    Federal Law Enforcement Training Center: Capacity Planning and
    Management Oversight Need Improvement (24-JUL-03, GAO-03-736).

    The Federal Law Enforcement Training Center (FLETC) provides
    federal law enforcement training for 75 Partner Organizations
    (agencies) primarily at four domestic facilities located at
    Glynco, Ga; Artesia, N. Mex.; Charleston, S.C.; and Cheltenham,
    Md.. Given the post-terrorist attack security environment,
    coupled with the increased demand for training, concerns have
    been raised about FLETC's continued ability to meet this training
    demand. Because of these concerns, GAO was asked to issue a
    report on (1) how FLETC plans to meet the projected demand for
    training; (2) FLETC's ability to efficiently coordinate and
    schedule training activities; and (3) whether oversight and
    governance structures provide the guidance it needs to address
    its capacity and planning challenges.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-03-736
        ACCNO:   A07688
      TITLE:     Federal Law Enforcement Training Center: Capacity
    Planning and Management Oversight Need Improvement
         DATE:   07/24/2003
      SUBJECT:   Counterterrorism
    	     Employment or training programs
    	     Law enforcement
    	     Law enforcement agencies
    	     Law enforcement personnel
    	     Police training
    	     Strategic planning
    	     Training utilization

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    GAO-03-736

    Report to Congressional Requesters

    United States General Accounting Office

    GAO

    July 2003 FEDERAL LAW ENFORCEMENT TRAINING CENTER

    Capacity Planning and Management Oversight Need Improvement

    GAO- 03- 736

    FLETC*s overall capacity to provide training at the Glynco and Charleston
    campuses is currently strained, while Artesia has been underutilized, and
    Cheltenham is being upgraded and cannot operate at full capacity. FLETC is
    developing a Master Plan to address how to overcome the long- term
    capacity challenges, but questions exist regarding the assumptions and

    methodologies used, contingency planning, cost estimation and budgeting,
    and the need to address capacity shortfalls sooner than planned.
    Department of Homeland Security officials intend to review the new
    department*s training needs and capacities, and update the plan to reflect
    its vision for law enforcement training. Within the context of its
    strained training capacity, FLETC uses a predominantly manual scheduling
    process that does not

    ensure the efficient use of training resources and poses internal control
    risks due to potential loss of scheduling materials and the lack of backup
    documentation. Although FLETC has begun the process to acquire a fully
    automated scheduling system, FLETC officials have yet completed important
    risk management activities and are not using recognized best practices for
    acquiring commercial off- the- shelf- based systems associated with this
    type of acquisition. Furthermore, FLETC*s solicitation activities have not
    adequately addressed security requirements. FLETC faces additional
    challenges regarding its governance structure in that the status of
    FLETC*s Board of Directors is unclear, and its membership, roles and
    responsibilities, and past practices are not fully consistent with
    prevailing governance best practices. Partner Organization Training
    Projections Compared to Current Optimum Combined Campus Capacity (in
    student weeks)

    100,000 150,000

    0 200,000

    1997

    130,069 140,322

    160,871 154,362 132,470

    150,355

    1998 1999

    Pre 9- 11- 01

    Fiscal year

    Post 9- 11- 01

    2000 2001

    9- 11- 01 Terrorist attacks

    2002 2003 2004 2005 2006 2007 2008 250,000

    300,000 PO - Projected

    student weeks

    Source: GAO analysis of FLETC data. 5- day/ 8- hour capacity = 199,000

    265,848 283,106

    232,221 230,089 228,142 224,385 Demand surge

    6- day/ 8- hour capacity = 238,000 Overcapacity

    zone

    Note: A *student week* is defined as 5 days of training for 1 student. The
    Federal Law Enforcement Training Center (FLETC) provides

    federal law enforcement training for 75 Partner Organizations (agencies)
    primarily at four domestic facilities located at Glynco, Ga; Artesia, N.
    Mex.; Charleston, S. C.; and Cheltenham, Md.. Given the post- terrorist
    attack security environment, coupled with

    the increased demand for training, concerns have been raised about FLETC*s
    continued ability to meet

    this training demand. The visual below demonstrates the sharp increase
    since the September 11, 2001, attacks. Because of these concerns, GAO was
    asked to issue a report on (1) how FLETC plans to meet the projected
    demand for training; (2) FLETC*s ability to efficiently coordinate and
    schedule

    training activities; and (3) whether oversight and governance structures
    provide the guidance it needs to address its capacity and planning
    challenges.

    GAO recommends that the Secretary of the Department of Homeland Security
    improve capacity planning, periodically assess the condition of training
    facilities and infrastructure, improve the acquisition process for

    an automated scheduling system, and enhance the governance and oversight
    capabilities of FLETC*s

    Board of Directors. The department and FLETC generally concurred with
    GAO*s recommendations.

    www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 736. To view the full product,
    including the scope and methodology, click on the link above. For more
    information, contact Richard M. Stana, 202- 512- 8777, Stanar@ GAO. gov.
    Highlights of GAO- 03- 736, a report to

    Congressional Requesters

    July 2003

    FEDERAL LAW ENFORCEMENT TRAINING CENTER

    Capacity Planning and Management Oversight Need Improvement

    Page i GAO- 03- 736 Federal Law Enforcement Training Letter 1 Results in
    Brief 4 Background 7 FLETC*s Training Capacity is Strained, and Its
    Planning for Adding Capacity Raises Concerns 12 FLETC*s Current Scheduling
    System Is at Risk and Its Acquisition

    of an Automated System Raises Concerns 24 The Status of FLETC*s Board of
    Directors Is Unclear, and DHS Has Begun to Provide Oversight and Guidance
    34 Conclusions 39 Recommendations for Executive Action 41 Agency Comments
    and Our Evaluation 43 Appendix I Objectives, Scope, and Methodology 47

    Capacity, Planning, and Coordination 48 Scheduling and Coordination of
    Training Activities 49 Governance and Oversight Structure and Guidance 50
    Appendix II FLETC*s 75 Partner Organizations 52

    Appendix III Training Programs and Seminars Provided by FLETC 57

    Appendix IV Comments from the Department of Homeland Security 59

    Appendix V GAO Contacts and Staff Acknowledgments 71 GAO Contacts 71 Staff
    Acknowledgements 71 Tables

    Table 1: Capacity and Demand at the FLETC Campuses (in student weeks) 13
    Contents

    Page ii GAO- 03- 736 Federal Law Enforcement Training Table 2: Potential
    Campus Capacities Following Completion of Phase I Master Plan Projects (in
    student weeks) 21 Figures

    Figure 1: Various FLETC Training Activities 8 Figure 2: FLETC Fiscal Year
    2003 Budget Enactment and Fiscal Year 2004 Budget Request 9 Figure 3:
    Partner Organization Training Projections Compared to Current Combined
    Campus Optimum Capacity (in student weeks) 15 Figure 4: FLETC Campus at
    Artesia, New Mexico 17 Abbreviations

    ACMS Academy Class Management System ATF Bureau of Alcohol, Tobacco,
    Firearms and Explosives COTS commercial off- the- shelf- based systems DHS
    Department of Homeland Security FAM Federal Air Marshals FCI Facility
    Condition Index FLETC Federal Law Enforcement Training Center FTE full-
    time equivalent INS Immigration and Naturalization Service IT information
    technology MOU memorandum of understanding O& M operation and maintenance
    OMB Office of Management and Budget PO Partner Organization RFP request
    for proposals SASS student administration and scheduling system SEI
    Software Engineering Institute TSA Transportation Security Administration

    This is a work of the U. S. Government and is not subject to copyright
    protection in the United States. It may be reproduced and distributed in
    its entirety without further permission from GAO. It may contain
    copyrighted graphics, images or other materials. Permission from the
    copyright holder may be necessary should you wish to reproduce copyrighted
    materials separately from GAO*s product.

