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Report to the Ranking Member, Subcommittee on Oversight of Government
Management, the Federal Workforce, and the District of Columbia,
Committee on Homeland Security and Governmental Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
July 2010:
Border Security:
CBP Lacks the Data Needed to Assess the FAST Program at U.S. Northern
Border Ports:
GAO-10-694:
GAO Highlights:
Highlights of GAO-10-694, a report to the Ranking Member, Subcommittee
on Oversight of Government Management, the Federal Workforce, and the
District of Columbia, Committee on Homeland Security and Governmental
Affairs, U.S. Senate.
Why GAO Did This Study:
The United States and Canada share a border of nearly 5,525 miles.
U.S. Customs and Border Protection (CBP), within the Department of
Homeland Security (DHS), is responsible for securing the borders while
facilitating trade and travel. CBP launched the Free and Secure Trade
(FAST) program in 2002 to expedite processing for pre-vetted, low-risk
shipments. GAO was requested to assess U.S.-Canadian border delays.
This report addresses the following for U.S. northern border land
ports of entry: (1) the extent to which wait times data are reliable
and reported trends in wait times, (2) any actions CBP has taken to
reduce wait times and any challenges that remain, and (3) the extent
to which CBP and FAST participants experience the benefits of the FAST
program. GAO analyzed CBP information and data on staffing,
infrastructure, wait times, training, and the FAST program from 2003
through 2009 to analyze operations. GAO visited six northern border
land ports, which were primarily selected based on commercial traffic
volume. GAO interviewed importers, trade organizations, and border
stakeholders. The results are not generalizable, but provide insights.
What GAO Found:
CBP does not collect data that would allow it to assess the effect of
staffing and infrastructure constraints on wait times, but CBP
officials and stakeholders report that wait times have decreased. CBP
calculates and reports wait times hourly for 28 of 122 northern border
land ports. However, CBP officials and the 13 border stakeholders,
importers, and trade organizations GAO interviewed about wait times
questioned the accuracy and reliability of CBP’s wait times data. For
example, CBP officers at three crossings questioned the methods used
to estimate wait times, such as driver surveys, which are subjective.
According to CBP and all stakeholders GAO interviewed, wait times for
commercial vehicles have generally decreased due to lower traffic
volumes as a result of the recession as well as staffing and
infrastructure improvements, among other things. CBP initiated a pilot
project in 2009 to automate wait times measurement and improve the
accuracy of the data, and plans to deploy initial technology in the
summer of 2010.
To reduce wait times, CBP has taken actions to address staffing
constraints and make infrastructure improvements, but challenges
remain. CBP has increased northern border staffing levels by 47
percent from fiscal years 2003 through 2010, and thus is better able
to staff all available lanes. GAO found that CBP officers receive 3 to
14 weeks of on-the-job training rather than the required 12 to 14
weeks. CBP launched an enhanced tracking system in April 2010 to
monitor training, which officials said will enable them to work with
field offices that are not providing required training. CBP has a
process for identifying and prioritizing capital infrastructure needs
at land ports and has infrastructure projects related to 35 of the 122
northern border ports under way or planned over the next 5 years, in
part, to help reduce wait times. CBP has made infrastructure
improvements at 5 of the 6 land ports GAO visited. CBP officials said
they face challenges addressing infrastructure needs, such as
expanding infrastructure at the Peace Bridge, which is confined on
three sides by the Niagara River, a historic park, and a residential
neighborhood.
CBP lacks data needed to assess whether FAST program participants
receive program benefits, but depending on the infrastructure
available, CBP and 8 of 11 stakeholders GAO interviewed had generally
favorable views of the program. CBP’s Automated Commercial Environment
(ACE) collects data on freight processing but does not differentiate
between FAST and non-FAST shipments. Thus, it is difficult for CBP to
determine the extent to which participants experience intended
benefits. CBP officials stated that the ACE system needs to be
modified to capture these data, but CBP has not yet set milestones to
do so. Establishing milestones could help CBP ensure that
modifications to ACE proceed as planned so that CBP is better
positioned to begin collecting data. However, CBP does not have plans
to conduct a study to determine if program benefits are being realized
once these data have been captured. Conducting such a study would help
CBP determine if the benefits are experienced by all FAST
participants, and what program adjustments, if any, are needed.
What GAO Recommends:
GAO recommends that CBP (1) develop milestones for completing the
enhancement of the database to capture data on FAST program benefits
and (2) conduct a study to determine if program benefits are being
realized. DHS concurred.
View [hyperlink, http://www.gao.gov/products/GAO-10-694] or key
components. For more information, contact Richard M. Stana at (202)
512-8777 or stanar@gao.gov.
[End of section]
Contents:
Letter:
Background:
CBP Does Not Collect Data That Would Allow It to Assess the Effect of
Staffing and Infrastructure Constraints on Wait Times, but CBP
Officials and Stakeholders Stated That Wait Times Have Decreased:
CBP Has Taken Actions to Address Staffing and Infrastructure
Constraints, but Training Challenges Remain:
CBP Lacks Data to Assess the FAST Program, but CBP, Selected
Importers, and Trade Organizations Report Generally Favorable Reviews
Where Infrastructure Is Available:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Comments from the Department of Homeland Security:
Appendix II: Comments from the Department of Commerce:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Duration of On-the-Job Training Provided to New Officers at
Ports Visited, as Reported by CBP Managers and Staff:
Table 2: GSA Funding Requests and Appropriations for Capital
Investment and Leasing Program for Land Ports of Entry, Fiscal Years
2003 through 2010:
Figures:
Figure 1: Lewiston-Queenston Border Crossing, Lewiston, New York:
Figure 2: Cargo Processing at Land Port of Entry:
Figure 3: FAST Enrollment Rates from Calendar Years 2003 through 2009:
Figure 4: Annual Truck Crossings along the Northern Border, Calendar
Years 2005 through 2009:
Figure 5: Trucks Queuing on the Ambassador Bridge, Detroit, Michigan,
in 2007:
Figure 6: Northern Border Staffing Trends, Fiscal Years 2003 through
2009:
Figure 7: Aerial View of Lewiston-Queenston Bridge Facility:
Figure 8: High-Low Processing Booth for Either Cars or Trucks Next to
Four Regular Car Booths at the Port Huron Facility:
Figure 9: Lewiston-Queenston Bridge with Four Lanes Prior to Expansion
Project:
Figure 10: Lewiston-Queenston Bridge with Five Lanes after Expansion
Project:
Figure 11: Mobile VACIS Scanning Shipment in Secondary Inspection:
Figure 12: Truck Curving around Wall and Lane 10 to Access FAST Booths
Ahead:
Figure 13: GSA Land Port of Entry Capital Program Delivery Process:
Figure 14: Overhead View of Peace Bridge Facility in Buffalo, New York:
Figure 15: A Dedicated FAST Booth at the Pacific Highway Crossing in
Blaine, Washington:
Figure 16: A FAST-Dedicated Booth in Port Huron, Michigan:
Figure 17: FAST Truck Curving around Lane 10 and Heading toward
Dedicated FAST Booths Ahead:
Abbreviations:
ACE: Automated Commercial Environment:
ATS: Automated Targeting System:
ATU: Advance Targeting Unit:
CBP: U.S. Customs and Border Protection:
C-TPAT: Customs-Trade Partnership Against Terrorism:
DHS: Department of Homeland Security:
DOT: Department of Transportation:
FAST: Free and Secure Trade:
FDA: Food and Drug Administration:
GM: General Motors:
GSA: General Services Administration:
HHS: Department of Health and Human Services:
LTL: less-than-truckload:
MDOT: Michigan Department of Transportation:
NCAP: National Customs Automation Program:
OMB: Office of Management and Budget:
PAPS: Pre-Arrival Possessing System:
POE: port of entry:
RFID: Radio Frequency Identification Device:
RPM: Radiation Portal Monitor:
SRA: Strategic Resource Assessment:
VACIS: Vehicle and Cargo Inspection System:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
July 19, 2010:
The Honorable George V. Voinovich:
Ranking Member:
Subcommittee on Oversight of Government Management, the Federal
Workforce, and the District of Columbia:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Dear Senator Voinovich:
The Department of Homeland Security (DHS) faces challenges in
balancing the need to secure the U.S. borders to prevent the illegal
entry of persons and contraband while at the same time facilitating
legitimate trade and travel. The United States and Canada share the
longest undefended border in the world, covering nearly 5,525 miles,
[Footnote 1] and one of the world's largest trading relationships.
Canada is the United States' largest single trading partner.[Footnote
2] Most of this trade crosses the border by truck. In 2009,
approximately 53 million passengers in personal vehicles and 5 million
commercial vehicles crossed the border from Canada into the United
States. However, this volume is down from about 63 million passengers
in personal vehicles and about 7 million commercial vehicles in 2005,
primarily due to the economic recession.[Footnote 3] In 2006, the
Department of Transportation (DOT) projected that U.S. imports from
Canada by truck would increase from 125 million tons in 2002 to 181
million tons in 2015.[Footnote 4] As the United States and Canada
begin to emerge from the recession, economists expect trade between
these two countries to increase. Further, according to DHS, the
heightened emphasis on border security can lengthen the amount of time
it takes for travelers and cargo to pass inspections and cross the
border.
We reported in August 2007 that DHS had made progress in implementing
its functions in each of its management and mission areas; however, it
faced challenges in balancing trade facilitation and border security,
among other areas.[Footnote 5] For example, we identified challenges
in DHS's efforts to interdict flows of illegal goods into the United
States. There have also been concerns with respect to the adequacy of
staffing as well as facilities and physical infrastructure to
accommodate an increasing volume of traffic. In November 2007, we
reported that staffing shortages affected DHS's ability to carry out
border security responsibilities and that DHS faced challenges in
addressing weaknesses in physical infrastructure at land border
ports.[Footnote 6] Moreover, in September 2008, we reported that
infrastructure constraints and limitations were major impediments to
the smooth flow of traffic and trade crossing at the U.S.-Canada
border at the Peace Bridge in Buffalo, New York.[Footnote 7]
Recognizing the need to improve both border security and border-
crossing efficiency, the United States and Canada have collaborated on
various cross-border management initiatives intended to increase the
flow of legitimate travel across the border while maintaining
security. For example, to facilitate the travel of low-risk screened
shipments across the border, the United States and Canada participate
in the Free and Secure Trade (FAST) program through which approved
commercial drivers are to receive expedited border processing. The
FAST program is intended to provide access to dedicated lanes, fewer
referrals to secondary inspections for participants, priority
processing for U.S. Customs and Border Protection (CBP) inspections,
and enhanced security.[Footnote 8]
You requested that we assess delays crossing the U.S.-Canadian border.
Therefore, this report addresses the following questions:
* To what extent are CBP's wait times data reliable for determining
the impact of staffing and infrastructure on wait times, and what are
the reported trends in commercial vehicle wait times?
* What actions, if any, has CBP taken to reduce wait times caused by
staffing and infrastructure constraints along the U.S. northern border
and what challenges, if any, remain?
* To what extent do CBP and FAST participants experience the benefits
of the FAST program at U.S. northern border land ports of entry?
