100 65

October 2010 118 66

November 2010 135 78

December 2010 138 84

January 2011 150 89

February 2011 138 83

March 2011 134 71

April 2011 145 76

May 2011 168 92

June 2011 139 82

July 2011 103 57

August, 2011 103 57

September 2011 104 55

October 2011 122 61

November 2011 134 79

December 2011 127 72

January 2012 147 80

February 2012 151 84

March 2012 155 84

April 2012 159 83

May 2012 178 47

June 2012 142 48

July 2012 101 44

August 2012 103 41

September 2012 104 42

Source: GAO analysis of CBP data.

Table 11: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at Bridge of the Americas Crossing in El Paso, Texas, Fiscal Years 

2008 through 2012 

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 164 87

November 2007 164 84

December 2007 143 91
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 73 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

January 2008 153 93

February 2008 164 93

March 2008 161 89

April 2008 168 94

May 2008 168 93

June 2008 175 93

July 2008 163 94

August 2008 168 89

September 2008 154 92

October 2008 154 91

November 2008 142 86

December 2008 120 83

January 2009 134 88

February 2009 132 77

March 2009 129 78

April 2009 118 75

May 2009 114 73

June 2009 117 76

July 2009 118 76

August 2009 122 77

September 2009 129 80

October 2009 129 81

November 2009 137 86

December 2009 122 82

January 2010 137 86

February 2010 144 91

March 2010 139 88

April 2010 140 90

May 2010 66 40

June 2010 126 70

July 2010 125 49

August 2010 129 48

September 2010 131 53

October 2010 130 63

November 2010 131 63

December 2010 111 63
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 74 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

January 2011 120 60

February 2011 117 65

March 2011 131 66

April 2011 132 68

May 2011 131 72

June 2011 133 72

July 2011 125 77

August 2011 132 81

September 2011 129 75

October 2011 127 71

November 2011 130 67

December 2011 109 49

January 2012 121 63

February 2012 118 54

March 2012 117 39

April 2012 117 52

May 2012 116 52

June 2012 116 74

July 2012 113 77

August 2012 114 79

September 2012 111 72

Source: GAO analysis of CBP data.

Table 12: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at Ysleta Crossing in El Paso, Texas, Fiscal Years 2008 through 

2012 

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 131 92

November 2007 138 89

December 2007 119 90

January 2008 121 91

February 2008 135 94

March 2008 144 93

April 2008 137 94

May 2008 132 92

June 2008 138 95
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 75 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2008 127 94

August 2008 131 88

September 2008 131 89

October 2008 131 81

November 2008 84 50

December 2008 71 45

January 2009 73 44

February 2009 73 41

March 2009 79 41

April, 2009 82 44

May 2009 83 46

June 2009 105 55

July 2009 102 54

August 2009 110 56

September 2009 118 58

October 2009 116 58

November 2009 115 58

December 2009 101 55

January 2010 103 55

February 2010 112 58

March 2010 117 57

April 2010 127 58

May 2010 179 77

June 2010 141 59

July 2010 121 33

August 2010 124 35

September 2010 130 37

October 2010 129 39

November 2010 130 38

December 2010 112 37

January 2011 120 36

February 2011 129 40

March 2011 140 40

April 2011 142 44

May 2011 131 43

June 2011 131 41
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 76 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2011 122 42

August 2011 126 40

September 2011 130 41

October 2011 128 37

November 2011 123 35

December 2011 104 29

January 2012 123 38

February 2012 135 38

March 2012 135 27

April 2012 137 35

May 2012 141 35

June 2012 140 46

July 2012 127 44

August 2012 137 48

September 2012 139 46

Source: GAO analysis of CBP data.

Table 13: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at Columbia Solidarity Bridge Crossing in Laredo, Texas, Fiscal 

Years 2008 through 2012 

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 143 36

November 2007 138 36

December 2007 130 42

January 2008 133 45

February 2008 148 44

March 2008 143 46

April 2008 157 45

May 2008 145 45

June 2008 140 47

July 2008 123 45

August 2008 130 47

September 2008 122 46

October 2008 129 47

November 2008 122 45

December 2008 109 47
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 77 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

January 2009 105 46

February 2009 110 46

March 2009 102 41

April 2009 107 42

May 2009 96 43

June 2009 99 42

July 2009 96 39

August 2009 98 41

September 2009 108 39

October 2009 108 41

November 2009 114 40

December 2009 110 40

January 2010 119 38

February 2010 125 38

March 2010 134 36

April 2010 137 37

May 2010 126 38

June 2010 132 40

July 2010 115 38

August 2010 137 36

September 2010 132 36

October 2010 142 38

November 2010 146 39

December 2010 140 36

January 2011 138 37

February 2011 151 36

March 2011 155 36

April 2011 148 37

May 2011 139 36

June 2011 139 36

July 2011 130 37

August 2011 134 35

September 2011 144 36

October 2011 144 37

November 2011 145 36

December 2011 141 37
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 78 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

January 2012 142 37

February 2012 156 38

March 2012 158 37

April 2012 166 37

May 2012 151 37

June 2012 148 37

July 2012 141 37

August 2012 142 37

September 2012 140 36

Source: GAO analysis of CBP data.