    Page 1 GAO- 03- 736 Federal Law Enforcement Training July 24, 2003 The
    Honorable Harold Rogers Chairman, Subcommittee on Homeland Security

    Committee on Appropriations House of Representatives

    The Honorable Jack Kingston The Honorable Ernest J. Istook, Jr. House of
    Representatives

    Since its inception in the early 1970s, the Federal Law Enforcement
    Training Center (FLETC), now a component of the Department of Homeland
    Security (DHS), 1 has played a vital role in training personnel from
    federal, state and local, and foreign law enforcement agencies. FLETC is
    responsible for providing basic, advanced, specialized, and refresher
    training for law enforcement officers from 75 federal law enforcement
    agencies. 2 Following the September 11, 2001, terrorist attacks against
    the United States, FLETC*s role and continued ability to provide law
    enforcement training in a timely manner is critical in the war against
    terrorism. For fiscal year 2003, according to the Director of FLETC, 65
    percent of its projected training workload will come from 9 agencies
    transferred to DHS.

    The sudden influx of the large numbers of law enforcement personnel to
    FLETC, coupled with the post- terrorist attack security environment, has
    revived past concerns about the strain placed on its capacity to meet the
    training demand. 3 Most recently beginning in the mid- 1990s, these
    influxes

    1 FLETC transferred to DHS on March 1, 2003, pursuant to the Homeland
    Security Act of 2002 (P. L. 107- 296, 116 Stat. 2135). Previously, FLETC
    was part of the Enforcement Division of the Department of the Treasury. 2
    It should be noted that not all federal law enforcement agencies receive
    their training at

    FLETC. For example, the Federal Bureau of Investigation and the Drug
    Enforcement Administration have their own training facilities in Quantico,
    Va. 3 For this report, capacity is defined as the resources required, such
    as instructors, facilities, and equipment, to achieve the optimum level of
    training. Its measurement depends upon the following factors: type of
    operation schedule (e. g., 5- day/ 8- hour schedule), the campus (e. g.,
    Glynco), the time frame (e. g., a given fiscal year), and special
    considerations (e. g., changes in training priority, mission, or policy).

    United States General Accounting Office Washington, DC 20548

    Page 2 GAO- 03- 736 Federal Law Enforcement Training were the result of
    increases in the personnel levels of the U. S. Border Patrol; 4 the
    increases were a function of initiatives to control illegal

    immigration along U. S. borders. FLETC, in cooperation with the
    Immigration and Naturalization Service (INS), established a separate,
    temporary campus in Charleston, South Carolina, in fiscal year 1996 to
    handle the demand for training Border Patrol agents because the main FLETC
    campus at Glynco, Georgia, could not accommodate this influx. The current
    influx has raised concerns also about the relevance, quality, and
    timeliness of training provided by FLETC. These concerns, in turn, have
    prompted some federal law enforcement agencies that use FLETC for their
    basic training to periodically consider establishing their own facilities,
    tailored to their unique training needs and philosophy. At the same time,
    however, Treasury and FLETC officials have said that the consolidated
    approach to federal law enforcement training has provided economy- of-
    scale savings annually, although these officials could not establish the
    actual amount of recent savings. According to the FLETC officials, most of
    the savings accrued from (1) achieving economies of scale that enabled
    them to charge training participants lower per diem rates at FLETC
    facilities than those participants would have incurred at

    their own training facilities and (2) avoiding the need for maintaining
    redundant or duplicate training facilities elsewhere.

    The issue of consolidated federal law enforcement training is of
    particular interest to you and the Appropriations Committee, which is on
    record as being fully committed to the principle of such training. This
    report responds to an April 2002 request by Representatives Istook and
    Kingston; the House Appropriations Subcommittee on Homeland Security
    joined the request when it assumed jurisdiction over FLETC in Spring 2003.
    On the basis of discussions with your offices, we are addressing the
    following objectives:

     Determine the extent to which FLETC is able to meet the current and
    projected demand for training, how FLETC is planning to meet the demand,
    and the associated costs; and the extent to which FLETC coordinates or
    uses existing, non- FLETC government training assets, and any associated
    costs.

    4 On March 1, 2003, the border protection functions of the Border Patrol,
    and the border protection responsibilities of certain other agencies, such
    as the U. S. Customs Service and INS, were transferred to the Bureau of
    Customs and Border Protection within DHS. Since they each have their own
    training programs and academies at FLETC campuses, we use the terms Border
    Patrol, Customs, and INS to identify these agencies throughout this
    report.

    Page 3 GAO- 03- 736 Federal Law Enforcement Training  Examine FLETC*s
    current organizational structures and processes for coordinating and
    scheduling training activities and whether FLETC plans

    any changes to these structures and processes.  Review FLETC*s oversight
    and governance structures and the extent to

    which these structures are providing guidance to FLETC as it addresses its
    capacity and planning challenges during a period of transformational
    change.

    You also asked us to review the final version of FLETC*s Master Plan.
    However, DHS did not give us the final plan for FLETC in time to be
    included in this report, citing its need to review the plan. Accordingly,
    we based our analysis of FLETC*s planning for future facilities on the
    final draft version of the plan, submitted to us in April 2003, and the
    analyses of the other issues on the most recent information available. As
    agreed with your offices, once the final version of the Master Plan is
    provided to us

    (DHS estimated that it might provide the plan in late summer 2003), and
    the status of the training projections, system acquisition, and FLETC
    governance becomes more apparent, we will complete our analyses and brief
    you on any additional observations.