To address these questions, we reviewed CBP, Department of Commerce
(Commerce), DOT, General Services Administration (GSA),[Footnote 9]
and Food and Drug Administration (FDA) within the Department of Health
and Human Services (HHS) documents and data on staffing,
infrastructure, wait times, training, the FAST program, and commercial
traffic volumes. We visited six ports of entry (POE)[Footnote 10]
(Ambassador Bridge in Michigan, Detroit-Windsor Tunnel in Michigan,
Lewiston-Queenston Bridge Crossing in New York, Pacific Highway
Crossing in Washington, Peace Bridge Crossing in New York, and Port
Huron in Michigan), which we selected based on high commercial volume;
geographic diversity; the results of CBP's Strategic Resource
Assessments (SRA);[Footnote 11] and interviews with CBP, border
stakeholders, importers, and trade organizations. The ports we visited
accounted for, in total, approximately 64 percent of the value of
goods imported into the United States from Canada in 2008. At each
port, we held discussions with CBP officers and met with management to
discuss, among other things, staffing, infrastructure needs, and
trends in border wait times. We toured each facility and observed
primary and secondary inspections[Footnote 12] for FAST and non-FAST
commercial vehicles. Additionally, we interviewed 13 border
stakeholders, including officials from DOT; Commerce; Canada Border
Services Agency in the Windsor-St. Clair and Niagara-Fort Erie
Regions; Detroit River International Crossing; GSA; five bridge
authorities--the Blue Water Bridge Authority, the Niagara Falls Bridge
Commission, the Peace Bridge Authority, the Detroit International
Bridge Company, and the Detroit-Windsor Tunnel Operators--and two
regional traffic organizations--the Niagara International
Transportation Technology Coalition and the International Mobility and
Trade Corridor Project. We also interviewed 10 importers and trade
organizations, of which 3--Ford, General Motors (GM), and Chrysler--
were FAST participants. The other 7 trade organizations were the
American Trucking Association; the Canadian Trucking Alliance; the
U.S., Mexican, and Detroit Chambers of Commerce; as well as the
National and Detroit Customs Forwarders and Brokers Associations.
These stakeholders were selected on the basis of their knowledge of
staffing, infrastructure, wait times at northern border POEs, and the
FAST program. Although the results of our interviews and visits are
not generalizable, they provided us with an overview and perspective
on operations at high-volume northern border land POEs.
To address the first and second objectives, we reviewed CBP
documentation on wait times and infrastructure plans and CBP and GSA
criteria for prioritizing the construction and renovation of land
POEs. We also analyzed CBP's staffing data from fiscal years 2003
through 2009. We selected fiscal year 2003 as the start date for
analysis to ensure consistency with other data used in the report.
Although we discussed the staffing model and its results with CBP
officials responsible for the model, validating the model and its
results was outside the scope of our review. However, CBP is
undertaking efforts to validate and update the assumptions used in the
staffing model and review the sources of data, although CBP has not
yet assessed the reliability of the model's data. Additionally, we
reviewed CBP's data and reports on wait times at northern border land
POEs. We compared CBP's policies and procedures for collecting and
maintaining wait times and staffing with criteria in Standards for
Internal Control in the Federal Government.[Footnote 13] To assess the
reliability of CBP's wait times data, we interviewed agency officials
about data quality, data entry protocols, and quality assurance
procedures, and reviewed relevant documentation, such as CBP's
Inventory of Current Programs for Measuring Wait Times at Land Border
Crossings and the Port of Detroit, Port of Buffalo, and Port Huron
methods for measuring wait times, to determine the source of the data
and the agency's control over the data. We reviewed a number of
analyses of cross-border travel[Footnote 14] and concluded that these
studies were sufficiently reliable for purposes of characterizing
qualitatively the expected costs of wait times.
To address the third objective, we reviewed CBP program goals, the
Federal Register notice establishing the FAST program, and reports
that discussed whether FAST participants receive the benefits. We
reviewed CBP's data on primary and secondary inspections and
processing times and wait times data from fiscal years 2003[Footnote
15] through 2009 for FAST participants compared with non-FAST
participants at northern border land POEs. Further, we reviewed data
for the same time period on the number of FAST shipments referred to
secondary inspection compared to non-FAST shipments. We compared this
information against criteria in Standards for Internal Control in the
Federal Government related to effective characteristics of program
management, as well as the Project Management Standards that call for
documenting the scope of the program and milestones (e.g., time
frames) to ensure that results are achieved.[Footnote 16]
Additionally, we analyzed FAST enrollment rates, and interviewed
selected border stakeholders, importers, and trade organizations, as
previously discussed, to obtain their views on whether the advertised
benefits of FAST are experienced by program participants. We also
interviewed CBP officials in headquarters and at selected land POEs to
understand how the FAST program operates and any challenges that exist
in implementing the program.
We conducted this performance audit from November 2009 through July
2010 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.
Background:
Securing the northern border while at the same time facilitating trade
is the primary responsibility of various components within DHS, in
collaboration with other federal, state, and local entities. CBP is
the lead agency responsible for securing the nation's borders while
facilitating legitimate trade and travel. CBP's Office of Field
Operations is responsible for cargo and passenger processing
activities related to security, trade, immigration, and agricultural
inspection at air, land, and sea POEs. In addition, GSA oversees
design, construction, and maintenance for all POEs in consultation
with CBP. Within DOT, the Federal Highway Administration provides
funding for highway and road construction and administers the
Coordinated Border Infrastructure Program that provides funding to
support the safe and efficient movement of motor vehicles across the
land borders of the United States with Canada and Mexico.
In executing its mission, CBP operates 166 land border POEs. Ownership
of POEs varies by location. CBP's land POE inventory consists of 166
ports, 99 owned by GSA, 22 leased by GSA, 1 owned by the National Park
Service, and 43 owned by CBP. The remaining port is partially owned
and leased by GSA. In general, the CBP-owned ports are small, rural,
and characterized by low-traffic volumes. In contrast, GSA-owned ports
are large, urban, and high-traffic volume ports. A majority (122 of
166) of land border crossings are located on the northern border, and
vary considerably in size, location, and volume. See figure 1 for an
example of a POE.
Figure 1: Lewiston-Queenston Border Crossing, Lewiston, New York:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Appropriations Laws Required CBP to Develop Processes to Prioritize
Resource Needs:
In fiscal year 2005, the conference report accompanying DHS's
appropriation directed CBP to submit a master construction plan for
fiscal years 2005 through 2009, including purpose, cost, and schedule
details for each facility construction planned.[Footnote 17] Further,
the Consolidated Appropriations Act, 2008, required DHS to prepare and
submit a biennial National Land Border Security Plan.[Footnote 18]
This plan was to include a vulnerability, risk, and threat assessment
of each POE located on the northern border or the southern border,
beginning in January 2009. Moreover, the DHS Appropriations Act for
fiscal year 2009 required in fiscal year 2010 and thereafter that
CBP's annual budget submission for construction include, in
consultation with GSA, a detailed 5-year plan for all federal land POE
projects with a yearly update of total projected future funding
needs.[Footnote 19] Additionally, to help address infrastructure
constraints, in 2009, the American Recovery and Reinvestment Act
appropriated $720 million for land POE modernization.[Footnote 20] DHS
received $420 million for ports owned by CBP, which CBP plans to use
for reconstruction, repairs, and alterations at land POEs. These funds
will be used at 21 POEs located along the northern border. The act
appropriated the remaining $300 million for the GSA-owned inventory,
which is being used to provide design or construction funds to seven
new or ongoing capital projects, four of which are along the northern
border.
Moreover, congressional interest in CBP's ability to link resources to
its mission led Congress to call on CBP to develop resource allocation
models. In response to language in the conference report for the
fiscal year 2007 DHS appropriation[Footnote 21] and the Security and
Accountability for Every Port Act of 2006,[Footnote 22] CBP developed
a staffing model for its land, air, and sea POEs. The conference
report directed CBP to develop the staffing model in a way that would
align officer resources with threats, vulnerabilities, and workload.
The staffing model is designed to determine the optimum number of CBP
officers that each POE needs to accomplish its mission
responsibilities.
Commercial Vehicles Are Subject to Inspection by CBP and Other Federal
Agencies:
Processing commercial vehicles at land POEs involves various steps and
requirements. First, carriers are required to submit electronic lists
describing what they are shipping, referred to as e-Manifests,
[Footnote 23] to CBP prior to a shipment's arrival at the border. CBP
requires that e-Manifests for FAST shipments be submitted 30 minutes
prior to arrival, while e-Manifests for non-FAST shipments must be
submitted at least 1 hour before arrival. Second, CBP reviews the e-
Manifest using its Automated Commercial Environment (ACE) database,
among others, and assigns a risk level[Footnote 24] to the shipment, a
process known as pre-vetting. Next, when the commercial truck proceeds
into the United States, it must go to the primary inspection booth at
the U.S. POEs, where a CBP officer reviews documentation on the
exporter, importer, and goods being transported.[Footnote 25] If the
truck's documentation is consistent with CBP requirements and no
further inspections are required, the truck is allowed to pass through
the port. Depending on the POE, 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 based on
experience and training, targeted inspection,[Footnote 26] or random
inspection. Secondary inspection involves more detailed document
processing and examinations using other methods, such as the Vehicle
and Cargo Inspection System (VACIS), a gamma ray imaging system used
to detect various forms of contraband, including explosives and drugs
in commercial vehicles; advanced radiation portal monitor (RPM), a
vehicle monitoring system used to detect nuclear and radiological
materials;[Footnote 27] or unloading and physical inspection. Trucks
that require secondary inspection are inspected by CBP and may be
inspected by more than one federal agency, depending on their cargo.
For example, FDA, under HHS, and the Food Safety and Inspection
Service (FSIS), under the Department of Agriculture, have primary
responsibility for food safety. FDA is responsible for the safety of
virtually all foods, including milk, seafood, fruits, and vegetables.
FSIS oversees the safety of meat, poultry, and processed egg products,
both domestic and imported, and verifies that shipments of these
products meet FSIS requirements. Figure 2 shows the cargo processing
steps at land POE crossings.
Figure 2: Cargo Processing at Land Port of Entry:
[Refer to PDF for image: illustration]
Carrier submits e-Manifest to CBP;
Non-FAST shipments submit e-Manifest 1 hour prior to arrival;
FAST shipments submit e-Manifest 1/2 hour prior to arrival;
Automated Commercial Environment (ACE) database pre-vetting with
various entries;
CBP officer at primary booth:
Release shipment; or:
Take shipments to secondary inspection (paperwork, Vehicle and
Cargo Inspection System-VACIS, physical inspection, etc.) or other
federal agencies; then:
Release shipment; or:
Shipment not permitted entry.
Sources: GAO analysis of CBP information; Art Explosion (clip art).
[End of figure]
A Goal of the FAST Program Is to Expedite Processing for Preapproved
Commercial Shipments:
CBP launched the FAST program in 2002 to include electronic and semi-
electronic automated processing for preapproved shipments. The FAST
program is intended to secure and facilitate legitimate trade by
providing expedited processing of participants' merchandise in
designated traffic lanes at select border sites, fewer referrals to
secondary inspections, "front-of-the-line" processing in secondary CBP
inspections, and enhanced security. FAST shipments are screened
through advanced manifest reviews and targeting, nonintrusive
inspections, canine sweeps, and random exams. 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 pre-vetted in the FAST
program. C-TPAT is a customs-to-business partnership program that
provides benefits[Footnote 28] to supply chain companies that agree to
comply with predetermined security measures.[Footnote 29] We reported
in August 2008 that all C-TPAT participants--the carrier, importer,
and manufacturer--are vetted prior to enrollment and are required to
certify that they meet program minimum security requirements, such as
a secure area to store trailers to prevent unauthorized access or
manipulation.[Footnote 30] Additionally, the (1) driver is required to
have a pre-vetted FAST card, (2) truck is required to have a
transponder, (3) truck cannot be carrying shipments with loads from
multiple shippers that are not C-TPAT certified, and (4) e-Manifest is
required to be submitted to CBP 30 minutes prior to arrival at the
port. There are approximately 90,000 FAST drivers and 9,830 C-TPAT
members, of which 4,400 are importers and 2,721 are carriers. The
remaining 2,709 C-TPAT members are brokers, consolidators, and foreign
manufacturers. FAST participation has increased substantially since
CBP launched the program. However, the number of FAST participants
decreased slightly in 2009, as shown in figure 3. All 122 northern
border POEs and lanes can process FAST shipments in ACE, but 7 POEs on
the northern border have FAST-dedicated lanes.
Figure 3: FAST Enrollment Rates from Calendar Years 2003 through 2009:
[Refer to PDF for image: multiple line graph]
Year: 2003;
Northern border FAST enrollment: 3,260;
Total FAST enrollment: 3,961.
Year: 2004;
Northern border FAST enrollment: 18,287;
Total FAST enrollment: 23,403.
Year: 2005;
Northern border FAST enrollment: 50,791;
Total FAST enrollment: 57,665.
Year: 2006;
Northern border FAST enrollment: 61,623;
Total FAST enrollment: 70,126.
