Inspection of the Secure Electronic Network
for Travelers' Rapid Inspection
Report Number I-2000-019
June 2000

Response to OIG's Inspection of the Secure Electronic Network
for Travelers' Rapid Inspection, A-98-35

U.S. Department of Justice Immigration and Naturalization Service HQOIA 110/8.2-C

MEMORANDUM FOR MARY W. DEMORY
ASSISTANT INSPECTOR GENERAL FOR INSPECTIONS
DEPARTMENT OF JUSTICE

FROM:	Doris Meissner Commissioner Immigration and Naturalization Service
SUBJECT:	Inspection of the Secure Electronic Network for Travelers' Rapid Inspection (SENTRI), A -98-3 5

I appreciate the opportunity to comment on the subject report and solicited input from the senior management official who is most significantly impacted --the Executive Associate Commissioner for Policy and Planning. I reviewed his response and concur with the conclusions and observations. The response is attached for your review.

We support the conclusions of the report and expect to be able to implement the recommendations during the course of the Justice Performance Review laboratory period, which ends in August 2001. However, we have concerns about your reference to SENTRI being installed along the northern border. A more comprehensive discussion of this concern is addressed in the attached memorandum. Also included is a description of the changes made to clarify the location of SENTRI sites in all future correspondence and congressional testimony.

Thank you again for the opportunity to respond to the draft report. If you have any questions, please contact Kathleen Stanley, Audit Liaison, at (202) 514-8800.

Attachment
cc: Vickie L. Sloan, DOJ Audit Liaison

U.S. Department of Justice Immigration and Naturalization Service HQPGM 70/5.3

MEMORANDUM FOR THE COMMISSIONER

FROM:	Robert L. Bach Executive Associate Commissioner Office of Policy and Planning
SUBJECT:	Inspection of the Secure Electronic Network for Travelers' Rapid Inspection (SENTRI), A-98-35

We appreciate the opportunity to respond to the Office of the Inspector General's (OIG) Draft Inspection Report on the SENTRI program. We would like to take this opportunity to commend the OIG on their review of the SENTRI program. The Office of Policy and Planning (HQOPP) has concurred with the eight recommendations made by the 010 in their draft report.

The HQOPP respectfully differs with the 010 on its finding that the Immigration and Naturalization Service's (INS) northern border dedicated commuter lanes (DCLs) are SENTRI sites. The HQOPP believes that there is a significant distinction between the southern border SENTRI sites and northern border DCLs that utilize portions of the SENTRI technology. The SENTRI program was specifically designed for the southern border. Northern border sites are further distinguished as they lack the full complement of SENTRI technology. The HQOPP acknowledges .that the DCLs along the northern border that utilize SENTRI technology have been reported as SENTRI sites. This has been as a matter of reporting convenience rather then the actual designation of these sites as part of the southern border SENTRI project. The Office of Inspections has taken steps to distinguish between the two programs by designating separate program managers for SENTRI and for the northern border DCLs. To further distinguish between the two projects the INS has revised how the two programs are reported internally, to the Department of Justice, and to Congress.

The OPP's responses to the OIG's recommendations are outlined below:

RECOMMENDATION 1:
Work with Customs and JPR to develop and implement long range plans regarding SENTRI's status beyond its scheduled term as a reinvention laboratory. These plans should include developing a management structure for SENTRI as a permanent program; recovering SENTRI's operating costs at all sites, as required by Office of Management and Budget Circular A-25; and devising a strategy for the future of the northern border SEINTRI sites.

INS RESPONSE: CONCUR:
The INS concurs that the INS, the U.S. Customs Service (US CS) and the Justice Management Division (JMD) should develop and implement a long range plan that will transition the SENTRI project from a reinvention laboratory to a co-managed INS/USCS permanent program with INS as the lead agency. The long-range plan will cover the management structure of the program and a strategy to achieve operating cost recovery. The plan will also include a revised framework for future site selection. In accordance with the OIG's recommendations, it will include a quantitative analysis of commuter wait times, traffic volume, and incidences of border violations. Future site selection criteria will also include: an analysis of the physical infrastructure of the port-of-entry and its ability to support the installation of an enrollment center and the lane technology; the ability of the approach road infrastructure to support a dedicated commuter lane; congressional and community support; the growth patterns of the surrounding communities; and the potential commuter population within the region. The framework will also incorporate an estimate of installation costs to include current estimates of equipment costs, installation fees, and any necessary infrastructure modifications. The revised framework will be completed by October. The final implementation of this plan will coincide with the end of the current Justice Performance Review laboratory period, August 2001.