    To develop our information, we visited the FLETC campuses in Glynn County,
    Ga. (commonly referred to as *Glynco*); Charleston, S. C.; Artesia, N.
    Mex.; and Cheltenham, Md. At the campuses, we observed training
    activities; met with FLETC managers and officials in charge of training,
    scheduling, information technology support, and infrastructure facilities,
    and held meetings with officials from various agencies, known as Partner
    Organizations (PO)* such as the Border Patrol and the Bureau of Alcohol,
    Tobacco, Firearms, and Explosives (ATF)* that use these campuses. We
    reviewed relevant documents, including the 1970 memorandum of
    understanding (MOU) that established FLETC*s roles and responsibilities in
    providing training to law enforcement agencies that are signatories to the
    MOU; FLETC budget requests and related justifications; PO and FLETC
    historical training statistics and projections for future training;
    FLETC*s 1989 Master Plan, the 1996 Master Plan update; the 2003 draft
    final Master Plan for facilities assessment, construction, and renovation;
    and best practices related to facilities and information technology

    acquisition and governance and internal and management control. In
    addition to those we interviewed at the FLETC campuses, we met with
    headquarters officials at DHS; and the Departments of the Treasury,
    Justice, and Transportation and their components; and with staff from the
    Office of Management and Budget (OMB). We also met with a

    Page 4 GAO- 03- 736 Federal Law Enforcement Training representative of the
    architectural and engineering firm in Norfolk, Virginia, retained by FLETC
    to help with its future planning. 5 We

    conducted our work from May 2002 through June 2003 in accordance with
    generally accepted government auditing standards. Appendix I provides more
    detailed information about the scope and methodology of our work.

    Fueled initially by the growth in Border Patrol personnel that began in
    the mid- 1990s, and currently by the surge in overall federal law
    enforcement personnel levels in response to the September 2001 terrorist
    attacks, the overall 5- day/ 8- hour capacity to provide training at the
    Glynco and Charleston campuses is strained, while the Artesia campus has
    been underutilized, and the Cheltenham campus is being upgraded and is not
    fully operational (e. g., the U. S. Capitol Police is conducting limited
    training using classrooms and several physical venues). FLETC has been
    able to generally meet POs* needs for basic training (the training
    provided to new

    recruits) by, among other things, operating a 6- day schedule at the
    Glynco campus and deferring POs* advanced classes (those provided to
    experienced personnel). POs offered a variety of views about the effect of
    the strained capacity on the training of their personnel* for example,
    former Justice POs 6 noted that the quality of the training had suffered;
    other POs said that although their students and instructors were fatigued
    and stressed, the quality of the training was still good. FLETC officials
    disputed the view that capacity constraints had a negative impact on PO
    training* these officials said that based on FLETC*s own data, student
    scores, for example, had not declined. The strained capacity has had an
    adverse effect on the condition of FLETC facilities and the infrastructure
    that supports them. Continued use of these facilities at an accelerated
    rate without maintenance and renovation would likely lead to further

    deterioration and exacerbate capacity challenges. FLETC has worked with an
    architectural and engineering firm to develop a Master Plan to help
    address long- term capacity challenges. The planning process raises
    several concerns about the assumptions and methodologies

    5 The firm, Clark Nexsen, Architecture and Engineering, was retained to
    develop an updated Master Plan and assist in establishing a strategy to
    analyze existing facilities and programs and handle future growth.

    6 The POs who expressed their opinions to us about the impact of the
    capacity constraints on their personnel were, at the time of our meetings,
    still part of the Department of Justice. On March 1, 2003, most of these
    POs moved to DHS. Results in Brief

    Page 5 GAO- 03- 736 Federal Law Enforcement Training used to develop the
    plan*s recommendations, and the extent to which they allow for
    contingencies, such as potential future surges or declines in

    demand for training; cost estimating and budgeting; and the extent to
    which the plan*s recommendations would be implemented in time to help
    alleviate the capacity constraints. DHS officials told us they intend to
    review the plan, but might not adopt substantial parts of it, as the
    department is formulating its vision for federal law enforcement training
    in general and FLETC in particular* these officials said that while useful
    in some respects (e. g., it contains a comprehensive inventory of the
    condition of FLETC training facilities), the plan was essentially dated in
    its assumptions. FLETC does not have a formal contingency plan for
    addressing its capacity challenges during the period up to when facilities
    recommended by the Master Plan begin coming on line and, as a practice,
    has not routinely utilized alternative training assets (e. g., off- site
    training

    and e- learning) to provide basic training for POs. In addition to
    strained training capacity challenges, FLETC faces a challenge to automate
    the scheduling of training for its POs. Specifically, FLETC*s scheduling
    process uses a predominantly manual scheduling process that does not
    ensure the efficient use of training resources and poses internal control
    risks due to potential loss of scheduling materials and the lack of backup
    documentation. FLETC has recognized these risks and is in the process of
    acquiring an automated student administration and scheduling system (SASS)
    to address them. Although FLETC*s plans and activities for acquiring the
    SASS generally include performance of certain key acquisition management
    functions, FLETC has yet to address

    important risk management issues associated with its SASS acquisition. 7
    Moreover, with the exception of its SASS solicitation, FLETC*s plans and
    activities do not incorporate recognized best practices for acquiring
    commercial off- the- shelf- based systems (COTS). Furthermore, FLETC*s
    solicitation activities have not adequately addressed SASS security
    requirements. Taken as a whole, this means that FLETC*s SASS acquisition
    is currently at risk of not delivering a system solution to best meet its
    needs. Although FLETC continues to develop documentation for the SASS
    proposal, at our urging, it is also working with the Border Patrol to
    determine whether its existing Academy Class Management System (ACMS),
    which is being enhanced with a scheduling module, can be used

    7 Managing project risk means proactively identifying facts and
    circumstances that increase the probability of failing to meet project
    commitments and taking steps to prevent this from occurring.

    Page 6 GAO- 03- 736 Federal Law Enforcement Training instead of acquiring
    SASS. According to FLETC officials, if it chooses ACMS, FLETC could save
    the cost of the SASS solicitation and the

    system*s estimated $10 million cost over 5 years, while spending
    considerably less to adopt the ACMS scheduling module.

    FLETC faces challenges in its governance structure because (1) the status
    of its Board of Directors is unclear as FLETC, its individual board
    members, and DHS consider the Board*s future; and (2) the Board*s
    membership, roles and responsibilities, and past practices are not fully
    consistent with prevailing governance and internal and management control
    best practices. For example, according to a FLETC official the Board did
    not meet for a period of 3- 1/2 years, prior to its most recent meeting in
    November 2002, even though it is required by its own charter to meet at
    least quarterly; and, according to governance best practices, the
    *typical* board of directors meets about eight times a year. 8 A DHS
    official said that DHS has recently assumed responsibility for FLETC and
    recognizes the need to provide guidance and oversight to FLETC; DHS has
    begun to work with FLETC to provide guidance related to its demand and
    capacity challenges. In addition, DHS recognizes the role an effective

    FLETC board could play in enhancing governance. Without effective internal
    and external governance and oversight, FLETC could be at risk of not
    effectively addressing the transformational challenges it faces.