Year: 2007;
Northern border FAST enrollment: 73,636;
Total FAST enrollment: 84,200.
Year: 2008;
Northern border FAST enrollment: 82,570;
Total FAST enrollment: 94,378.
Year: 2009;
Northern border FAST enrollment: 82,140;
Total FAST enrollment: 92,676.
Source: GAO analysis of CBP data.
[End of figure]
ACE tracks shipments by the types of manifests trucks use to report
their shipments. FAST shipments are processed in ACE using two of the
various types of manifests--National Customs Automation Program
(NCAP), limited to certain types of FAST shipments, and Pre-Arrival
Possessing System (PAPS), used by non-FAST and FAST shipments.
According to CBP officials, the FAST/NCAP shipment provides limited
information compared to a standard e-Manifest and no entry record is
filed at the time the shipment is released. For example, the FAST/NCAP
manifest does not include the driver information, trailer license
plate number, or the quantity of shipment. The driver information and
trailer license plate number can be added to the manifest by CBP at
the primary inspection point. However, the quantity of shipment must
be recorded by the broker when the entry is filed within 10 days of
crossing the border. According to CBP, the FAST/NCAP manifest is used
primarily by the auto industry. In contrast, the PAPS shipment uses a
complete data set, including all the information CBP requires, such as
driver information, trailer license plate number, and the quantity of
shipments. Additionally, an entry record must be on file before a
shipment is released. Approximately 60 percent of FAST shipments are
PAPS shipments.
CBP Does Not Collect Data That Would Allow It to Assess the Effect of
Staffing and Infrastructure Constraints on Wait Times, but CBP
Officials and Stakeholders Stated That Wait Times Have Decreased:
CBP Does Not Collect Data That Would Allow It to Determine the Effect
of Staffing and Infrastructure Issues on Wait Times:
CBP is limited in its ability to accurately quantify the impacts of
staffing and infrastructure on wait times because its wait times data
are collected using inconsistent methods and are unreliable. CBP
defines border wait time as the time it takes for a vehicle to travel
from the end of the queue to the CBP primary inspection point. CBP
calculates and reports wait times hourly at 28 major land POEs along
the northern border.[Footnote 31] In October 2007, CBP issued interim
guidance on approved methods for measuring wait times at land POEs.
The guidance outlined various methods for calculating wait times,
including (1) line of sight--CBP officials at the port estimate wait
times based on volume, number of lanes open, and landmarks that
identify the end of the line to the naked eye or camera; (2)
benchmark--CBP officials at the port and stakeholders identify various
benchmarks and measure wait times from the end of the traffic line to
the primary inspection booth based on the number of lanes open and the
benchmark points; (3) license plate reader--CBP officials at the port
manually record the license plate of the last vehicle in line and then
run the plate in TECS[Footnote 32] to identify when the plate was
processed at primary inspection; and (4) driver surveys--when the end
of the line is no longer visible, CBP officials at the port use driver
surveys to estimate wait times. Drivers arriving at primary inspection
are asked by the CBP officer how long they have been waiting in the
queue. CBP officials at the port take an average of the survey results
to estimate wait times.
The six POEs we visited use one or more of the methods described above
to measure wait times. Because the wait times are estimated using
approximations of varying reliability at selected POEs, the data
cannot be used for analyses across ports, and the methods of
collection raise questions about the reliability of the overall data.
CBP officials stated that all wait time measures are collected and
coordinated with local bridge authorities and regional traffic
management centers for concurrence prior to posting. However, some CBP
officials as well as 13 of the 15 importers, trade organizations, and
border stakeholders we spoke with about the accuracy of CBP's wait
times raised questions about the accuracy and reliability of CBP's
wait times data. For example, the CBP officer responsible for
maintaining the Border Wait Times database stated that the accuracy of
the wait times data varies depending on the method used to collect the
data. Specifically, the official stated that driver surveys were
subjective, and that impatient drivers may not provide accurate times
spent in the queue. Further, a CBP official working on the wait times
pilot project stated that manual measurement of wait times data is
time consuming for staff, inaccurate, and could be improved. Commerce
stated that the methods used to measure border wait times are
subjective and therefore, the data vary in their reliability.
Moreover, 12 other border stakeholders, trade organizations, and
importers told us that industry organizations do not use CBP's wait
times data because they question the accuracy of the data.
According to CBP, it uses several methods to measure wait times due to
the infrastructure and port layout at land POEs. However, the formulas
used to estimate wait times are not consistently updated. Further,
because lane use varies at the POEs depending on traffic level and
infrastructure, it may be difficult to obtain accurate wait times for
passenger and commercial vehicles when all traffic share the same
lane. Additionally, prior to April 2006, CBP's Border Wait Time
database did not delineate between wait time data for NEXUS[Footnote
33] and FAST lanes at several POEs. As a result, wait times data for
these programs were recorded within a single data element. Because of
these factors, the data cannot be used for analyses across POEs or at
individual ports, and the methods of collection raise questions about
the reliability of the overall data. Standards for internal control
require that all transactions be clearly documented in a manner that
is complete, accurate, and useful for managers and others involved in
evaluating operations.[Footnote 34] Moreover, internal control
standards call for agencies to establish policies and procedures to
ensure the validity and reliability of data.
CBP acknowledged that the current methodology for measuring private
and commercial vehicle wait times is not ideal, and has initiated a
pilot project to automate wait times measurement and to improve the
accuracy and consistency of the data collected. The wait times pilot
project is a binational interagency initiative led by the Border Wait
Times Work Group made up of representatives from CBP, the Canada
Border Services Agency, the Federal Highway Administration, and
Transport Canada. CBP and DOT officials anticipate spending
approximately $2 million on the pilot project, and CBP and Transport
Canada have committed to funding 50 percent of the cost. The initial
goal of the pilot project is to identify and test up to eight
potential technology solutions for automating the measurement of
border wait times for passengers and commercial vehicles at two land
border locations, the Peace Bridge between Buffalo, New York, and Ft.
Erie, Ontario, and the Pacific Highway crossing between Blaine,
Washington, and Douglas, British Columbia. The pilot also intends to
implement two long-term technology solutions at one or more land
border crossings along the U.S.-Canadian border. According to DOT, if
the pilot project is successful, the selected pilot technologies will
remain in place for approximately 1 year at the designated sites until
further funding is identified. The objectives of the project are to
measure wait times in both directions for cars and trucks, determine
real-time and predictive capabilities, replace the manual process for
calculating wait times, and explore long-term operations. According to
DOT, the test sites were selected based on several criteria, including
traffic types, volume, wait time variability and frequency, site
characteristics, and willingness of site operators to participate in
the pilot project. The initial technology deployment is scheduled to
occur in the summer of 2010. As of April 2010, the Border Wait Times
Work Group had selected four vendor technology solutions, including
traffic radar and Bluetooth, for phase I testing. According to CBP,
during phase I testing, the technology solutions will be installed and
testing will occur for about 30 days. If phase I testing and
evaluation is successful, the technology wait time measurement
solutions will be deployed at the national level during phase II
pending funding. CBP expects to complete the pilot project by the
summer of 2011.
Using a consistent methodology, such as a standard formula and
automation, to measure wait times across all ports could better
position CBP to analyze trends in wait times across land POEs. CBP and
GSA officials report considering wait times as well as other factors
in determining staffing, managing traffic workload, and infrastructure
investments. Without reliable wait times data, CBP and others are
unable to quantitatively determine the extent to which staffing and
infrastructure constraints affect wait times, or readily estimate the
costs of border delays. Having accurate border wait times data could
better position CBP to allocate the needed resources to POEs and
better manage those operations.
Moreover, CBP and DOT officials we interviewed cited a range of
potential benefits that may result from automating border wait times
measurement, such as (1) reducing the burden of manually collecting
wait times data by customs staff; (2) increasing the accuracy,
reliability, and timeliness of the wait times data collected and
disseminated; (3) improving the agency's transparency by enabling land
border wait times to be easily shared with participating agencies and
regional traffic management centers; (4) improving customer service by
increasing available staff for other port tasks; and (5) reducing
delays in freight movement. Additionally, a CBP official working on
the pilot project told us that automating wait times measurement to
improve the data quality will facilitate better management decisions
regarding staffing needs and infrastructure investment at land POEs.
CBP Officials and Stakeholders Report That Wait Times Have Decreased:
CBP officials at the 6 POEs we visited and the 14 border stakeholders,
importers, and trade organizations we spoke with about wait times
agreed that, in general, wait times for commercial vehicles along the
northern border have decreased since 2007. They credit reduced wait
times, in part, to the economic recession, which resulted in reduced
passenger and truck traffic, and staffing and infrastructure
improvements. Border wait times are influenced by multiple factors,
including infrastructure available, staffing, traffic volume, and time
of the year, including holiday travel and special events. Our analysis
of DOT data shows that total truck crossings along the northern border
decreased from about 7 million in 2005 to 5 million in 2009 (see
figure 4). This trend is also reflected in passenger crossing data.
The total number of passenger crossings along the northern border
declined from about 63 million in 2005 to 53 million in 2009.
Figure 4: Annual Truck Crossings along the Northern Border, Calendar
Years 2005 through 2009:
[Refer to PDF for image: vertical bar graph]
Year: 2005;
Truck crossings: 6,784.
Year: 2006;
Truck crossings: 6,649.
Year: 2007;
Truck crossings: 6,559.
Year: 2008;
Truck crossings: 5,895.
Year: 2009;
Truck crossings: 5,032.
Source: GAO analysis of DOT data.
[End of figure]
Although the economic downturn has reduced traffic volume and wait
times, border delays were an issue before the recession. For example,
the summer of 2007 saw the longest delays since the terrorist attacks
in 2001, according to CBP and trade organizations. During this period,
Port Huron, Michigan, regularly had delays that exceeded 1 hour, where
the wait extended to the Blue Water Bridge from Canada into the United
States, according to CBP officials, border stakeholders, and trade
organizations that we interviewed. CBP officials in Detroit, Michigan,
and Buffalo, New York, also reported having similar delays of over 1
hour during the summer of 2007 due to high traffic volume and
infrastructure issues. Figure 5 shows trucks queuing on the Ambassador
Bridge in 2007.
Figure 5: Trucks Queuing on the Ambassador Bridge, Detroit, Michigan,
in 2007:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Longer wait times at the border represent an increase in the cost of
travel, which may lead people to make fewer trips. Conversely, shorter
wait times represent a decrease in the cost of travel, which may lead
people to make more trips.[Footnote 35] According to a number of
analyses of cross-border travel, such delays can result in additional
expenses for industry and consumers stemming from increased carrier
costs, inventory costs, labor costs, problems with inventory, and
resulting reduction in trade and output.[Footnote 36] For example,
many manufacturing industries on both sides of the border manage their
inventories using just-in-time management, a system that allows
companies to ship goods just before they are needed and keep
inventories and warehousing costs lower. Studies indicated that delays
at the border affect delivery of shipments, and could have major
consequences to industries that are time sensitive. Examples of time-
sensitive industries that are reliant on just-in-time inventories and
more vulnerable to supply disruptions include the automotive industry
of the Great Lakes region and companies trading manufactured goods.
Studies show that congestion can affect just-in-time delivery
schedules. For example, according to a July 2009 Brookings Institution
report, unexpected delays forced assembly lines to slow down and in
some cases stop when the parts they need did not arrive on time.
[Footnote 37]
CBP Has Taken Actions to Address Staffing and Infrastructure
Constraints, but Training Challenges Remain:
CBP Has Taken Actions to Address the Effect of Staffing Levels on Wait
Times, but Training Challenges Remain:
CBP has increased staffing levels at northern border POEs to reduce
wait times and improve operations, but is challenged in balancing
increased staffing with training needs. Staffing levels along the
northern border have increased by 47 percent from fiscal years 2003 to
2010 and, as a result, CBP officials at the six ports we visited told
us that they are better able to staff all available primary processing
lanes when needed, which increases throughput and decreases wait
times. For example, CBP management in Blaine, Washington; Buffalo, New
York; and Detroit, Michigan, said that although they struggled with
staffing issues in the past, presently, their staffing needs are met.
