MEMORANDUM FOR GLENN A. FINE
Thank you for the opportunity to comment on the Office of Inspector General's (OIG) draft report entitled, "IDENT/IAFIS: Follow-up Review of the Status of IDENT/IAFIS Integration." I appreciate your recognition of the significant steps that have been taken to expedite the deployment of the initial version of the integrated IDENT/IAFIS workstation, providing the Department of Homeland Security (DHS) access to criminal history records maintained by the Federal Bureau of Investigation (FBI). I also appreciate your acknowledgement of the many actions of the Department of Justice (DOJ) has taken to promote the implementation of an interoperable IDENT/IAFIS system.
I believe your report has fairly and effectively presented the different perspectives of the various agencies involved in the effort to achieve interoperability between the two biometric identification systems operated by DOJ and DHS. These two agencies, plus the Department of State (DOS) and the National Institute of Standards and Technology (NIST), have different sets of mission objectives, and each one has been a forceful advocate for its respective position. The Department supports full interoperability and will continue to advocate approaches that best meet the law enforcement and counter-terrorism needs of the country. It is our hope that your report will help resolve many, if not all, of the outstanding issues that you have identified.
Below are comments regarding the recommendations contained in the draft report.
- By December 31, 2004, report to the Homeland Security Council (HSC) and Congress that the Department, the DHS, and the DOS have reached an impasse and cannot complete the Memorandum of Understanding (MOU) directed by Congress. The report should formally request that the HSC or Congress decide on the adoption of the NIST Technology Standard and define the capabilities to be provided in the interopable system.
As indicated above, it is our hope that this report will help resolve the issues related to the objective of achieving interoperability between these systems. Once your report is issued in final, we will transmit it to the HSC and ask that its members address the matter. We also intend to report to Congress on the status of this project within 90 days of the enactment of the Department's FY 2005 appropriations act.
- Increase the transmission of the fingerprints of Known or Suspected Terrorists from the FBI to the DHS from monthly to at least weekly.
The FBI will provide fingerprints of Known and Suspected Terrorists within one week of establishing the record within IAFIS. The FBI is also exploring opportunities to improve its processing of Known or Suspected Terrorists. Several IAFIS system changes are in development that may allow for these records to be exchanged with DHS daily.
- Request access to a random sample of data from the US-VISIT and other relevant immigration biometric databases used for enforcement or benefit purposes for comparison to IAFIS in order to determine the risk posed by not checking all visitors against IAFIS.
As reported in the draft, the Department has made such a request, but an agreement on the parameters of the study has not been reached. It is our belief that an agreement can be achieved once the other, larger issues have been resolved through the HSC.
- Coordinate with the DHS to identify the capacity needed to conduct IAFIS searches on all visitors referred to secondary inspection and inform the Department's CIO how the capacity of IAFIS (now planned to be 20,000 searches by October 1, 2005) could be increased to handle that level of activity.
Until such time as the issues articulated in your report are resolved, it is premature to identify specific operational requirements and the attendant system capabilities that would be needed. As soon as these issues are settled, the Department will move expeditiously to ensure that it, and its systems, can meet expectations.
- Develop options for the eventual upgrade of IAFIS to enable the system to conduct ten flat fingerprint searches on all US-VISIT enrollees and TPRS submissions from the Border Patrol and from the ports of entry.
This recommendation presupposes policy decisions that have not been made. Until policy decisions are made at the HSC level, it seems inadvisable and inappropriate to spend resources to develop detailed options for full operational implementation. Pending policy decisions by HSC, the Department continues exploring various options informally as to ways to further and better support US-VISIT.
- Take steps to ensure that IAFIS meets its availability requirement of 99 percent.
The FBI has been working to improve the IAFIS availability routinely since the system went operational in July 1999. Since IAFIS began operations, the yearly system availability has increased with each year. Several initiatives are currently underway to reduce unscheduled outages by eliminating single points of failure and creating redundancy where possible. The FBI is in the process of standardizing the hardware platforms across IAFIS. This initiative, which began in 2003 and will be completed by April 2005, will provide automated recovery capabilities to support rapid restoration of services during off-nominal events.
The FBI's long term plans to reduce both scheduled and non-scheduled outages include the development of a full system disaster recover capability. The FBI is currently defining the concept of operations as well as the system requirements that will shape this future vision. Funding as yet has not been identified, so an implementation date has not been determined.
Again, thank you for the opportunity to comment on this draft report. We look forward to the resolutions of the issues identified in your report and to further progress toward improved identification capabilities for federal, state and local governments in their efforts to keep America safe and secure.