    Because of the importance to FLETC*s ability to meet its considerable
    challenges, we are making recommendations to the Secretary of DHS to
    improve capacity planning, periodically assess the condition of training
    facilities and associated infrastructure through the use of performance
    measures, improve the acquisition process for an automated scheduling
    system, and enhance the governance and oversight capabilities of FLETC*s

    Board of Directors. We provided a draft of this report to DHS and to the
    Department of Justice for comment. In its response, from the Under
    Secretary for Border and Transportation Security, DHS generally agreed
    with our conclusions and recommendations and outlined actions it either
    had taken or was planning to take to implement the recommendations. DHS
    also provided technical comments and clarifications, including updated
    information on FLETC*s SASS acquisition; we have incorporated them in this
    report where

    8 However, according to our review of Board minutes, the Board did not
    meet for a period of 5 years (from November 1997 to November 2002).

    Page 7 GAO- 03- 736 Federal Law Enforcement Training appropriate. Justice
    did not submit formal written comments; the Associate Assistant Attorney
    General for Federal Law Enforcement

    Training submitted an email with two general comments related to the
    issues of FLETC training capacity and governance, respectively.

    The September 2001 attacks spurred a significant surge in the numbers of
    federal law enforcement personnel to respond to the threat posed by
    terrorism. This surge, in turn, resulted in an influx of a large number of
    law enforcement personnel into FLETC*s campuses around the country, over
    and above their historical enrollment. Preceding the attacks, in fiscal
    year 2001, over 21, 000 students spent over 101,000 student weeks 9
    training at FLETC*s domestic campuses. In fiscal year 2002, primarily as a
    result of the post- attack surge, over 28,000 students spent about 157,000
    weeks training at these campuses. Placing the training statistics in
    historical context, the weeks spent by students at FLETC in fiscal year
    2002, for example, represented a 267- percent increase over the level in
    fiscal year 1983 (the earliest year for which complete data were
    available) and a

    72- percent increase from the level of as recently as fiscal year 1999.
    FLETC*s most recent adjusted domestic student training projections for
    fiscal year 2003 call for about 49,000 students to train for about 259,000
    student weeks, with PO projections rising to all- time highs of over
    57,000 students and about 283,000 student weeks in fiscal year 2004.

    FLETC was established as a consolidated interagency training facility in
    the Department of the Treasury by a Treasury order dated March 2, 1970.
    Subsequent to the Treasury order, an MOU between FLETC and its POs

    was established in September 1970. As of June 2003, FLETC was working to
    revise its MOU with its POs to reflect the move to DHS, which occurred in
    March 2003, according to a FLETC official. The original MOU, which was
    revised in 1977 and again in 1984, states that FLETC is responsible for,
    among other things, providing recruit (basic), advanced, specialized, and
    refresher training for designated criminal law enforcement personnel;
    specialized law enforcement training for state and local government
    personnel if space is available; facilities and student support services
    necessary for specialized training conducted at FLETC by a PO; updated

    9 *Student week* is the statistical measure of capacity for training;
    FLETC has defined a student week as 5 days of training for one student.
    For example, if 100 students receive training during a fiscal year, of
    which 25 receive 3 weeks of training, 40 receive 6 weeks of training, and
    the remaining 35 receive 8 weeks of training, the campus would be
    providing 595 student weeks of training during that fiscal year [( 25 X 3)
    + (40 X 6) + (35 X 8) = 595]. Background

    Page 8 GAO- 03- 736 Federal Law Enforcement Training training methods and
    curriculum content in response to the common needs of the participating
    law enforcement agencies; and dormitory space,

    food service, travel, and support services; and facilities for students
    trained at FLETC. The original POs were the Departments of the Interior,
    Justice, State, and Treasury; OMB; the U. S. Civil Service Commission*

    now the Office of Personnel Management; the U. S. Postal Service; and the
    Smithsonian Institution. FLETC*s original MOU was expanded over time to
    currently include the training of law enforcement personnel from 75 POs. A
    list of these 75 POs appears in appendix II.

    Figure 1: Various FLETC Training Activities

    As shown in figure 2, for fiscal year 2003, FLETC had an enacted budget of
    about $172 million, about 79 percent of which was for salaries and
    expenses and 21 percent for acquisition, construction, improvements, and

    Page 9 GAO- 03- 736 Federal Law Enforcement Training related expenses.
    That year, FLETC had 878 full- time equivalent (FTE) permanent staff
    authorized. For fiscal year 2004, the budget request

    totaled about $146 million, of which about 84 percent was for operating
    expenses (formerly classified as *salaries and expenses*) and about 16
    percent for capital acquisition (formerly classified as *acquisition,
    construction, improvements, and related expenses*). For fiscal year 2004,
    the budget request calls for 754 FTE permanent staff.

    Figure 2: FLETC Fiscal Year 2003 Budget Enactment and Fiscal Year 2004
    Budget Request

    a *Facilities* refers to *acquisition, construction, improvements and
    related expenses* in fiscal year 2003 and *capital acquisition* in fiscal
    year 2004. No funding was requested for major construction in fiscal year
    2004. b *Human capital* refers to *salaries and expenses* in fiscal year
    2003 and *operating expenses* in

    fiscal year 2004. FLETC provides training at four domestic campuses. 10
    Specifically, FLETC*s largest campus, which also serves as its
    headquarters, is located in Glynn County, Georgia (referred to as
    *Glynco*), and was established in 1975. Most of FLETC*s POs conduct their
    law enforcement basic training

    at the Glynco campus. FLETC*s second campus, established in 1989, is
    located in Artesia, New Mexico. The resident agencies at Artesia are the
    Border Patrol (for advanced training only), the Bureau of Indian Affairs,
    Indian Police Academy (basic and advanced), the INS Officers Academy, the
    Transportation Security Administration*s (TSA) Federal Air Marshals

    10 FLETC also has oversight responsibility on behalf of DHS for the
    International Law Enforcement Academy at Gabarone, Botswana.

    Source: GAO analysis of FLETC data.