CBP officials attributed increased staffing levels to various factors,
including recent recruitment efforts and improved retirement benefits
for CBP officers.
To estimate its staffing needs, CBP uses a workload staffing model
along with other information, such as input from CBP field offices.
[Footnote 38] According to CBP, the model assesses staffing needs
based on factors including traffic volume; workload data; processing
times; expected time away for holidays, leave, training, and temporary
duty assignments; task complexity; and threat levels, and then
calculates the possible number of full-time equivalent CBP officers
for each POE. CBP field offices also conduct their own staffing needs
assessments by POE. CBP considers requests from field offices along
with the model to determine staffing levels. According to CBP, since
the model does not capture the complexity of the operations at the
ports, such as wait times, projected traffic volumes, the
implementation of new programs, facility expansions, and special
enforcement initiatives, final decisions about resource requests and
allocations are made in consultation with operational managers and
program managers at the POEs and headquarters.[Footnote 39] Once final
decisions on staffing needs are made by CBP headquarters, the agency
allocates staffing resources to each POE. According to CBP, the
directors of field operations have the ability to place CBP officers
where they are needed to meet operational needs. CBP management at the
six POEs we visited stated that they determine staffing needs based on
workload, enforcement efforts, and other factors, including wait
times, holidays, and local events.
As of the end of fiscal year 2009, results of the model for the
northern border land POEs showed a recommended level of staffing that
was higher than the number of CBP officers on board. The model
estimated that CBP needed 4,207 CBP officers while CBP had 3,927
officers on board at the end of fiscal year 2009. However, CBP
reiterated that the model does not capture the complexity of land
border operations, nor does it accurately determine resource
requirements at the local level. For example, because the model does
not take into account projected traffic volumes, it would not have
accounted for the initial impacts of the economic recession.
Therefore, CBP does not believe that northern border land POEs are
understaffed based on the staffing model results. Moreover, CBP
officials report that staffing has increased from 2,777 in fiscal year
2003 to 4,151 in fiscal year 2009 (see figure 6 for more details). In
fiscal year 2009, CBP undertook a "hiring surge," which resulted in an
additional 285 staff for northern border land POEs. Due to CBP's
hiring effort, CBP officials report that northern border field offices
received additional staff allocations. The Seattle, Washington;
Detroit, Michigan; and Buffalo, New York, field offices received a
majority of the new staff, as 238 of 285 positions were allocated to
these three offices.
Figure 6: Northern Border Staffing Trends, Fiscal Years 2003 through
2009:
[Refer to PDF for image: line graph]
Year: 2003;
Staffing: 2,777.
Year: 2004;
Staffing: 3,345.
Year: 2005;
Staffing: 3,406.
Year: 2006;
Staffing: 3,355.
Year: 2007;
Staffing: 3,392.
Year: 2008;
Staffing: 3,717.
Year: 2009;
Staffing: 4,151.
Source: GAO analysis of CBP data.
[End of figure]
* Although CBP has taken actions to begin to address the effect of
staffing constraints on wait times, it faces challenges in providing
training to its officers. Newly hired CBP officers undergo multiple
training programs consisting of pre-academy orientation, academy, and
post-academy programs.
* Pre-academy orientation--new officers attend pre-academy orientation
at their duty stations prior to attending the academy training. The
orientation provides new officers with an overview of the job,
including port operations and trade enforcement and facilitation.
* Academy--new officers are required to complete a 73-day training
program at the Federal Law Enforcement Training Center in Glynco,
Georgia. This training consists of classroom, laboratory, and
practical exercises to ensure that the trainees are able to perform
the job.
* Post-academy--after completing academy training, new officers are
required to complete 12 to 14 weeks of post-academy training to gain
on-the-job training (OJT) at their respective POEs.
We reported in November 2007 that CBP faced challenges in providing
the required training and lacked the data needed to assess whether new
officers demonstrate proficiency in required skills.[Footnote 40] We
reported that while CBP requires at least 12 weeks of OJT, new
officers at the POEs visited did not receive 12 weeks of training.
Moreover, we reported that when staff do not receive required training
or are not trained consistent with program guidance, knowledge
building is limited and the risk that needed expertise is not
developed is increased. The lack of experience, combined with
incomplete training, can contribute to delays at primary points of
inspection and unnecessary referrals to secondary inspections.
Moreover, it increases the risk of incomplete or faulty inspections.
We recommended that CBP incorporate into its procedures for its OJT
program specific tasks that CBP officers must experience during OJT
and requirements for measuring officer proficiency in performing those
tasks. CBP officials have begun to take actions to address these
recommendations by, among other things, developing OJT proficiencies
that CBP officers must demonstrate before CBP certifies that the
officers' OJT is complete.
However, at five of six POEs we visited, CBP officers were not
receiving the required 12 to 14 weeks of OJT. The length of training
provided ranged from 3 to 10 weeks at ports we visited rather than the
12 to 14 weeks required by CBP's post-academy training guidance. Table
1 shows the duration of training provided to new officers at the six
ports we visited.
Table 1: Duration of On-the-Job Training Provided to New Officers at
Ports Visited, as Reported by CBP Managers and Staff:
Port: Location 1;
Duration of on-the-job training (weeks): 3 weeks.
Port: Location 2;
Duration of on-the-job training (weeks): 8 weeks.
Port: Location 3;
Duration of on-the-job training (weeks): 8 weeks.
Port: Location 4;
Duration of on-the-job training (weeks): 10 weeks.
Port: Location 5;
Duration of on-the-job training (weeks): 10 weeks.
Port: Location 6;
Duration of on-the-job training (weeks): 12 to 14 weeks.
Source: GAO analysis of CBP training information.
[End of table]
For example, CBP managers at one POE we visited stated that, in
general, new officers receive 3 weeks of OJT. Officers also spend 2 to
4 weeks in a mentoring program. However, as a result of the recent
staffing increase and the need to train more officers, the mentoring
program at this POE has been reduced from 3 to 4 months to about 2 to
4 weeks. Moreover, CBP line officers at the same POE said that 2 weeks
of mentoring is not sufficient time to train new officers. CBP
managers at another POE said that new officers receive about 10 weeks
of OJT. CBP officers at this POE stated that due to the large number
of new staff requiring training and the need to balance this demand
with port operations, the new officer OJT program has been reduced
from 12 to 14 weeks to 6 weeks. Also, officials at another POE told us
that on average, new hires receive at least 8 weeks of OJT. CBP stated
that trainees in all POEs are required to complete the same post-
academy training program and that deviations from the prescribed post-
academy training program are not authorized. However, CBP training
officials stated that depending on staffing levels, field offices may
fast-track training to get new officers on the line to balance the
need to provide training with facilitating the flow of commerce.
Although CBP officials at the six POEs we visited told us that
staffing was adequate, CBP managers at four of six POEs said that it
was a challenge to balance training needs with operational demands.
For example, CBP managers at two POEs told us that they limit the
number of officers sent off-site for training during peak seasons
because it affects staffing level and port operations. According to
CBP managers at one POE we visited, training new officers is expensive
because the agency needs extra staff during each shift that training
occurs. They told us that the agency does not have the capability to
properly train the surge of new officers brought onboard due to recent
hiring efforts because there is a shortage of experienced staff
available to train new hires at the POEs. As a result, new officers
are often trained by less experienced officers than before. Officers
also told us that, in some instances, new officers are assigned to
their duty stations without completing the required field training.
For example, at one location, CBP line officers told us that although
new officers receive a training checklist that supervisors are
supposed to certify, typically supervisors do not certify that the
training checklist has been completed before new officers are assigned
to duty stations.[Footnote 41]
Internal control standards related to human capital management state
that management should ensure that the organization has a workforce
that has the skills necessary to achieve organizational goals.
According to CBP officials responsible for training, staffing and
meeting operational demands are the greatest challenges in training
new hires. CBP officials in headquarters responsible for planning
training stated that when ports undergo a hiring surge, it can be
difficult for them to train the new officers. CBP officials also noted
that ports need to staff extra officers to cover for field trainers
and officers receiving training. For example, field trainers are
officers taken off the line to train new hires. Additionally, CBP
officials said that it is difficult to provide training during peak
seasons when traffic volumes are high, and that field training may be
limited due to capacity issues or availability of space at the POEs.
CBP officials said they recognize that training is a challenge at
POEs, and launched an enhanced tracking system in April 2010 to
monitor the various stages of training, including pre-academy, basic
academy, and post-academy training. According to CBP officials, with
the system enhancement, they will be able to track delivery of
training and work with field offices that are not meeting identified
training needs. Further, CBP training officials told us that they plan
to address the issue related to the need for more experienced field
trainers by developing a certification program, which is being
developed in two stages. The first stage, related to pre-academy
training, was piloted in April 2010. The second stage, related to post-
academy training, will be piloted and completed in September 2010.
In addition, CBP reported that in May 2009 the agency designed and
began implementing a new training approach known as the Federal Career
Internship Program for CBP Officers. According to CBP, the newly
piloted program consists of 3-week pre-academy, 85-day basic training,
and post-academy training. CBP officials explained that depending on
the new hire's POE assignment, the new post-academy program may
consist of specific training in land operations, air and sea
operations, or cargo operations. Additionally, CBP officials stated
that it will use its enhanced tracking system to track all phases of
the new training curriculum locally, in the field offices, and at
headquarters. Further, CBP officials believe that the new post-academy
curriculum and enhanced tracking system will help to eliminate
variance among ports of the same environment in the way post-academy
training is conducted. The pilots of the new curriculum are planned to
be implemented in 2010 and final launch is planned for fiscal year
2011.
CBP Has Prioritized Infrastructure Needs and Has Made Incremental
Improvements to Reduce Wait Times, but Infrastructure Challenges
Continue:
CBP Has a Process for Prioritizing Infrastructure Needs at Land Ports,
and CBP and GSA Have Developed a 5-Year Plan for Infrastructure
Improvements:
CBP's process for identifying and prioritizing capital infrastructure
needs at land POEs consists of several steps, including gathering data
using the SRA process, ranking the facilities by identified needs,
conducting an analysis[Footnote 42] on the initial ranking of needs,
assessing project feasibility and risk; and establishing a capital
investment plan. During the SRA, CBP evaluates the facility against
more than 60 criteria to identify deficiencies that affect the
following categories: mission and operations, security and life
safety, space and site deficiency, and personnel and workload growth.
CBP conducted an SRA of every land POE along both the northern and
southern borders from fiscal years 2003 through 2006. CBP has
concluded that most of the inspection facilities are outdated and were
designed to accomplish legacy missions. On the basis of the
assessments, CBP estimates that it will need over $6 billion during
the next 10 years to modernize the land POE inventory to meet the
operational requirements in a post-9/11 environment and the workload
demands of the 21ST century. CBP began another round of SRAs in fiscal
year 2008, and completion is scheduled for fiscal year 2011.
CBP and GSA have plans to make infrastructure improvements at a number
of land POEs along the northern border designed to ease congestion,
improve inspection capacity, and increase throughput. Over the next 5
years, CBP will have infrastructure projects related to 35 different
northern border land POEs in various stages of development. Five of
the 6 ports we visited have infrastructure improvement projects
scheduled or pending approval. For example, CBP and other stakeholders
initiated a project to expand and modernize the Blue Water Bridge
plaza in Port Huron, Michigan, to alleviate congestion, eliminate
bottlenecks, and enhance security. The project involves a complete
redesign and construction of the bridge plaza, including all
facilities utilized by CBP, the bridge owner, the Michigan Department
of Transportation (MDOT), and other federal agencies. The
Environmental Impact Study was approved in March 2009, and CBP expects
construction to begin in early 2016, with completion projected for
2019. CBP estimates that the project will cost over $500 million.
After the expansion, the facility is planned to increase from 12 to 56
acres, and the number of primary lanes is expected to increase from 13
to 24, which CBP officials said will result in increased throughput
and reduced congestion. According to CBP, 15 of 24 lanes will be
equipped with high-low booths to process passenger ("low") and
commercial traffic ("high"), and 9 lanes will be dedicated to
passenger vehicles to meet CBP's operational requirements.
