U.S. Customs and Border Protection’s (CBP) Air and Marine Operation’s (AMO) aviation assets are critical tools for carrying out its interdiction capabilities and surveillance missions. Failure to successfully acquire and deploy aviation assets and associated technology could hamper AMO’s ability to fulfill its mission.
As of November 2020, AMO managed an inventory of 236 aircraft. AMO has 14 types of aviation assets, including unmanned, rotary-wing, and fixed-wing aircraft. In 2006, AMO initiated its Strategic Air and Marine program (StAMP) to replace aging aviation and marine assets.
A new report from the Office of Inspector General (OIG) says CBP has not effectively managed its aviation fleet acquisitions to meet operational mission needs. The watchdog found that AMO acquired and deployed 16 multi-role enforcement aircraft (MEA) that did not contain the necessary air and land interdiction capabilities to perform its mission. In addition, OIG determined that AMO initiated the MEA and medium lift helicopter programs without well-defined operational requirements and key performance parameters, both of which are critical items in the acquisition planning process.
The August 9 report says this occurred because CBP did not provide oversight and guidance to ensure AMO acquisition personnel followed key steps required by the Department of Homeland Security (DHS) Acquisition Lifecycle Framework. As a result, OIG found that AMO expended approximately $330 million procuring MEA that, at the time of acceptance, did not effectively respond to emergent air threats along the northern or southern borders, and experienced schedule delays deploying the medium lift helicopter.
In addition, the audit found AMO did not effectively manage the test and evaluation process for the MEA. DHS acquisition policy requires a component to perform operational tests during the “Obtain” phase to demonstrate an aircraft’s operational effectiveness and suitability prior to full rate production. However, OIG said AMO did not test the MEA for air-to-air interdiction capability due to “system immaturity” and ignored undesirable land-interdiction test results.
The watchdog said AMO has taken steps to improve management of its aviation fleet acquisitions to obtain solutions to its mission needs, but points out that continued oversight and effective guidance is required to prevent aviation acquisitions taking longer to deliver, at a greater cost, and without needed capabilities.
CBP was critical of OIG’s report and said it demonstrated a “significantly uninformed understanding of DHS’ Acquisition Lifecycle Framework and relied on outdated documentation, resulting in an overly negative conclusion about the cost and success of the MEA acquisition”. Specifically, CBP asserted that the original Operational Requirements Document for the MEA program was not explicit and allowed the program manager discretion to develop a path forward based on experience and lessons learned over time.
CBP also strongly disagreed with OIG’s conclusion that AMO did not effectively manage the MLH acquisition program. CBP admitted that, although key performance parameters were not well-defined in the original 2008 Operational Requirements Document, they were amended in 2019 to meet DHS’ Joint Requirements Integration and Management System (JRIMS) requirements. According to CBP, the only programmatic delays were in response to new requirements from the Federal Aviation Administration.
In addition, CBP said the audit was neither timely nor current, as it took almost 2.5 years from the announcement date of October 26, 2018. According to CBP, the draft report does not accurately describe the efforts and improvements that have gone into the management of CBP’s aviation fleet acquisitions.
OIG maintained its concerns were warranted and made four recommendations which it believes will improve AMO’s acquisition management of its aviation fleet to meet operational needs:
- CBP’s Component Acquisition Executive should update its acquisition policy to include a formalized process for developing operational requirements, all key requirements from DHS’ Acquisition Lifecycle policy, and alignment with DHS guidance.
- CBP’s Component Acquisition Executive should review the Multi-Role Enforcement Aircraft and the Medium Lift Helicopter programs to ensure they comply with all DHS Acquisition Lifecycle requirements. Specifically, CBP’s Component Acquisition Executive should determine whether the Acquisition Program Baseline for the Medium Lift Helicopter program reflects revised requirements accurately.
- CBP AMO should conduct a post-implementation review of the Multi-Role Enforcement Aircraft program to determine whether the deployed system is meeting capability needs, take corrective actions as appropriate, and apply lessons learned for future acquisitions.
- CBP AMO should conduct a post-implementation review of the Medium Lift Helicopter program to determine whether the deployed system is meeting capability needs, take corrective actions as appropriate, and apply lessons learned for future acquisitions.
CBP leadership did not agree with the first recommendation and stated that creating a separate formalized process independent of the Department’s policies is “redundant and unnecessary”. Further, CBP asserted that the Office of Acquisition routinely updates its policies and guidance to ensure continued alignment with department-wide policies as a normal practice whenever DHS issues new or revised policies, instructions, guidance, or templates.
CBP did however agree with the remaining three recommendations, and believes much of the work to meet these has already been completed or is ongoing. For example, CBP AMO is conducting a post-implementation review of the MEA. CBP’s Office of Acquisition will make the post-implementation review report available to other acquisition programs so they may apply any appropriate lessons learned. The estimated completion date is July 30, 2021. AMO is also planning to conduct a post-implementation review of the medium lift helicopter program, with an estimated completion date of May 31, 2022.