    FLETC Fiscal Year 2003 Budget Enactment

    (in thousands)

    FLETC Fiscal Year 2004 President*s Request

    (in thousands)

    79% $136,109

    21% $35,766

    84% $122,379

    16% $23,679 Facilities a

    Human Capital b Facilities a

    Human Capital b

    Total $171,875 Total

    $146,058

    Page 10 GAO- 03- 736 Federal Law Enforcement Training (FAM), and the U. S.
    Secret Service Uniformed Division. FLETC*s third campus is a former naval
    base in Cheltenham, Maryland, that was

    transferred to FLETC in May 2001. FLETC intends to use the Cheltenham
    campus primarily as a driving and firearm re- qualification center for POs
    based in Washington, D. C., and its metropolitan area. At the time of our
    review, the campus was being upgraded and was not fully operational.
    According to FLETC officials, the Cheltenham campus will have, among other
    things, an indoor, 108- point, state- of- the- art firing range, and a
    multiuse, topographically varied driving course. Currently, over 12
    federal, including the U. S. Capitol Police, and state and local law
    enforcement agencies are using the campus. FLETC officials at Cheltenham
    anticipate that approximately 61POs will use the campus* firearms and
    driving

    re- qualification center. The fourth domestic campus is the Border Patrol
    Academy in Charleston, South Carolina. FLETC officials said that to date,
    this academy has not been placed under FLETC*s authority; however, FLETC
    provides technical support to the campus for the Border Patrol training.
    The campus was established in 1996 at a former naval base as a temporary
    facility to handle the surge in the number of Border Patrol agent recruits
    that were the result of a hiring initiative to control illegal immigration
    along U. S. borders. The existing FLETC campuses could not accommodate the
    Border Patrol*s surge in the resulting demand for training. In October
    2002, Public Law 107- 248 directed that the Secretary of the Navy transfer
    administrative jurisdiction of Charleston, in effect, to DHS, although it
    is not clear whether FLETC would control the facilities. 11 In February
    2003, Public Law 108- 7 established the Charleston *law

    enforcement training facility* as a permanent training facility. 12 The
    campus has been extensively remodeled and outfitted to provide basic
    training to the Border Patrol*s agent recruits; while it was originally
    scheduled to close in fiscal year 2004, if control of the Charleston
    facility transfers to FLETC, it intends to keep the campus open to help
    provide training capacity, regardless of who receives training there. In
    addition to the training provided directly by FLETC, a number of POs, such
    as the

    former Customs and INS, the U. S. Marshals Service, and the Internal
    Revenue Service, maintain their own *academies* at the FLETC campuses to
    provide agency- specific instruction to their recruits.

    FLETC offers predominantly four types of training programs* recruit
    (basic), specialized, advanced, and refresher training. Appendix III

    11 Department of Defense Appropriations Act, 2003 (P. L 107- 248, 116
    Stat. 1519 (2002)). 12 Consolidated Appropriations Resolution, 2003 (P. L.
    108- 7, 117 Stat. (2003)).

    Page 11 GAO- 03- 736 Federal Law Enforcement Training provides a detailed
    description of the variations of training programs and seminars FLETC
    offers. Basic training (i. e., training provided to new

    recruits) has represented the greatest demand for FLETC*s resources of all
    four types of programs given the increase in Border Patrol and the surge
    in federal law enforcement hiring since the September 11 attacks. Basic
    training is mandatory for entry- level federal law enforcement personnel,
    such as those hired by the Border Patrol, and is usually provided during
    the first year of employment to familiarize recruits with law enforcement
    skills and operations. Basic training also extensively uses FLETC*s
    training facilities, including firearm and driver training facilities, in
    addition to classrooms and other physical education facilities.

    For specialized training programs, such as agency- specific basic training
    programs (i. e., training provided by agencies immediately following
    FLETC*s basic training), FLETC has the responsibility for providing
    instructors for the parts of the program that are standard to FLETC*s
    curriculum, while the agency provides the part of the curriculum more
    specific to its mission. For example, FLETC provides the instructors for
    the Courtroom Testimony Lecture and shares responsibility with the Border
    Patrol for the Courtroom Testimony Laboratory. ATF and the Environmental
    Protection Agency, in addition to the Border Patrol are examples of
    agencies requiring specific programs as part of their basic training
    program. For the sections of the program that are not designated as a
    FLETC responsibility, the PO must provide instructors. FLETC also
    evaluates these programs to ensure that PO training objectives are being
    met.

    Advanced training is usually provided to junior and senior- level law
    enforcement personnel as part of their continuing professional
    development. An agency that maintains its own academy at a FLETC campus,
    such as the Border Patrol, will typically use its own instructors for
    advanced training. If it has instructors available, FLETC may sometimes
    assist an academy with advanced training. Advanced training includes (1)
    training of inspectors or agents to be instructors; (2) *followon basic*
    training, where skills particular to an agency mission are taught; and (3)
    in- service training, which is typically an intensive seminar on a current
    issue or the development of a law enforcement or management skill.

    FLETC also provides refresher training for its POs. For example, law
    enforcement personnel in the Washington, D. C., area will be able to
    receive refresher training in firearms and vehicle operation re-
    qualification at FLETC*s Cheltenham campus.

    Page 12 GAO- 03- 736 Federal Law Enforcement Training FLETC*s overall 5-
    day/ 8- hour capacity to provide training at the Glynco and Charleston
    campuses is currently strained, while the Artesia campus

    has been underutilized. The Cheltenham campus is being upgraded and is not
    fully operational, thus its contribution to FLETC*s overall capacity is
    limited. POs offered a variety of views about the effect of the strained
    capacity on the training of their personnel* for example, former Justice
    POs now in DHS believed that the quality of the training had suffered,
    while other POs said that although their students and instructors were
    fatigued and stressed, they believed that the quality of the training was
    still good. The strained capacity has had an adverse effect also on the
    condition of FLETC facilities and the infrastructure that supports them;
    further deterioration could exacerbate capacity challenges. FLETC has
    worked with an architectural and engineering firm to develop a Master Plan
    to help overcome the long- term capacity challenges, although DHS
    officials said that the plan might no longer be germane to the
    department*s vision for law enforcement training. The planning process
    raises several concerns about the assumptions and methodologies used to
    develop the plan*s recommendations, and the extent to which they allow for
    contingencies, such as future surges or declines in demand; cost
    estimating and budgeting; and the extent to which the plan*s
    recommendations would be implemented in time to help alleviate the
    capacity constraints. FLETC does not have a formal contingency plan for
    addressing its capacity challenges during the period up to when facilities
    recommended by the Master Plan begin coming on line and, as a practice,
    has not routinely utilized alternative training assets to provide basic

    training for POs. Primarily as the collective result of the surge in
    Border Patrol personnel levels begun in the mid- 1990s and the surge in
    overall federal law enforcement personnel following the September 2001
    terrorist attacks, the overall capacity to provide basic training at
    Glynco and Charleston is strained. As shown in table 1, the latest
    available PO- projected demand 13 exceeds the 5- day/ 8- hour capacity for
    fiscal year 2003, at these two

    training campuses. The combined capacity for a 5- day/ 8- hour workweek at
    13 FLETC uses PO projections of demand for training as part of its
    capacity planning. In March/ April of each year, POs submit to FLETC their
    projections for training. These projections are generally a function of
    the need for personnel and expected funding levels. In June of each year,
    FLETC, in consultation with POs, adjusts the projections, in recent years
    by less than 5 percent. In addition to the projections they submit,
    throughout the year, POs may submit requests to add, defer, or cancel
    classes. FLETC*s Training

    Capacity is Strained, and Its Planning for Adding Capacity Raises Concerns

    FLETC*s Training Capacity Is Strained at the Glynco and Charleston
    Campuses

    Page 13 GAO- 03- 736 Federal Law Enforcement Training the three FLETC
    campuses is about 67,000 student weeks short of projected demand, and for
    a 6- day/ 8- hour workweek about 28,000 student weeks short of the
    projected demand. Table 1: Capacity and Demand at the FLETC Campuses (in
    student weeks)

    Campus Optimum 5- day/ 8- hour capacity Optimum 6- day/ 8-

    hour capacity Fiscal year 2003

    projected demand

    FLETC estimated actual attendance

    (as of 4/ 30/ 03) Difference between

    projected demand and

    estimated attendance

    Glynco 192,494 148,311 44,183 November 2002 120,000 144,000 March 2003
    (temporary

    increase in capacity) 135,000 162,000 Charleston 37,000 44,000 41,259
    33,816 7,443 Artesia 27,000 32,000 32,095 18,556 13,539

    Total 199,000 238,000 265,848 200,683 65,165

    Source: GAO analysis of FLETC data.