In another example, infrastructure improvements are also planned for
the Lewiston-Queenston crossing in Buffalo, New York. According to the
May 2008 Lewiston-Queenston Facility feasibility study, the primary
inspection lanes are inadequate to handle passenger and commercial
vehicle traffic and improvements are needed (see figure 7 for an
aerial view of the Lewiston-Queenston Bridge Facility). The study
further concluded that there are too few commercial inspection docks
at Lewiston, and that the docks are undersized. At present, there are
four commercial inspection docks and CBP plans to construct eight
additional docks during renovation. CBP and the Niagara Falls Bridge
Commission estimate that the Lewiston-Queenston renovation will cost
about $117 million. According to CBP officials, CBP is planning to
expand the Lewiston-Queenston Bridge Facility, but the design and
construction remain unfunded. Once funding is available, CBP expects
design to be completed within 12 to 18 months and construction within
24 months.[Footnote 43]
Figure 7: Aerial View of Lewiston-Queenston Bridge Facility:
[Refer to PDF for image: photograph]
Source: Niagara Falls Bridge Commission.
[End of figure]
CBP Has Made Incremental Infrastructure Enhancements That Have Helped
to Improve Border Operations, Including a Reduction of Wait Times:
CBP has made infrastructure improvements at five of six northern
border land POEs we visited, which CBP officials and the seven
importers, trade organizations, and border stakeholders said have
helped to reduce congestion, improve the flow of traffic, and reduce
border wait times. For example, in 2005, CBP made infrastructure
improvements to the Peace Bridge inspection facility, which CBP
officials told us has helped to ease congestion. Specifically, the
number of primary lanes at the facility was increased from 8 to 11 car
lanes and from 4 to 7 commercial vehicles lanes. Furthermore, five of
the primary processing booths are high-low, which allows for
flexibility in processing either cars or trucks, depending on the
specific demand, and maximizes available space (see figure 8 for an
example of high-low booths).
Figure 8: High-Low Processing Booth for Either Cars or Trucks Next to
Four Regular Car Booths at the Port Huron Facility:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Nine of 13 lanes at Port Huron, Michigan, were modified to equip them
with high-low booths, and the Lewiston-Queenston Bridge Facility was
remodeled to include high-low booths for either cars or trucks, where
lanes change as needed based on traffic composition. Additionally, the
Niagara Falls Bridge Commission increased the capacity of the bridge
from four lanes to five lanes. As a result, there are now three U.S.-
bound lanes--one for FAST, one for commercial vehicles, and one for
personal cars (see figures 9 and 10).
Figure 9: Lewiston-Queenston Bridge with Four Lanes Prior to Expansion
Project:
[Refer to PDF for image: photograph]
Source: Niagara Falls Bridge Commission.
[End of figure]
Figure 10: Lewiston-Queenston Bridge with Five Lanes after Expansion
Project:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Moreover, CBP increased the number of primary lanes at the Ambassador
Bridge Fort Street Cargo Facility and the Ambassador Bridge Plaza,
which according to CBP has helped to ease traffic congestion and
reduce delays. For example, in June 2008, the Ambassador Bridge Plaza
was expanded from 12 to 19 primary lanes. According to CBP and the
Ambassador Bridge Authority, the expansion helped to improve traffic
flow and reduce congestion on the bridge. Further, in 2004, CBP
increased the commercial processing capacity of the Ambassador Bridge
Fort Street Cargo Facility by adding seven primary processing booths.
Despite these incremental infrastructure changes, however, CBP
officials at the six ports we visited told us that additional
processing capacity is needed to accommodate projected traffic flows.
As discussed earlier in the report, five of six ports we visited have
infrastructure improvement projects planned or pending approval.
CBP Has Also Deployed Technological Infrastructure to Expedite
Processing:
CBP has also deployed automated license plate and document readers as
well as other technology at the six POEs we visited, which CBP
officials said have helped to facilitate vehicle processing. License
plate readers automatically read front and rear license plates of
vehicles as they enter the primary inspection area, with the data
simultaneously queried against CBP and law enforcement databases. CBP
has installed technology that can read documents enabled with Radio
Frequency Identification Device (RFID) technology, which according to
CBP speeds up processing. A driver who has a FAST card, for expedited
processing, holds up the RFID-enabled card before entering the booth.
As a result, the driver's information is automatically displayed on
the screen before the driver approaches the primary inspection booth.
In addition, CBP officials said that use of nonintrusive technologies,
such as the VACIS and RPM, have allowed CBP to inspect more shipments
efficiently and reduced the number of physical inspections, which can
be costly and time consuming. These technologies allow CBP to inspect
cargo without having to perform a time-intensive manual search or
other intrusive examinations of the contents. For example, CBP
officials at the Peace Bridge told us that they scan over 100
commercial shipments a day using VACIS; however, prior to deploying
VACIS, CBP officials said they unloaded and inspected only 12
commercial vehicles a day (figure 11 shows a picture of a mobile
VACIS). In general, CBP can use VACIS to avoid unloading of the
contents of a truck, but at certain times a CBP officer may determine
that a physical search is necessary.
Figure 11: Mobile VACIS Scanning Shipment in Secondary Inspection:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Prior to the deployment of the current version of ACE, deployed in
2006, CBP did not receive advance e-Manifest on trucks crossing at
land POEs. As a result, decisions on whether to release, examine, or
detain a shipment had to be made at the primary inspection booth. With
the deployment of new technologies such as ACE, CBP officials told us
that officers spend less time manually inputting information, thereby
reducing inspection times and improving the accuracy of the collected
information. All of CBP's land border POEs are capable of receiving
and processing e-Manifests as part of ACE. Moreover, according to CBP
officials, more shipments are released at the primary inspection booth
as a result of ACE and advance information provided via e-Manifest.
The Lack of Space Hampers More Comprehensive Infrastructure
Improvements:
Despite the incremental infrastructure improvements discussed earlier,
CBP officials told us that limited space and equipment continue to
affect CBP's inspection of commercial vehicles and operations at the
six ports we visited. The Peace Bridge site is one of the busiest
commercial crossings between the United States and Canada, yet
existing border infrastructure at Peace Bridge contributes to a number
of crossing inefficiencies, according to CBP. The facility, which is
considered a large port, is located on 17 acres of land, as opposed to
the 80 acres that CBP recommends for a large POE (see figure 14).
According to CBP, the port does not have the space to handle the
number of vehicles referred for secondary inspections. The plaza is
spatially constrained and lacks the space needed for the enclosed
VACIS equipment to screen cargo vehicles in secondary inspections. As
a result, officers can screen one commercial vehicle at a time. CBP
officials told us that if the secondary inspection area is full, CBP
officers must hold vehicles referred for secondary inspection in the
primary lane, causing congestion and delays. In addition, we observed
that because of the configuration of the port, vehicles referred to
secondary inspections must cross paths with commercial vehicles
exiting the primary inspection area, which contributes to border
crossing inefficiencies and creates an obstructive intersection and
safety and security risks. CBP and GSA are planning to expand and
modernize the Peace Bridge Facility, but they have not yet requested
funding for the facility due to federal budgetary scorekeeping rules
governing leases.[Footnote 44] However, once funding is available, CBP
and GSA expect the design to be completed within 12 to 18 months and
construction within 24 to 36 months.
As another example, the Lewiston-Queenston POE was constructed in the
early 1960s and, with the exception of a few modifications (such as
the increase in lanes from four to five), has remained unchanged,
although security measures and traffic volume have increased over
time. CBP has concluded that the main building and commercial building
are too small to handle current operations and can no longer
accommodate either the traffic or the complexity of processing
operations required since 9/11. Specifically, CBP has concluded that
there are inadequate primary inspection lanes to process car and truck
traffic, the commercial inspection docks are undersized, and the
secondary processing facilities are dated. For example, CBP noted that
the work space is insufficient to accommodate existing staff and
operations. In addition, the work areas are small and overcrowded, and
there is no room for additional staff or functions. CBP and GSA are
planning to expand the Lewiston-Queenston Bridge Facility, but they
have not yet requested funding for the facility due to federal
budgetary scorekeeping rules governing leases. However, once funding
is available, CBP and GSA expect design to be completed within 12 to
18 months and construction within 24 months.
The Pacific Highway facility in Blaine, Washington, is one of the
largest POEs for cargo processing on the northern border, and has
three commercial inspection lanes. CBP managers stated that the
Pacific Highway crossing needs more lanes to increase throughput, but
the facility lacks the space needed to expand. According to CBP, there
is limited room to expand without acquiring additional property. In
addition to limited lanes, there is minimal staging area for trucks
waiting for secondary inspections. When this occurs, the placement of
VACIS causes backups. CBP officials told us that three trucks can
queue at once for VACIS scans. When more than three trucks are
referred to VACIS, CBP does not have space available on the plaza to
queue additional vehicles and traffic blocks the primary lanes.
Officials said this happens on a daily basis. As a result, when this
happens, CBP officers told us that the primary officer has to decide
whether to refer the shipment to secondary inspection, causing the
lanes to shut down, or to keep traffic moving, facilitating the flow
of commerce. According to CBP officials in Blaine, Washington, as the
economy improves, infrastructure constraints will exacerbate delays at
the port.
According to the Port Director at Port Huron, the lack of adequate
physical space and infrastructure adversely affects port operations.
CBP has concluded that the site size is inadequate to support
operations. Specifically, officials stated that the facility is too
small, with limited parking and space to off-load trucks, forcing
officers to escort trucks elsewhere to be searched. CBP officials
stated that they have to dedicate two staff to escort shipments to an
off-site location for unloading and inspection, which according to CBP
is a security risk and takes staffing resources away from other
critical port functions. Further, CBP officials explained that after
the construction of the new plaza and cargo inspection facility, CBP
will be able to inspect cargo on-site and will save on resources
devoted to escorting trucks to off-site facilities. CBP officials
stated and we observed that the facility has 22 inspection docks and
they are too small to meet the inspection needs of the POE. CBP
officers told us that the contents of a truck can take up the entire
length of all the docks. We observed that Port Huron's 12-acre
elevated inspection area, which sits 26 feet above ground, serves as
the on and off ramps for the Blue Water Bridge from Interstates 69 and
94. The port is surrounded by commercial and residential developments,
thus limiting CBP's ability to expand the plaza or add more lanes. CBP
and MDOT have initiated plans to renovate Port Huron to alleviate
congestion, reduce wait times, eliminate bottlenecks, and improve the
inspection capacity. CBP expects construction to begin in 2016, with
completion projected for 2019.
Moreover, CBP officials told us that although CBP recently made some
infrastructure improvements at the Ambassador Bridge Fort Street Cargo
facility, challenges remain. For example, due to limited physical
space, we observed that the placement of VACIS causes backups in
secondary inspections that slows throughput and the secondary RPM is
placed directly in front of the VACIS machine. In addition to the
location of the VACIS machine, all vehicles form one queue for
screening. As a result, a shipment referred to secondary inspection
for advanced RPM screening may be delayed if the VACIS machine is
being used. CBP officials also told us that a wall surrounding the
Ambassador Bridge Fort Street inspection plaza and the placement of
one of the primary inspection booths ("lane 10") limits access to the
dedicated FAST booths, as shown in figure 12. As a result, FAST trucks
have to form a single queue and curve around both the wall and lane 10
to access the four dedicated FAST booths. CBP officials told us that
they plan to improve access to the FAST lanes and increase throughput
by expanding the queuing space available by removing the wall.
Construction is expected to commence in September 2010 and completion
is scheduled for November 2010.
Figure 12: Truck Curving around Wall and Lane 10 to Access FAST Booths
Ahead:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Although CBP has a process for prioritizing infrastructure needs, it
faces challenges in addressing identified issues, according to CBP
officials responsible for infrastructure improvements. CBP works with
GSA to coordinate infrastructure projects with other stakeholders,
such as private bridge authorities and state departments of
transportation. The process for making capital improvement projects,
such as building new lanes or secondary inspection facilities, is
lengthy. According to CBP and GSA officials, the process for
submitting a request for an infrastructure improvement and completion
of the project is approximately 7 years. For example, CBP officials
told us that the Peace Bridge improvement project that occurred in
2005 took at least 5 years from start to completion. Prior to every
construction project, GSA conducts a feasibility study--the study
defines the project's scope, including the budget; the amount of land
required; the basic design; and the environmental challenges as well
as the community impact. GSA officials told us that they use the
results of the feasibility studies to justify the funding requests
submitted to the Office of Management and Budget (OMB). See figure 13
for GSA's land POE capital program delivery process.
