U.S.-Mexico Border: CBP Action Needed to Improve Wait Time Data and Measure Outcomes of Trade Facilitation Efforts
Released: 2013-07-24T00:00:00

Letter

Background

Agencies’ Responsibilities at Land Ports of Entry

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.

Processing commercial vehicles into the United States at land ports of entry involves various steps and requirements. First, CBP requires carriers to submit electronic lists describing their shipments, known as e- Manifests, prior to a shipment’s arrival at the border.reviews the e-Manifest using its Automated Commercial Environment Second, CBP database, among others, and assigns a risk level to the shipment. 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. 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. Trucks that require secondary inspection may be inspected by more than one federal agency, depending on their cargo. See figure 2 for an illustration of the steps in the commercial vehicle inspection process at land ports of entry.

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. 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.

CBP Public Reporting of Border Crossing Wait Time Data

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.

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 Staff at Land Border Crossings

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. 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.

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 security included $29 million for hiring additional CBP officers for southwest border land ports of entry.

Assessments of Port Infrastructure

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.information on completed, ongoing, or planned infrastructure improvement projects at southwest border land ports of entry for fiscal years 2008 through 2012.

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

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 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.

CBP 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. 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. 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.

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.

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 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. 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.

Wait time data currently reported on CBP’s public website are of limited usefulness to inform industry and the public because of the data 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. 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 border- crossing 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.

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 senior 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 measurement and reporting of wait times.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.

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 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.

CBP Has Not Assessed the Feasibility of New Automation Options

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. Wait time data resulting from some of these pilots is currently shared on a publicly available website with updates every 10 minutes. 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.

CBP headquarters and field officials, as well as FHWA and a Texas Department of Transportation official, cited a range of potential benefits 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 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 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. 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.

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

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

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

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. 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: 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 an hourly average of between 80 and 84 percent of Mariposa’s primary lanes per month.

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. This generally supported CBP officials’ statements that they have the capacity to open more primary inspection lanes at these crossings.

Our 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. lanes were opened, causing congestion throughout the facility because of limited space at secondary inspection. 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.

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

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. 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. 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 well- coordinated land transportation and infrastructure planning process along the border.

CBP Cites Need for Additional CBP Officers to Process Commercial Traffic at Some Crossings but Documentation Could Increase Transparency of Staff Allocations across Locations

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. 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.

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. 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 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. However, officials at the Otay Mesa port of entry noted that the availability of overtime funds has decreased because of budget constraints in recent years.

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.

Best practices for strategic workforce planning identified by GAO emphasize the importance of ensuring that the methodology underlying staffing decisions is well documented. Standards for Internal Control in the Federal Government also calls for clear documentation of policies and procedures that are readily available for examination. 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.

CBP Performance Measures Do Not Reflect Progress in Achieving Trade Facilitation Goals

In fiscal year 2013, CBP identified 28 performance measures to assess and report on progress toward CBP’s security and trade facilitation goals. 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 OFO continues to use internally.fiscal year 2013 performance measures.)

The 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, low- risk travelers through dedicated lanes and kiosks. FAST is one of several such programs. 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, In addition, though they note that it is limited to passenger vehicles.OMB guidance states that proxy measures that are closely tied to the desired outcome can be used to indirectly measure program outcomes when programs are difficult to measure because data are not available.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.

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.

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.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 This guidance further states that outcome goals wherever possible to reflect the results of their activities. In addition, OMB guidance encourages the use of outcome measures because they are much more meaningful to the public. 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.

Conclusions

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.

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.

Recommendations for Executive Action

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 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.

Agency Comments and Our Evaluation

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.

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 outcome- oriented 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; 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.

Appendix I: Results of Studies on the Economic Impact of Wait Times on Cross- Border Commerce

To determine what is known about the economic impact of wait time on cross-border commerce, we identified and analyzed relevant studies. 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. 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.

CBP Study Estimated the Effect of Additional Staff at Ports of Entry on Wait Times and the U.S. Economy

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. 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. 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.

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 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. 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.

Other Commissioned Studies Reported That Wait Times Directly Affect the U.S. Economy, Resulting in Lost Revenue and Jobs

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.

Appendix II: Objectives, Scope, and Methodology

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. 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, 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.

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.documentary and testimonial evidence of how wait times are currently being calculated by officials at land ports of entry on the southwest border We compared 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. 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. 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.

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 reports. 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. 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 To ensure data reliability, we did excluded hazardous materials traffic.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 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. 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.

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 goals and incorporate successful practices. 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 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 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.

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

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. 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.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.

This process, known as the capital 1. Strategic Resource Assessments 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. 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 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.

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 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 near- term 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

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. 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. 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.

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.

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 7 summarizes the one planned infrastructure improvement project at a southwest border land port of entry that processes commercial traffic. .

Appendix V: Average Hourly Traffic Volume and Average Hourly Percentage of Lanes Open Per Month, Fiscal Years 2008-2012

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. 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.

Appendix VI: Performance Measures for U.S. Customs and Border Protection Activities, Fiscal Year 2013

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. (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.

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.

Appendix VII: Comments from the Department of Homeland Security

Appendix VIII: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.