Table 14: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes 

Open Per Month at World Trade Bridge Crossing in Laredo, Texas, Fiscal Years 

2008 through 2012 

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

October 2007 327 87

November 2007 369 89

December 2007 349 90

January 2008 333 90

February 2008 363 89

March 2008 358 89

April 2008 373 90

May 2008 374 89

June 2008 374 90

July 2008 361 86

August 2008 367 89

September 2008 336 90

October 2008 361 93

November 2008 335 91

December 2008 306 91

January 2009 240 85

February 2009 247 83

March 2009 253 80

April 2009 255 73

May 2009 242 74

June 2009 307 80
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 79 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2009 344 85

August 2009 369 84

September 2009 386 86

October 2009 384 85

November 2009 382 83

December 2009 386 84

January 2010 371 79

February 2010 397 77

March 2010 398 75

April 2010 418 79

May 2010 405 77

June 2010 414 79

July 2010 372 79

August 2010 418 78

September 2010 412 78

October 2010 405 79

November 2010 403 77

December 2010 391 77

January 2011 396 78

February 2011 419 76

March 2011 431 79

April 2011 443 71

May 2011 435 53

June 2011 432 51

July 2011 414 49

August 2011 431 52

September 2011 440 52

October 2011 435 48

November 2011 429 51

December 2011 403 50

January 2012 421 49

February 2012 470 54

March 2012 490 55

April 2012 480 57

May 2012 486 58

June 2012 488 57
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 80 GAO-13-603 U.S.-Mexico Border

Month and year

Average hourly traffic 

volume per month

Average hourly lane utilization 

per month (in percent)

July 2012 462 55

August 2012 481 55

September 2012 462 54

Source: GAO analysis of CBP data.

Figure 10: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at Otay Mesa Crossing 

near San Diego, California, Fiscal Year 2008 through 2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 81 GAO-13-603 U.S.-Mexico Border

Figure 11: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at the Mariposa Crossing 

in Nogales, Arizona, Fiscal Year 2008 through 2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 82 GAO-13-603 U.S.-Mexico Border

Figure 12: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at the Bridge of the 

Americas Crossing in El Paso, Texas, Fiscal Year 2008 through 2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 83 GAO-13-603 U.S.-Mexico Border

Figure 13: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at Ysleta Crossing in El 

Paso, Texas, Fiscal Year 2008 through 2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 84 GAO-13-603 U.S.-Mexico Border

Figure 14: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at Columbia Solidarity 

Bridge Crossing in Laredo, Texas, Fiscal Year 2008 through 2012
Appendix V: Average Hourly Traffic Volume 

and Average Hourly Percentage of Lanes Open 

Per Month, Fiscal Years 2008-2012

Page 85 GAO-13-603 U.S.-Mexico Border

Figure 15: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month at World Trade Bridge 

Crossing in Laredo, Texas, Fiscal Year 2008 through 2012
Appendix VI: Performance Measures for U.S. 

Customs and Border Protection Activities, 

Fiscal Year 2013

Page 86 GAO-13-603 U.S.-Mexico Border

Table 15 lists the 28 performance measures DHS and CBP are using in 

fiscal year 2013 to assess and report on CBP progress toward the 

agency’s security and trade facilitation goals. These CBP-focused 

performance measures include the following:

• Nine measures selected by DHS as Government Performance and 

Results Act (GPRA) measures.1 (These are also called strategic 

measures within the department.) These measures are aligned with 

the goals and objectives in DHS’s Quadrennial Homeland Security 

Review Report and publicly reported to communicate achievement of 

these strategic goals and objectives.2

• Fifteen management measures that are not reported publicly but 

rather inform internal CBP decisions on program priorities and 

resource allocation, and to monitor progress and performance. CBP

officials report, for example, that these measures are used in crafting 

the department’s budget justification.

• Four CBP Office of Field Operations (OFO) operational measures that 

capture former GPRA measures that OFO uses internally to evaluate 

senior officials’ performance, for example.3

 

1

In fiscal year 2013, DHS has designated 84 GPRA performance measures—9 of which 

focus on CBP efforts.

2

The agency’s security and trade facilitation goals are articulated in DHS’s February 2010 

Quadrennial Homeland Security Review Report, which outlined a strategic framework for 

homeland security. See DHS, Quadrennial Homeland Security Review Report: A Strategic 

Framework for a Secure Homeland (Washington, D.C.: February 2010).

3

According to CBP officials, OFO is the only office within CBP that maintains such 

operational measures.