    However, also as shown in table 1, FLETC is estimating (as of April 30,
    2003) that the actual number of student weeks spent at the three campuses
    will total 200,683 student weeks, or 25 percent less than the fiscal year
    2003 projected levels. A FLETC official said that it is not unusual for
    actual attendance to fall short of projections because of factors such as
    recruiting shortfalls, funding reallocations, and classes that begin with
    less than their full complement. In fact, actual attendance (in student
    weeks)

    fell short of projections as recently as fiscal year 2001, when attendance
    was about 76 percent of the projected level. In fiscal year 2002, actual
    attendance was about 112 percent of the projected level.

    The FLETC official attributed the difference in fiscal year 2003 to three
    principal factors. First, changes in TSA*s projections* TSA originally
    projected about 49,000 student weeks of training primarily for airport
    security officers, and for *flight deck officers* (i. e., airline pilots
    trained to carry firearms in cockpits) and FAMs. However, the TSA
    projections have not materialized to date, with the estimated actual
    attendance totaling

    about 10,000 student weeks. Second, changes to the Border Patrol*s
    projections* the Border Patrol originally projected about 46,000 student
    weeks of training for agents. However, the estimated actual attendance
    totals about 33,000 student weeks. Third, changes to the former INS*s
    projections* INS originally projected about 50,000 student weeks of
    training for inspectors and agents. However, the estimated actual

    Page 14 GAO- 03- 736 Federal Law Enforcement Training attendance totals
    about 40,000 student weeks. A FLETC official cautioned that the final
    actual attendance for fiscal year 2003 might be different than the
    estimates based on additional requests, DHS reorganization training

    guidelines, attrition, and additional hiring budgets. For example, there
    is a possibility that if funding is restored, TSA may yet end up needing a
    number of the student weeks it originally projected.

    Even if the fiscal year 2003 projections do not ultimately materialize,
    FLETC*s 5- day/ 8- hour capacity would still be strained. Specifically,
    the total estimated actual attendance of 200,683 student weeks will exceed
    the combined 5- day/ 8- hour capacity of 199,000 student weeks by about
    1,700 student weeks. In discussing the capacity strains facing FLETC, we
    note that *student weeks* provides FLETC with a statistical measure of
    optimum throughput, or best case, training capacity (see footnote 3). This
    measure assumes that all of the requisite facilities, instructors, and
    equipment will be available to provide training when needed. However,
    capacity is ultimately a function of facilities, instructors, and
    equipment that are actually available to provide training at a point in
    time. Accordingly, while a number of student weeks may appear to be
    *available* (for example, as in the case of the Charleston campus, where
    estimated actual attendance is about 3,000 student weeks below the
    campus*s 5- day/ 8- hour capacity); at any given time, a number of
    physical and human *choke points,* or training obstacles, either
    individually or collectively result in capacity constraints. Thus, the
    choke points essentially reduce the number of available student weeks from
    the bestcase level.

    In this regard, a number of choke points are causing the capacity strains
    that the Glynco and Charleston campuses are experiencing. Specifically,
    according to FLETC, the principal choke points that are collectively
    causing the capacity strain at Glynco are the firearms ranges, driving

    ranges, practical exercise facilities, the dining hall, classrooms,
    dormitories, and a shortage of instructors and support staff. At
    Charleston, the choke points include the firearms ranges, driving ranges,
    and a shortage of instructors* illustrating the effect of choke points on
    capacity at Charleston, during fiscal year 2003, the Border Patrol had to
    defer 3 classes of agent training because the campus*s emergency response
    driving range had to be taken off- line for resurfacing. According to
    FLETC officials, had these classes actually taken place, Charleston*s 5-
    day/ 8- hour capacity would have been met or exceeded.

    On the basis of the latest PO projections for training demand, FLETC*s
    overall capacity strain is expected to continue for fiscal year 2004.

    Page 15 GAO- 03- 736 Federal Law Enforcement Training However, for fiscal
    years 2005 through 2008, PO projections show a relatively stable decrease
    in demand from fiscal year 2004 peak levels, but projected demand still
    exceeds FLETC*s fiscal year 2003 5- day/ 8- hour

    capacity and is approaching the current 6- day/ 8- hour capacity. Figure 3
    shows the difference between combined projected demand and combined
    current capacity of FLETC facilities for fiscal years 1997 through 2008.

    Figure 3: Partner Organization Training Projections Compared to Current
    Combined Campus Optimum Capacity (in student weeks)

    Note: This graph includes the Glynco, Artesia, and Charleston campuses.

    While capacity at the Glynco and Charleston campuses has been strained,
    the Artesia campus has been underutilized following the completion of
    FAM*s ramped- up training during fiscal year 2002. In this regard, as
    shown in table 1, Artesia has an annual capacity of 27,000 student weeks
    for a 5- day/ 8- hour schedule and 32,000 student weeks for a 6- day/ 8-
    hour schedule. In fiscal year 2002, PO trainees spent 19, 188 student
    weeks at Artesia, well short of capacity. Although PO demand projections
    of 32,095 student weeks initially suggested that the Artesia campus would
    experience some minor capacity strains in fiscal year 2003, it is not
    clear that the campus will be fully utilized. Specifically, based on year-
    to- date attendance data through April 2003, FLETC estimated that 18, 556
    student Artesia Campus Has Been Underutilized