Figure 13: GSA Land Port of Entry Capital Program Delivery Process:
[Refer to PDF for image: illustration]
Total time from feasibility study to construction: 7 years.
Year 1:
Facility needed/agency request:
Feasibility study phase.
Year 2-3:
Site/design phase:
A) Site/design prospectus;
B) Site/design prospectus to OMB;
C) Proposed site/design authorization to Congress;
D) Proposed site/design appropriation to Congress.
Year 4-5:
Program development study phase:
A/E selection predesign and Concepts.
Year 6:
Construction phase:
A) Construction prospectus;
B) Construction prospectus to OMB;
C) Proposed construction authorization to Congress;
D) Proposed construction appropriation to Congress; General contractor
selected.
Year 7:
Building construction.
A/E = Architect/Engineer.
OMB = Office of Management and Budget.
Source: GAO analysis of GSA information.
[End of figure]
Furthermore, CBP and GSA officials said that land constraints affect
their ability to make infrastructure improvements. For example, CBP
officials said that they have been discussing plans to expand the
Peace Bridge Facility for the past 10 years. Although CBP recognizes
that increasing the size of the Peace Bridge Inspection Facility is
necessary to address capacity issues, there is limited room adjacent
to the facility for expansion without affecting the surrounding
community. The facility sits on 17 acres and is confined on three
sides by the Niagara River, a historic park, and a residential
neighborhood. See figure 14 for an overhead view of the Peace Bridge
Facility. Further, the Port Huron Facility is scheduled for renovation
starting in fiscal year 2016 with completion in 2019. Due to the lack
of space for expansion, CBP officials told us that MDOT used eminent
domain law--the government's power to take private property for a
public use while fairly compensating the property owner--to purchase
nearby homes and businesses to acquire land for the plaza expansion
project.
Figure 14: Overhead View of Peace Bridge Facility in Buffalo, New York:
[Refer to PDF for image: photograph]
The following are indicated with labels on the photograph:
Peace Bridge;
Niagara River;
Interstate I-190;
Buffalo Land Port of Entry;
Park;
Residential Community.
Source: Peace Bridge Authority.
[End of figure]
According to GSA officials, securing funding for infrastructure
projects is also dependent on the annual budget cycle. On average, it
takes about 18 months to obtain funding for large projects after GSA
submits its proposal to OMB for approval. GSA officials also told us
that they may not get the full amount of funds requested for
infrastructure projects due to competing priorities, which affects
their ability to make infrastructure changes, such as resizing the
roads leading to the POEs. Table 2 provides information on GSA funding
requests and appropriations for the POE capital investment and leasing
program for fiscal years 2003 through 2010. Additionally, CBP and GSA
officials said that they have to coordinate with multiple
stakeholders, including city and state governments, to address
infrastructure needs because the bridges and roads leading to the POEs
are owned by private entities or state governments. GSA officials
noted that coordinating with multiple stakeholders to address
infrastructure issues can be time consuming.
Table 2: GSA Funding Requests and Appropriations for Capital
Investment and Leasing Program for Land Ports of Entry, Fiscal Years
2003 through 2010:
Fiscal year: 2003;
Funding: Requests: $33,075,000;
Funding: Appropriation: $37,075,000.
Fiscal year: 2004;
Funding: Requests: $186,037,000;
Funding: Appropriation: $182,037,000.
Fiscal year: 2005;
Funding: Requests: $84,973,000;
Funding: Appropriation: $84,973,000.
Fiscal year: 2006;
Funding: Requests: $211,761,000;
Funding: Appropriation: $211,761,000.
v2007;
Funding: Requests: $96,539,000;
Funding: Appropriation: $100,397,000.
Fiscal year: 2008[A];
Funding: Requests: $154,688,000;
Funding: Appropriation: $339,509,000.
Fiscal year: 2009[B];
Funding: Requests: $374,114,000;
Funding: Appropriation: $374,114,000.
Fiscal year: 2010;
Funding: Requests: $151,129,000;
Funding: Appropriation: $151,129,000.
Total:
Funding: Requests: $1,292,316,000;
Funding: Appropriation: $1,480,995,000.
Source: GAO analysis based on data from GSA.
[A] The total fiscal year 2008 appropriation includes $225,000,000 in
Emergency Designation funding.
[B] The total fiscal year 2009 appropriation includes $300,000,000
appropriated under the American Recovery and Reinvestment Act of 2009.
[End of table]
CBP Lacks Data to Assess the FAST Program, but CBP, Selected
Importers, and Trade Organizations Report Generally Favorable Reviews
Where Infrastructure Is Available:
CBP Lacks the Data to Assess Whether FAST Participants Are
Experiencing Intended Benefits, but Is Taking Action to Collect the
Data:
Although CBP established the FAST program to expedite cargo processing
for low-risk shippers and uses the program as a tool to help focus its
inspections, targeting resources on areas of greatest risk, it lacks
the data needed to determine whether the FAST program is effective
because it collects incomplete data on FAST shipments. Moreover, data
collected by CBP on primary and secondary inspections for a subset of
the FAST population do not allow it to determine whether all FAST
participants experience reduced wait times to reach primary
processing, are less frequently referred to secondary inspections, or
receive "front-of-the-line" benefits.[Footnote 45] The FAST program is
intended to provide, among other things, (1) access to dedicated lanes
(where available) to increase the speed and efficiency of clearing the
border, (2) fewer referrals to secondary inspections for FAST
participants, and (3) front-of-the-line processing (i.e., priority in
the inspection queue) for CBP inspections.[Footnote 46] Additional
details on the data limitations to assess access to dedicated lanes,
fewer referrals to secondary inspections, and front-of-the-line
benefits for FAST participants are discussed below.
Access to Dedicated FAST Lanes:
Seven of 122 northern border POEs had dedicated FAST lanes, which
accounted for approximately 54 percent of the volume of commercial
traffic along the northern border in 2009. See figures 15 and 16 for
examples of a dedicated FAST lane at the Pacific Highway crossing in
Blaine, Washington, and in Port Huron, Michigan, respectively.
However, CBP is unable to monitor wait times for FAST shipments using
dedicated lanes to determine if the shipments are experiencing reduced
wait times in reaching primary processing because of data limitations
and other factors. CBP reported that wait times for FAST lanes at
individual ports were shorter than those for non-FAST lanes. However,
because dedicated FAST lanes are sometimes used for regular commercial
traffic during periods of heavy volume, the data collected at the
individual POE level for FAST dedicated lane wait times are less
useful for comparison. For example, at the Pacific Highway crossing in
Blaine, Washington, CBP officials said that when wait times exceed 1
hour, they open the FAST lane to all commercial traffic. Similarly, at
the Port of Detroit, CBP has the ability to adjust the FAST lanes and
open them to non-FAST traffic on a temporary basis. Moreover, the CBP
officials stated that if the FAST lane is empty, the Port Director has
discretion in determining whether to allow non-FAST shipments to use
the lane (e.g., livestock shipments or FAST drivers not carrying a
FAST load).
Figure 15: A Dedicated FAST Booth at the Pacific Highway Crossing in
Blaine, Washington:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
Figure 16: A FAST-Dedicated Booth in Port Huron, Michigan:
[Refer to PDF for image photograph]
Source: GAO.
[End of figure]
Fewer Referrals to Secondary Inspections:
The data CBP collects that could be used to determine whether FAST
participants experience reduced wait times at primary processing and
fewer referrals to secondary inspections are limited because CBP does
not differentiate between all FAST and non-FAST shipments. DHS noted
that dedicated FAST lanes enable greater processing efficiency,
thereby reducing queue lengths and wait times. DHS stated that lanes
dedicated to FAST have average primary processing times of 30 seconds
versus non-FAST lanes at 2 minutes. However, as explained below, these
averages account for approximately 38 percent of FAST participants.
The ACE system, through which data on commercial shipments are
collected by CBP, captures data on the NCAP and PAPS manifest types.
The NCAP manifest is available to select FAST shipments mostly related
to the auto industry. A majority of FAST shipments are processed under
the PAPS manifest type. However, the PAPS manifest is not confined to
the FAST program so shipments processed using the PAPS manifest
include both FAST and non-FAST shipments. If a FAST shipment is
processed using PAPS, the ACE system uses information submitted on the
electronic manifest to determine whether the shipment meets all the
conditions of the FAST program (e.g., the driver has a FAST card and
the carrier and importer are C-TPAT certified). If these conditions
are met and the shipment is eligible for FAST, ACE displays a green
flag to the officer processing the shipment in the primary lane.
Although the purpose of this process is to speed processing for
shipments, ACE does not save this information so it cannot be used to
assess processing times for all FAST versus non-FAST shipments. The
ACE system also uses information in the manifests to help determine
the need for secondary screening, but for the same reasons discussed
above, the system does not collect information on the number of
secondary screenings for all FAST versus non-FAST shipments.
Consequently, CBP is unable to determine whether the program provides
all participants with the intended benefits of reduced primary
processing times and fewer referrals to secondary inspections.
CBP acknowledged that the ACE system needs to be modified so that it
can monitor and record FAST primary processing times and the number of
referrals to secondary inspections more effectively. CBP began to
consider enhancing ACE to better differentiate between FAST and non-
FAST shipments in 2008 and estimates that the software changes would
cost about $122,000.[Footnote 47] However, senior CBP officials said
that the project remains unfunded due to other priorities. While we
recognize that CBP has competing priorities and that assessing a
program's impact or benefit is often difficult, determining whether a
program achieves its intended results can provide important
information about the program's progress and be used as a basis for
determining whether adjustments are needed to ensure its long-term
success. Further, a senior CBP official, Chief of Cargo Operations,
stated that CBP has not yet established timelines or milestones for
completing the ACE enhancement project to capture data for all FAST
participants because officials have not identified a source of
funding. Standard practices for project management established by the
Project Management Institute state that managing a project involves,
among other things, developing a timeline with milestone dates to
identify points throughout the project to reassess efforts under way
to determine whether project changes are necessary.[Footnote 48]
Establishing timelines or milestones for completing the enhancement to
ACE could help ensure that CBP's actions are implemented as planned so
that it is better positioned to begin collecting the data necessary to
determine whether FAST shipments are receiving the intended benefits
of the program--shorter primary processing times and fewer referrals
to secondary inspections. Additionally, although CBP stated that once
ACE is modified to collect data on all FAST participants, the data may
be useful for measuring program benefits, CBP has no plans to conduct
a study on whether the benefits are being realized. Our previous work
identified program evaluations or similar studies as a way for
agencies to explore the benefits of a program as well as ways to
improve program performance.[Footnote 49] Therefore, using this
information to conduct a study would enable CBP to determine if the
benefits are experienced by all FAST participants and what program
adjustments, if any, may be needed.
Front-of-the-Line Processing for CBP Inspections:
Moreover, CBP does not collect data on whether FAST shipments that are
sent to secondary inspections receive priority in the inspections
queue, known as front-of-the-line benefits. CBP officials in
headquarters said the ACE enhancement project will not allow CBP to
capture data on front-of-the-line benefits and there are no current
plans to capture these data. CBP officials stated that front-of-the-
line benefits may vary based on the infrastructure at the POE, traffic
volume, and the type of exam needed (e.g., paperwork issue or physical
inspection/unloading). Moreover, according to CBP officials, space
constraints in secondary inspection areas limit their ability to
provide front-of-the-line benefits to all FAST participants. For
example, CBP officials at the Pacific Highway crossing told us that
due to space constraints on the plaza, they cannot move FAST shipments
to the front of the line for VACIS screenings. However, in some
instances, FAST members receive priority processing for paperwork
issues, but they have to wait in line for other types of inspections,
such as physical inspections or VACIS screening due to infrastructure
issues. CBP is working to address challenges it is facing related to
infrastructure constraints, and until there are results, CBP will not
be able to develop a standard data collection method for front-of-the-
line benefits because of the variations in infrastructure across POEs.