Appendix VI: Performance Measures for U.S. 

Customs and Border Protection Activities, 

Fiscal Year 2013
Appendix VI: Performance Measures for U.S. 

Customs and Border Protection Activities, 

Fiscal Year 2013

Page 87 GAO-13-603 U.S.-Mexico Border

Table 15: U.S. Customs and Border Protection-Focused Performance Measures, Fiscal Year 2013

Type of 

performance 

measure Performance measure name

Fiscal year 

2013 target

Government 

Performance and 

Results Act / strategic 

performance 

measures

1 Number of apprehensions on the southwest border between the ports of entry < 391,000

2 Percent of people apprehended multiple times along the southwest border 18%

3 Percent of detected conventional aircraft incursions resolved along all borders of the 

United States

100%

4 Percent of cargo by value imported into the U.S. by participants in CBP trade 

partnership programs

57%

5 Percent of import revenue successfully collected 100%

6 Percent of imports compliant with U.S. trade laws 97.5%

7 Amount of smuggled outbound currency seized at ports of entry $30 million

8 Number of smuggled outbound weapons seized at ports of entry 400

9 Percent of inbound cargo identified by CBP as potentially high risk that is assessed or 

scanned prior to departure or at arrival at a U.S. port of entry

FOUOa

Management 

performance 

measures

1 Average number of apprehensions for persons with multiple apprehensions along the 

southwest border

2.48

2 Number of joint operations conducted along the southwest border by Border Patrol 

agents and Mexican law enforcement partners

11

3 Number of joint operations conducted along the northern border by Border Patrol agents 

and Canadian law enforcement partners

18

4 Percent of apprehensions at Border Patrol checkpoints < 5%

5 Percent of air support launches accomplished to support Homeland Security missions > 95%

6 Percent of pharmaceutical, health, and chemical industry imports compliant with U.S. 

trade laws

98%

7 Percent of petroleum industry imports compliant with U.S. trade laws 95%

8 Value of shipments seized as a result of intellectual property rights violations $136 million

9 Number of shipments seized as a result of intellectual property rights violations 24,000

10 Compliance rate for Customs-Trade Partnership Against Terrorism (C-TPAT) members 

with established C-TPAT security criteriab 94%

11 Percent of land border passengers compliant with laws, rules, and regulations 99.5%

12 Percent of air passengers compliant with laws, rules, and regulations 98%

13 Percent of border vehicle passengers in compliance with agricultural quarantine 

regulations

95.5%

14 Percent of international air passengers in compliance with agricultural quarantine 

regulations

95.5%

15 Percent of time TECS is available to end usersc 99%
Appendix VI: Performance Measures for U.S. 

Customs and Border Protection Activities, 

Fiscal Year 2013

Page 88 GAO-13-603 U.S.-Mexico Border

Type of 

performance 

measure Performance measure name

Fiscal year 

2013 target

Office of Field 

Operations’ 

operational 

performance 

measuresd

1 Percent increase in travelers to the U.S. enrolled in a Trusted Traveler program 

(cumulative)

16%

2 Percent of individuals screened against law enforcement databases for entry into the 

United States

FOUOa

3 Air passenger interdiction rate for major violations FOUOa

4 Land border interdiction rate for major violations FOUOa

Source: GAO analysis of CBP performance measurement documents.

a

The specific performance target is designated by CBP as for official use only (FOUO).

b

C-TPAT is a customs-to-business partnership program that provides benefits to supply chain 

companies that agree to comply with predetermined security measures

c

TECS is the principal system used by CBP officers at the border to assist with screening and 

determinations regarding admissibility of arriving persons.

d

According to CBP officials, OFO is the only office within CBP that maintains such operational 

measures.
Appendix VII: Comments from the Department 

of Homeland Security

Page 89 GAO-13-603 U.S.-Mexico Border

Appendix VII: Comments from the 

Department of Homeland Security
Appendix VII: Comments from the Department 

of Homeland Security

Page 90 GAO-13-603 U.S.-Mexico Border
Appendix VII: Comments from the Department 

of Homeland Security

Page 91 GAO-13-603 U.S.-Mexico Border
Appendix VII: Comments from the Department 

of Homeland Security

Page 92 GAO-13-603 U.S.-Mexico Border
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 93 GAO-13-603 U.S.-Mexico Border

Rebecca Gambler, (202) 512-8777 or GamblerR@gao.gov

In addition to the contact named above, Lacinda Ayers, Assistant 

Director; Claudia Becker; Sarah Kaczmarek; and Michael Lenington 

made key contributions to this report. Also contributing to this report were 

Pedro Almoguera, Frances Cook, Juan Gobel, Eric Hauswirth, Phil Herr, 

Stan Kostyla, Jessica Orr, Minette Richardson, and Loren Yager.

Appendix VIII: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(441094)
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