    100,000 150,000

    0 200,000

    1997

    130,069 140,322

    160,871 154,362 132,470

    150,355

    1998 1999

    Pre 9- 11- 01

    Fiscal year

    Post 9- 11- 01

    2000 2001

    9- 11- 01 Terrorist attacks

    2002 2003 2004 2005 2006 2007 2008 250,000

    300,000 PO - Projected

    student weeks

    Source: GAO analysis of FLETC data. 5- day/ 8- hour capacity = 199,000

    265,848 283,106

    232,221 230,089 228,142 224,385 Demand surge

    6- day/ 8- hour capacity = 238,000 Overcapacity

    zone

    Page 16 GAO- 03- 736 Federal Law Enforcement Training weeks will actually
    be spent at Artesia, well short of the levels originally projected by POs.
    As discussed earlier, according to FLETC officials, the shortfall is
    primarily caused by TSA*s original projections for training not

    materializing* part of this training was to be held at the Artesia campus.
    FLETC officials cautioned, however, that the final actual attendance might
    be different than the April 2003 estimate, and could be somewhat closer to
    the original projection based on additional PO requests, DHS

    reorganization training guidelines, attrition, and additional hiring
    budgets. In addition to Artesia*s underutilized housing and firearms
    ranges, the live- fire shoot houses and three Boeing 727s, specially
    configured for terrorism training, have not been used since the FAMs
    completed their training (see figure 4). A FLETC official indicated that
    it is conducting marketing and other types of activities to attract a
    number of additional users to the campus. In this regard, several POs told
    us that they considered Artesia to be too remote of a location to send
    their recruits and, especially, their instructors for training. The FLETC
    officials stressed that the Artesia campus could not, as currently
    configured, and discussed

    later, handle the transfer of the Border Patrol*s basic training from the
    Charleston campus to Artesia, as proposed in the Master Plan. If the
    transfer were to occur, the Border Patrol*s projected fiscal year 2003
    demand for training would exceed Artesia*s 5- day/ 8- hour capacity by at
    least 6,000 student weeks and up to 14,000 student weeks, depending on the
    schedule adopted.

    Page 17 GAO- 03- 736 Federal Law Enforcement Training Figure 4: FLETC
    Campus at Artesia, New Mexico Despite its strained capacity, FLETC has
    nevertheless been able to generally meet its POs* demand for basic
    training principally by, among

    other things,  operating on a 6- day, multiple- shift training week at
    its Glynco campus to overcome constrained resources;  deferring some
    training programs for certain POs that were not originally projected and
    that were made late in the year* for example, the Secret

    Service, Customs, and the General Services Administration*s Federal
    Protective Service made such requests;  canceling or deferring some of
    the POs* advanced training classes

    following the September 2001 attacks* FLETC rescheduled about 5 percent of
    these classes within the fiscal year;  continuing to schedule and conduct
    Border Patrol*s basic training at the

    Charleston campus, in cooperation with the Bureau of Customs and Border
    Protection/ Border Patrol;  rotating instructors to most needed areas of
    work; and  converting buildings and trailers that had been previously
    utilized for

    office space into training facilities such as raid houses, mat rooms,
    classrooms, and firearms simulations. FLETC Has Generally Met PO Needs for
    Basic

    Training

    Page 18 GAO- 03- 736 Federal Law Enforcement Training We note that while
    this approach may have helped mitigate the capacity constraints in the
    short term, deferring or canceling training may

    exacerbate any potential future strains on FLETC capacity* this training
    would likely need to be made up sometime in the future* and result in law
    enforcement personnel not being available for duty when needed.

    POs offered a variety of views about the effect of FLETC*s strained
    capacity on their training, in terms of, among other things, trainee
    attrition, the quality and timeliness of instruction, and instructor
    morale and retention. For example, representing the views of Justice POs
    (prior to their transition to DHS), a senior Justice official said that
    the strained capacity* and especially the need to train 6 days a week at
    Glynco* had resulted in higher attrition rates for trainees and fatigue,
    burnout, and low morale for instructors. In addition, according to this
    official, the quality of instruction, and thus that of the training
    received, had suffered. Further, a

    May 2002 internal Justice report on FLETC training issues noted that one
    of its component agencies had to cancel all of its *badly needed* advanced
    training due to the lack of space at FLETC. In commenting on a draft of
    this report, FLETC said that the PO was actually asked to shift its
    training within the fiscal year but declined to do so. The Justice report
    also noted that the 6- day training arrangement caused additional problems
    for Justice POs, including having to pay overtime and having difficulty in
    attracting and retaining instructors. Separately, a former Treasury PO
    reported that FLETC had to defer basic training for 168 agent recruits
    because of

    capacity constraints* since they could not be trained, and thus not
    deployed, these recruits were assigned nonagent, desk work. Basic training
    for recruits hired by September 2002 was to be completed in about 11
    weeks. However, capacity strains caused FLETC to train the recruits in
    stages, with some not completing their training until February 2003. FLETC
    officials disputed the POs views that capacity constraints had had a
    negative impact on training. These officials said that based on FLETC*s
    own data for the period of the capacity constraints, overall student test
    scores had not declined in a statistically significant manner over time,
    and student surveys continued to show a high level of satisfaction with
    FLETC*s training services. Regarding the aforementioned example of the
    Treasury PO deferral, FLETC said that the PO*s request was for 240
    students and was not initially projected. FLETC also said that it was
    actually able to accommodate immediately 72 of the students.

    Other POs indicated that while their instructors and students generally
    experienced greater fatigue and stress as a result of FLETC*s capacity
    constraints, the quality of the training had not suffered significantly.
    For PO Views about the Effect

    of the Capacity Strains on Their Personnel

    Page 19 GAO- 03- 736 Federal Law Enforcement Training example, one PO said
    that although there was a slight decline in student test scores, it was
    unclear whether this decline could be attributed

    exclusively to the capacity strain. The same PO reported that the extended
    hours resulting from the constraints actually allowed its trainees to
    complete their training in 9 weeks instead of 11, allowing them to be
    deployed to duty assignments sooner.

    FLETC*s implementation of 6- day, multiple- shift training at Glynco to
    help alleviate the capacity constraints at that campus has led to the
    intensive scheduling of its facilities. Such above- average usage of
    facilities places additional loads and strains on their systems and
    components, increasing the need for maintenance and repair. 14 Maintenance
    programs and renovation projects are often deferred, according to FLETC
    officials, due to the lack of funding or an ability to only schedule
    facility *down time* for maintenance in the evenings and on Sundays.
    Cheltenham, for example, has an electrical system that is subject to
    failure at any time and a chlorination system that has failed, resulting
    in the need to provide bottled water for drinking. At the time of our site
    visits, utility upgrades were needed at Glynco, Cheltenham, and Artesia,
    and road and parking upgrades were needed at Glynco and Cheltenham; many
    facilities at Glynco are now only available for maintenance during evening
    hours or on Sundays. Although not quantifiable at this point, continued
    deterioration of facilities would likely lead to increased capital
    requirements in the future and adversely affect employee working
    conditions and retention. 15 FLETC has considered the degradation issue in
    some of its internal

    reports; however, FLETC does not have any immediate contingency plans to
    address facility degradation. Such planning would be vital to help address
    the potential impact of facility degradation on FLETC*s already strained
    capacity. Many organizations use periodic facility condition assessments
    to establish baseline facility data and to aid in planning for short- and
    long- range facility maintenance and repair needs. Currently, FLETC does
    not have detailed information about the condition of its facilities. A
    *Facility Condition Index* (FCI) would help to address the degradation
    issue by giving measurable performance data about its facilities rather
    than relying on anecdotal information. An FCI is the ratio