Collecting data on the FAST program could better position CBP to gauge
program effectiveness and determine what program adjustments, if any,
are needed. Standards for Internal Control in the Federal Government
requires that all transactions be clearly documented in a manner that
is complete, accurate, and useful for managers and others involved in
evaluating operations.[Footnote 50] Moreover, internal control
standards call for agencies to establish policies and procedures to
ensure the validity and reliability of data. We previously reported
that leading organizations promote accountability by establishing
results-oriented goals and corresponding performance measures by which
to gauge progress.[Footnote 51] Having better information with which
to assess program effectiveness would help CBP in making management
decisions on the program and would enable CBP management to report to
participants and potential future participants whether the benefits of
the program are being realized. This information would help
participants determine whether to join or remain in the program.
CBP and Participants in FAST That We Interviewed Have Generally
Favorable Reviews of the Program, but Report That Infrastructure
Issues May Limit the Benefits Received:
CBP and 8 of 11 importers and trade organizations that we interviewed
have expressed generally favorable views of the program, but stated
that infrastructure challenges may limit the benefits received.
According to CBP officials, the FAST program helps the agency meet its
goal of securing borders while promoting legitimate trade by pre-
vetting drivers and securing the supply chain, which allow CBP to
focus its resources on high-risk shipments. For example, CBP officials
in Port Huron, Michigan, told us that the FAST program is beneficial
to CBP because it facilitates the processing of low-risk shipments,
and improves the flow of traffic by reducing congestion on the Blue
Water Bridge. CBP officials at the Port of Detroit and Port Huron also
noted that FAST participants benefit from the FAST program with faster
primary processing and front-of-the-line benefits. Moreover, officials
we spoke to representing "The Big 3" automakers--Ford, GM, and
Chrysler[Footnote 52]--are generally satisfied with the FAST program,
and noted that FAST is a vital program that decreases border delays
while ensuring a more secure supply chain. For example, these
officials stated that they receive fewer referrals to secondary
inspections, and told us that when their shipments are referred to
secondary inspection they generally receive priority processing.
Additionally, five trade organizations, such as the Detroit Regional
Chamber of Commerce, American Trucking Alliance, and customs brokers,
noted that certain intended benefits are met, including fewer
inspections.
However, these groups raised concerns about infrastructure
constraints. CBP officials said that FAST program benefits may be
limited due to infrastructure constraints at land POEs. As previously
discussed, only 7 of 122 northern border POEs have dedicated FAST
lanes. Further, officials from 7 of 10 trade organizations and
importers, such as the Canadian Trucking Alliance, the U.S. Chamber of
Commerce, the Detroit Regional Chamber, and Customs Brokers and
Forwarders, as well as officials from 7 of 13 border stakeholders we
spoke with, such as bridge commissions, stated that CBP lacks the
infrastructure needed to successfully implement the FAST program. For
example, American Trucking Association officials told us that a
challenge trucking companies continue to face is the lack of dedicated
lanes leading to the POE so that FAST traffic is not commingled with
non-FAST traffic. As a result, FAST shipments do not receive priority
treatment due to non-FAST and FAST shipments commingling on the bridge
as well as in the plaza and infrastructure constraints at the POEs.
CBP officials acknowledge that due to infrastructure constraints they
are unable to provide dedicated FAST lanes at certain locations, such
as the Peace Bridge and Lewiston facilities in Western New York. These
constraints also make access to existing FAST booths difficult. As
previously discussed, access to the dedicated FAST lanes at the
Ambassador Bridge Fort Street Cargo Facility is limited due to the
placement of lane 10 and a wall surrounding the inspection plaza, as
shown in figure 17. Due to these infrastructure constraints, FAST
trucks have to form a single queue to access the four dedicated FAST
booths, resulting in reduced throughput and increased delays.
Figure 17: FAST Truck Curving around Lane 10 and Heading toward
Dedicated FAST Booths Ahead:
[Refer to PDF for image photograph]
Source: GAO.
[End of figure]
Further, the Pacific Highway crossing in Blaine, Washington, has three
commercial lanes with one dedicated FAST lane and limited space for
expansion due to residential development and the international border.
Although the Pacific Highway crossing has a dedicated FAST lane, CBP
officials told us that when wait times exceed 1 hour, they open the
FAST lane to all commercial traffic to mitigate congestion. As a
result, FAST trucks are commingled with non-FAST traffic. CBP
officials also stated that due to limited space for queuing in the
secondary inspection area, they are unable to provide FAST shipments
with priority processing for VACIS screening.
Additionally, 10 of the 23 importers, trade organizations, and border
stakeholders we interviewed voiced concerns about the FAST program.
These concerns included the costs of enrollment as well as FAST
program policy issue such as shipment restrictions and the appeals
process for security incidents.
* Officials from the American Trucking Alliance and five other trade
organizations, such as the Canadian Trucking Alliance and National
Customs Brokers and Forwarders Association, stated that smaller and
medium-sized companies may not be able to afford the cost associated
with C-TPAT compliance. While the enrollment cost of the FAST program
is $50 for the driver card, FAST participants are also required to be
certified under C-TPAT. According to CBP, the potential cost of
implementing security measures to comply with C-TPAT varies by the
size of the company as well as the types of security measures
implemented. CBP officials stated that the cost for a company to
become C-TPAT certified will vary because the cost of securing the
supply chain varies depending on the size of the company or security
measures needed.
* Six importers and trade organizations raised concerns about the
restrictions on carriers that are transporting goods from multiple
shippers that, in total, are less than the size of one truckload
(called less-than-truckload shipments or LTL). CBP officials explained
that LTL shipments are allowed to use the FAST lane provided each of
the shippers are C-TPAT-certified members and all other FAST
requirements are met. CBP stated that this policy ensures that LTL
shipments using the FAST lane have completed a strict security review
by participating member companies. Further, according to CBP, it needs
to maintain a balance between facilitating trade and security.
Therefore, CBP restricts LTL shipments from using the FAST lane if all
of the shippers are not C-TPAT-certified members because the entire
shipment is not pre-vetted and deemed low risk.
* Four importers and trade organizations noted that CBP immediately
suspends a member's FAST privileges if a driver is involved with a
security incident until the results of the investigation are final.
CBP officials stated that the agency immediately revokes all program
privileges following the security violation rather than after the
investigation and imposes program restrictions to secure the supply
chain and maintain the integrity of the program. According to CBP, on
average, it takes about 15 days to conduct the post incident analysis
in coordination with other law enforcement agencies to determine where
the breakdown in the supply chain occurred. CBP officials said that if
a member is suspended after the investigation, the member may appeal
this decision to CBP headquarters. According to CBP, in general,
members are provided with the opportunity to prepare a corrective
action plan, which is subject to physical confirmation that all
identified vulnerabilities have been addressed. For example, in 2009,
CBP suspended or removed 82 members, 57 of which were reinstated.
However, CBP officials explained that in some instances, a company may
be permanently removed from the program for providing false
information or for repetitive security violations. Further, CBP
officials emphasized that members are informed of the appeals and
suspension process, and the information is provided on CBP's Web site.
Conclusions:
Canada is the United States' largest single trading partner, and
economists expect trade between the two countries to increase as the
economy improves. As such, achieving an effective balance between
facilitating legitimate trade and travel and performing the
inspections needed to secure the U.S. border is critical to the
security and economy of the United States. Further, CBP has taken
steps to address some of the infrastructure needs of its aging
northern border POEs and recognizes the continued need for
improvements to speed the flow of traffic. These improvements are
particularly important in light of projections regarding the increase
in trade between Canada and the United States. Cooperative U.S.-Canada
efforts to increase the flow of legitimate trade and travel and
improve border security, such as the FAST program, are promising, and
CBP and participants we interviewed generally believe the program is
helpful where infrastructure is sufficient. While CBP is taking
actions to collect data on the FAST program in the ACE database, CBP
has not established milestones to complete the enhancement for FAST
data collection. Establishing milestones for completing the
enhancement to ACE could help ensure that CBP's actions are
implemented as planned so that it is better positioned to begin
collecting the data necessary to determine whether FAST shipments are
receiving the intended benefits of the program--shorter primary
processing times and fewer referrals to secondary inspections.
Moreover, once CBP completes the enhancement to the ACE database,
using this information to conduct a study would enable CBP to
determine if the benefits are experienced by all FAST participants and
what program adjustments, if any, are needed.
Recommendations for Executive Action:
To enhance DHS's ability to assess the effectiveness of the FAST
program, we recommend that the Commissioner of CBP take the following
two actions:
* Develop and meet milestones for completing the enhancement of the
ACE database to capture data on the intended benefits of the FAST
program.
* Once the database is modified, use the data collected to conduct a
study to determine whether the FAST program is achieving its intended
benefits.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS, Commerce, DOT, GSA, and HHS
for review and comment. DHS provided written comments on July 9, 2010,
which are reprinted in appendix I. In commenting on the draft report,
DHS stated that it agreed with the two recommendations in this draft
and identified corrective actions it has planned or under way to
address them.
DHS's comments also raised three issues regarding our findings. First,
DHS stated that its current approach to measuring wait times shows
that those drivers using FAST lanes experience shorter wait times.
While average wait times for FAST lanes may be shorter than average
wait times for regular commercial lanes, as indicated in the report,
we found that the wait times reported for FAST lanes do not
necessarily reflect participants' wait times as dedicated lanes may be
used by FAST and non-FAST participants. Moreover, we reported that
because CBP's wait times are estimated using approximations of varying
reliability at selected POEs, the data cannot be used for analyses
across ports, and the methods of collection raise questions about the
reliability of the overall data.
Second, DHS commented that the discrepancies in wait times reported
between CBP, trade organizations, and importers may be attributed to
the different measures and definitions used to estimate wait times. We
acknowledge there could be a variety of reasons for the discrepancies
in wait times reported by CBP, trade organizations, and importers.
However, CBP's observation further supports our conclusion that using
a consistent methodology, standard formula, and automation could
increase the accuracy and reliability of the wait times data collected.
Third, DHS stated that CBP primary officers at the primary inspection
point can only add the driver and trailer information to a FAST/NCAP
manifest, and not the quantity of shipment. We revised the draft
report to reflect this information.
We received written comments from Commerce on July 2, 2010, in which
it concurred with our report. These comments are reprinted in appendix
II. DHS and DOT also provided technical comments, which we
incorporated in the report as appropriate. In addition, we received e-
mails from the GSA liaison on June 2, 2010, and the HHS liaison on
June 29, 2010, in which they notified us that they had no comments on
the draft report.
We are sending copies of this report to the Secretaries of Commerce,
Health and Human Services, Homeland Security, and Transportation; the
Administrator of GSA; and interested congressional committees as
appropriate. The report also is available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-8777 or stanar@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are
listed in appendix III.
Sincerely yours,
Signed by:
Richard M. Stana:
Director, Homeland Security and Justice Issues:
[End of section]
Appendix I: Comments from the Department of Homeland Security:
U.S. Department of Homeland Security:
Washington, DC 20528:
July 9, 2010:
Mr. Richard M. Stana:
Director, Homeland Security and Justice Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Stana:
Thank you for providing us with a copy of the Government
Accountability Office's (GAO) draft report entitled, "BORDER SECURITY:
CBP Lacks the Data Needed to Assess the Free and Secure Trade (FAST)
Program and U.S. Northern Border Ports" (GAO-10-694). U.S. Customs and
Border Protection (CBP) concur with the recommendations and offer the
following comments.