RECOMMENDATION 2:
Develop and implement a funding plan for SENTRI that will cover the operation of SENTRI at all sites and address current funding shortfalls.

INS REPSONSE: CONCUR:
The INS will develop a funding plan consistent with the broad policy goals of the INS. The INS has recently completed a review of the land border fee account that was initiated during the OIG inspection. Based on the findings of this review, the INS drafted a proposed rule that establishes a user fee to recover operating costs of the SENTRI program. This regulation is currently within the internal concurrence process. It is expected that will be published by January 2001.

RECOMMENDATION 3:
Require that inspectors consistently follow existing audit procedures for maintaining and validating SENTRI's enrollment data at sites along the Southwest border; develop and implement similar audit procedures for sites along the Northern border.

INS RESPONSE: CONCUR:
The INS and the USCS will issue a memorandum that instructs the field and regional personnel assigned to the SENTRI that existing audit procedures for the SENTRI program are to be followed. Adherence to these procedures will be monitored through local first line supervision, site visits by Headquarters and Regional Program Managers, as well as through semi-annual evaluations. These evaluations will be incorporated into the INS's INSpect review and the USCS Management Inspection Division (MID) process.

RECOMMENDATION 4:
Require that SENTRI's administrative procedures be consistently performed by inspectors at each site, including that inspectors conduct annual renewal of SENTRI's enrollees and run daily IBIS-queries.

INS RESPONSE: CONCUR:
The INS and the USCS will instruct the field managers and Inspection personnel assigned to the SENTRI program of the existing enrollment and renewal procedures of the SENTRI program. Adherence to these procedures will be monitored through local first line supervision, site visits by Headquarters and Regional Program Managers as well as through semi-annual evaluations.

RECOMMENDATION 5:
Perform semi-annual evaluations of SENTRI's full operations at each site as agreed to under the 1994 Memorandum of Understanding with Customs regarding the implementation of dedicated commuter lanes. These evaluations should be used by INS in identifying and resolving problems at existing sites as well as in reassessing the continued viability of these sites.

INS RESPONSE: CONCUR:
The 1994 Memorandum of Understanding (MOU) was drafted prior to the existence of the SENTRI program and was used as guidance in the development of the current SENTRI evaluation process. INS will continue to evaluate the SENTRI program and its performance measurement process and will seek to revise the MOU to reflect the frequent on-going evaluation of the program. This evaluation will be reported in the quarterly reporting to Congress and the Department of Justice. The INS will also continue its present internal evaluation of the SENTRI program and report its findings to the Commissioner in the INS's annual performance report, and in the INS's quarterly priority review. These frequent reviews will be used to identify and resolve problems at existing sites as well as in reassessing the continued viability of these sites.

RECOMMENDATION 6:
Reassess the appropriateness of existing performance goals, benchmarks, and measures developed for Southwest border sites and develop performance goals, benchmarks and measures for Northern border sites.

INS RESPONSE: CONCUR:
The INS and the USCS will reassess the existing performance goals and measures developed for the SENTRI program as well as develop separate performance goals and benchmarks for the northern border. The reassessment of the SENTRI program performance measurements and the development of performance goals and benchmarks will be completed by January 2001.

RECOMMENDATION 7:
Strengthen current methods for projecting enrollment levels at proposed sites.

INS RESPONSE: CONCUR:
The INS, the USCS, and the SENTRI team, working in conjunction with Bridge Authorities and local research groups, will continue to utilize market surveys, data analysis and stakeholder conferences to project potential enrollment levels at proposed sites. The INS and the USGS will strengthen these current methods through data validation and continued analysis of available crossing data. The INS and the USCS will further strengthen their method of projecting enrollment levels through a review of the available historical data.

RECOMMENDATION 8:
Revise the current framework used for evaluating and selecting proposed sites to include at a minimum a quantitative analysis of: commuter wait times, traffic volume, incidences of border violations, and potential enrollment levels.

INS RESPONSE: CONCUR:
The long-range plan, as discussed in the response to Recommendation 1, will include a revised framework for future site selection. The revised framework will incorporate the OIG's recommendations to include a quantitative analysis of commuter wait times, traffic volume, and incidences of border violations. Future site selection criteria will also incorporate an analysis of the physical infrastructure of the port-of-entry, the ability of the approach road infrastructure to support a dedicated commuter lane, congressional and community support, the growth pattern of the surrounding communities, and the potential commuter population within the region. The deadline for the implementation of this plan will coincide with the end of the current JIPR laboratory period, August 2001.