The GAO incorporated earlier feedback from CBP by including a comment
that "wait times for FAST lanes at individual ports were shorter than
those for non-FAST lanes." However, the GAO continues to state that
"because dedicated FAST lanes are sometimes used for regular
commercial traffic during periods of heavy volume, the data collected
at the individual ports of entry (POE) level for FAST dedicated lane
wait times is less useful for comparison." GAO goes on to provide the
example that "at Pacific Coast Highway crossing in Blaine, Washington,
CBP officials said that when wait times exceed 1 hour, they open the
FAST lane to all commercial traffic." Doing that would only add to the
wait time at the dedicated FAST lane at the Pacific Coast Highway
crossing, yet during all of FY09 the average wait time at
the FAST lane was less than 1 minute, while the average wait time at
the regular commercial lanes was nearly 9 minutes. GAO accurately
documents CBP's challenges of measuring wait times, but CBP believes
its current approach to measuring wait times clearly shows that those
drivers using FAST lanes experience shorter wait times.
The report also discusses the discrepancies in wait times reported
between CBP, trade organizations and importers. These discrepancies
can also be attributed to the fact that different measures/definitions
of wait times are employed. CBP measures wait times from end of queue
to primary booth. Trade organizations and importers use total crossing
times to define border wait times, which includes vehicle queue time,
primary processing time/dwell time, state inspection processing,
etc.). The lack of a standardized "wait time" definition has been an
ongoing issue between border agencies and trade organizations.
Finally, the report infers that all information not collected on a
FAST/NCAP (National Customs Automation Program) manifest can be added
by CBP Officer on primary. This is not accurate. The CBP Officers can
only add driver information and trailer plate information. They cannot
add any of the missing shipment data such as piece count. These are
added by the broker when the entry summary is filed, up to 10 days
after crossing, or the broker will file the entry information if the
shipment is sent to secondary for trade enforcement.
Thank you for the opportunity to comment on this Draft Report and we
look forward to working with you on future homeland security issues.
Sincerely,
Signed by:
Jerald E. Levine:
Director:
Departmental GAO/OIG Liaison Office:
[End of section]
Appendix II: Comments from the Department of Commerce:
United States Department Of Commerce:
The Under Secretary for International Trade:
Washington. D.C. 20230:
July 12, 2010:
Mr. Richard Stana:
Director, Homeland Security and Justices Issues:
U.S. Government and Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. Stana:
Thank you for forwarding the draft report titled, "Border Security:
CBP Lacks the Data Needed to Assess the FAST Program at U.S. Northern
Border Ports," GAO 10-694. The International Trade Administration
(ITA) concurs with the report and does not have any comments.
We appreciate the opportunity to provide comments on the draft report.
If you have any questions or comments about ITA's review of the draft,
please contact Victor E. Powers, Director, Office of Management and
Operations, at (202) 482-5436.
Sincerely,
Signed by:
Francisco J. Sanchez:
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Richard M. Stana, (202) 512-8777 or stanar@gao.gov:
Acknowledgments:
In addition to the contact named above, Susan Quinlan, Assistant
Director, and Minty M. Abraham, Analyst-in-Charge, managed this
assignment. David P. Alexander, Avrum I. Ashery, Chuck Bausell,
Frances Cook, Peter DelToro, Lara Kaskie, Alana R. Miller, Madhav S.
Panwar, and Mark Ramage made significant contributions to the report.
[End of section]
Footnotes:
[1] This figure includes the distance of the entire U.S.-Canada
border, including the border between Canada and Alaska.
[2] U.S. Department of Commerce, U.S. Census Bureau.
[3] U.S. Department of Transportation, Research and Innovative
Technology Administration, Bureau of Transportation Statistics.
[4] This forecast did not foresee the recession that began in 2007.
DOT expects to have an updated forecast by the end of fiscal year 2010.
[5] GAO, Department of Homeland Security: Progress Report on
Implementation of Mission and Management Functions, [hyperlink,
http://www.gao.gov/products/GAO-07-454] (Washington, D.C.: Aug. 17,
2007).
[6] GAO, Border Security: Despite Progress, Weaknesses in Traveler
Inspections Exist at Our Nation's Ports of Entry, [hyperlink,
http://www.gao.gov/products/GAO-08-219] (Washington, D.C.: Nov. 5,
2007).
[7] GAO, Shared Border Management: Various Issues Led to the
Termination of the United States-Canada Shared Border Management Pilot
Project, [hyperlink, http://www.gao.gov/products/GAO-08-1038R]
(Washington, D.C.: Sept. 4, 2008).
[8] Secondary inspections occur when a vehicle is referred by the
primary line officer for further inspection, including X-ray scans,
paperwork, and physical examinations.
[9] One hundred and twenty-two of 166 land border POEs are along the
northern border and are operated by CBP; the majority of these are
owned by GSA while the remainder are owned by CBP.
[10] At a POE location, CBP officers secure the flow of people and
cargo into and out of the country, while facilitating travel and trade.
[11] The SRA is an assessment that identifies capital needs at POEs by
evaluating existing facility conditions, predicting future workload
trends, performing space capacity analyses, and estimating costs for
the recommended options.
[12] Primary inspections occur at the border inspection booth by a
primary line officer. Secondary inspections occur when a vehicle is
referred by the primary line officer for further inspection, including
X-ray scans, paperwork, and physical examinations.
[13] GAO, Standards for Internal Control in the Federal Government,
[hyperlink, http://www.gao.gov/products/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, provide the overall framework for establishing and maintaining
internal control in the federal government.
[14] U.S. Chamber of Commerce, Finding the Balance: Shared Border of
the Future (Washington, D.C., 2009); International Trade and
Investment Center, Reaching a Tipping Point? Effects of Post-9/11
Border Security on Canada's Trade and Investment (Canada, 2007); and
Ontario Chamber of Commerce, Cost of Border Delays to the United
States Economy (Ontario, Canada, 2005).
[15] Fiscal year 2003 is the first full year data are available on the
FAST program.
[16] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00.21.3.1], and
the Project Management Institute, The Standard for Program Management©
(2006).
[17] H.R. Rep. No. 108-774, at 43 (2004) (Conf. Rep.).
[18] Pub. L. No. 110-161, div. E, § 604, 121 Stat. 1844, 2095-96
(2007) (codified at 6 U.S.C. § 1403).
[19] 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).
[20] Pub. L. No. 111-5, 123 Stat. 115, 149, 162 (2009).
[21] H.R. Rep. No. 109-699, at 126 (2006) (Conf. Rep.).
[22] Pub. L. No. 109-347, § 403, 120 Stat. 1884, 1926-28 (codified at
19 U.S.C. § 2075(h)).
[23] The entry document (e-Manifest) contains information about a
shipment, including the shipment type, conveyance, passenger/crew, and
equipment.
[24] CBP uses various databases, including the Automated Targeting
System (ATS), Automated Commercial System, and local Advance Targeting
Units (ATU) to screen and assign risk levels to travelers and cargo
entering the United States.
[25] For the purpose of this report, we focused on commercial-truck
crossings.
[26] According to CBP, officers select shipments for targeted
inspection based on several factors, including training received in
the cargo selectivity and cargo review environment. 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
ATS or ACE 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.
[27] Prior to the primary inspection booths, CBP also screens
commercial traffic using RPMs to detect nuclear and radiological
materials.
[28] The benefits of C-TPAT include a reduced number of inspections
and reduced border wait times, self-policing and self-monitoring of
security activities, and a C-TPAT supply chain specialist to serve as
the CBP liaison for validations.
[29] For more information on the C-TPAT program, see GAO, Supply Chain
Security: U.S. Customs and Border Protection Has Enhanced Its
Partnership with Import Trade Sectors, but Challenges Remain in
Verifying Security Practices, [hyperlink,
http://www.gao.gov/products/GAO-08-240] (Washington, D.C.: Apr. 25,
2008).
[30] GAO, Supply Chain Security: CBP Works with International Entities
to Promote Global Customs Security Standards and Initiatives, but
Challenges Remain, [hyperlink, http://www.gao.gov/products/GAO-08-538]
(Washington, D.C.: Aug. 15, 2008).
[31] CBP measures waits time at the most traveled land border POEs,
and at other ports with known sporadic periods (i.e., seasonal peaks)
of increased wait times.
[32] TECS, formerly known as the Treasury Enforcement Communications
System, is owned by CBP and maintains lookout (i.e., watch list) data,
interfaces with other agencies' databases, and is currently used by
CBP officers at POEs to verify traveler information and update
traveler data.
[33] The NEXUS program allows registered border residents and frequent
cross-border travelers identified as low-risk individuals access to
dedicated lanes and expedited processing with minimal inspection.
[34] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[35] GAO, Observations on Implementing the Western Hemisphere Travel
Initiative. [hyperlink, http://www.gao.gov/products/GAO-08-274R]
(Washington, D.C.: Dec. 20, 2007).
[36] U.S. Chamber of Commerce, Finding the Balance; International
Trade and Investment Center, Reaching a Tipping Point?; and Ontario
Chamber of Commerce, Cost of Border Delays to the United States
Economy.
[37] The Brookings Institution, Toward a New Frontier Improving the
U.S.-Canadian Border (Washington, D.C., 2009).
[38] For more information on CBP's Workload Staffing Model, see GAO-08-
219.
[39] In May 2010, CBP stated that it has initiated efforts to enhance
the Workload Staffing Model by, among other things, incorporating
information about each port's current and planned facility
infrastructure and the associated staffing to provide coverage across
the facility; researching staffing approaches of other DHS components
to incorporate best practice modeling techniques; and validating the
current assumptions in the model pertaining to work activities, work
efforts, and data sources. CBP expects to complete the validation
efforts by the end of the summer of 2010.
[40] [hyperlink, http://www.gao.gov/products/GAO-08-219].
[41] Further, CBP has not yet implemented OJT guidance for cargo
processing. CBP officials said that cargo processing is an advanced
assignment, and officers are trained when they are assigned to perform
that function. As a result, training on cargo processing varies across
POEs. CBP has initiated plans to develop and deploy specific on-the-
job guidance and training modules that will be tailored to the
specific operational environment, such as land border cargo primary
and secondary processing, but CBP stated that the development of the
training has not yet started. CBP officials estimate that the project
will be completed by late fiscal year 2010, and implementation is
scheduled for fiscal year 2011.
[42] According to CBP, their analysis includes the collection of
additional information from operational personnel at the port
locations to identify existing regional or local conditions that might
affect the initial facility ranking.
[43] In the interim, the Lewiston-Queenston Bridge facility is
scheduled to receive $1 million in fiscal years 2010 and 2011 to
renovate the administration building, build a new secondary processing
area, and make other improvements.
[44] The Peace Bridge is a GSA-leased facility, and its development
and modernization are subject to capital lease scoring. The federal
budgetary scorekeeping rules, which are implemented primarily through
Office of Management and Budget Circular No. A-11, require the full
cost of construction to be recorded up front in the budget. Budget
scorekeeping is the process of estimating the budgetary effects of
pending and enacted legislation and comparing them with limits set in
the budget resolution or legislation. Scorekeeping tracks data such as
budget authority, receipts, outlays, the surplus or deficit, and the
public debt limit.
[45] According to CBP, the front-of-the-line examination privilege
applies to all C-TPAT shipments regardless of whether they are FAST
shipments and to the extent possible and practicable in each port. CBP
does not believe it is feasible to track this benefit at this time due
to current port infrastructure and resource issues.
[46] For the purpose of this review, we focused on three FAST program
benefits that are pertinent to processing at land POEs. Other benefits
of the FAST program include enhanced supply chain security while
protecting the economic prosperity of the United States, Mexico, and
Canada; the knowledge that carriers are transporting shipments for an
approved C-TPAT importer; and using the FAST driver card as a Western
Hemisphere Travel Initiative--compliant document.
[47] CBP officials said they did not consider enhancing ACE to capture
all FAST data prior to 2008 because they were overcome by events and
other priorities.
[48] The Project Management Institute, The Standard for Program
Management.
[49] GAO, Secure Border Initiative: Technology Deployment Delays
Persist and the Impact of Border Fencing Has Not Been Assessed,
[hyperlink, http://www.gao.gov/products/GAO-09-896] (Washington, D.C.:
Sept. 9, 2009).
[50] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1].
[51] GAO, Executive Guide: Effectively Implementing the Government
Performance and Results Act, [hyperlink,
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June
1996).
[52] The Big 3, along with two other companies (Delphi and Bosch) use
the NCAP manifest. They account for approximately 38 percent of all
FAST shipments.
[End of section]
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