    14 National Research Council, *Stewardship of Federal Facilities* A
    Proactive Strategy for Managing the Nation*s Public Assets,* (Washington,
    D. C.: National Academy Press, 1998). 15 Ibid. Capacity Strains Have

    Impacted the Condition of Facilities and Supporting Infrastructure

    Page 20 GAO- 03- 736 Federal Law Enforcement Training of the cost of
    maintenance and repair deficiencies to the facility*s current replacement
    value. A FCI value of less than 0.05 is generally considered to

    represent a *good* facility condition. The draft final version of the
    Master Plan concluded that although FLETC had done a commendable job in
    handling the ever- increasing demand for training, it had done so at a
    price. Part of this price has been the degradation of its facilities*
    funding has been focused on building new facilities to alleviate choke
    points, while maintenance and renovation have been continuously deferred
    due to the lack of funding. Echoing our own concerns about this issue, the
    firm that developed the plan concluded that continuation of this cycle
    will eventually result in building element or critical infrastructure
    failures and made recommendations for renovations and expansion as part of
    its broader three- phase approach for improving

    and expanding FLETC*s capacity. The Master Plan*s recommendations for
    renovation and expansion of existing, and the construction of new
    facilities are arrayed in three, partly overlapping, 5- 7 year
    construction phases for each of the campuses (except Charleston, which
    FLETC had, at the time the Master Plan was being developed, assumed would
    close by 2004). The first phase of construction extends at maximum from
    2006 to 2011, the second from 2009 to 2015, and the third from 2013 to
    2019. Each phase includes a mix of renovation and expansion projects, as
    well as the construction of new facilities. According to FLETC, the extent
    of additional capacity, in terms of student weeks, would depend on the
    completion of the construction projects, the programmatic mix, and other
    factors (e. g., the requisite staffing being available). As shown in table
    2, if the plan*s prioritized list of construction projects for phase 1
    were to be completed, and the programmatic mix and other factors did not
    change, the capacities of Glynco and Artesia would increase as follows:
    for Glynco, 193,500 student weeks for the 5- day/ 8- hour schedule,
    232,000 student weeks for the

    6- day/ 8- hour schedule, and 278,000 student weeks for the 6- day/ 12-
    hour schedule; for Artesia, 55,000 student weeks for the 5- day/ 8- hour
    schedule, 66,000 student weeks for the 6- day/ 8- hour schedule, and
    79,000 student

    weeks for the 6- day/ 12- hour schedule. The Cheltenham campus is not
    included since it is being upgraded and FLETC currently does not intend to
    use the campus as a residential facility. FLETC Master Plan

    Intended to Help Alleviate Capacity Constraints

    Page 21 GAO- 03- 736 Federal Law Enforcement Training Table 2: Potential
    Campus Capacities Following Completion of Phase I Master Plan Projects (in
    student weeks) Campus 5- day/ 8- hour 6- day/ 8- hour 6- day/ 12- hour

    Glynco 193,500 232,000 278,000 Artesia 55,000 66,000 79,000

    Total 248,500 298,000 357,000

    Source: GAO analysis of FLETC data.

    The April 2003 final draft of the plan estimates the combined cost of the
    three phases to be about $907 million; the estimate includes costs for
    construction and furnishings and fixtures but excludes operation and
    maintenance (O& M) costs. O& M costs are estimated separately for the
    period of 2008 through 2040 from the project costs and total about $269
    million.

    The FLETC Master Plan*s assumptions and methodologies in particular, and
    FLETC*s plan to address its capacity constraints in general, raise a
    number of concerns. First, the plan assumes that the Border Patrol will
    shift its basic training from the Charleston campus to the Artesia campus
    and that the Charleston campus will close. 16 However, as indicated
    earlier, the Consolidated Appropriations Resolution, 2003 (Public Law 108-
    7), established the Charleston *law enforcement training facility* as a
    permanent training facility. While the Department of Defense
    Appropriations Act, 2003 (Public Law 107- 248) directed the Secretary of
    the Navy to transfer administrative jurisdiction of the Charleston law
    enforcement training facility to, in effect, the DHS, it is not clear
    whether FLETC will be the entity within the department to assume
    responsibility of the facility, and which FLETC POs, if any, will receive
    training there.

    16 There were, in the past, some congressional committee expectations that
    the temporary training facility at Charleston would close. In 1998, for
    example, a House Appropriations Committee report, citing a commitment to
    the principle of consolidated federal law enforcement training through
    FLETC, expressed an expectation that the administration would strive to
    close the temporary training facility at Charleston. H. R. Rep. No. 105-
    592 (1998). In March 2000, the then Director of FLETC testified before the
    Senate Committee on Appropriations, Treasury and General Government
    Subcommittee, that plans, at that time, called for Charleston to be closed
    by the fiscal year 2004 time frame, once the training requirements for the
    new Border Patrol hires were completed and/ or new facilities became
    available to accommodate the training at FLETC*s permanent locations. S.
    Hrg. 106- 712 at 152 (March 30, 2000). FLETC*s Planning to

    Address Its Capacity Constraints Raises Concerns

    Page 22 GAO- 03- 736 Federal Law Enforcement Training Second, the Master
    Plan assumes that the training schedule at Glynco will return to a 5- day/
    8- hour week, but a FLETC official acknowledged that a

    return to such a shift for basic training is unlikely in at least fiscal
    year 2004, given the current and projected demands for training at the
    campus. Third, the plan assumes a set of baseline projections of future
    demand for training for each of the campuses from which future facility
    needs are generated. These Master Plan projections are lower than the
    latest projected attendance levels that FLETC is currently facing.
    Specifically, while several baseline workload scenarios were originally
    considered, only one was actually utilized to estimate the future need for
    facilities. Using a single baseline is questionable because it excludes
    accounting for possible future increases or decreases in the demand for
    training that would render the original baseline obsolete.

    Fourth, the plan assumes constant (or straight- line) growth rates in
    projecting the need for additional facilities at each FLETC campus.
    However, these growth rates are based on historical precedent and do not
    fully take into account recent events such as today*s new security
    environment and the resulting surge in the demand for training of law
    enforcement personnel, and do not take into account future events such as
    potential further surges, or declines, in training demand, or changes in
    the attrition of federal law enforcement personnel. Finally, the plan does
    not assume potential efficiencies that might result from FLETC*s planned
    automation of its system for scheduling training (discussed below). Use of
    such an automated system could result in more efficient scheduling of
    facilities. The firm that developed the plan acknowledges that if
    efficiencies were to be achieved through the automation of scheduling, the
    plan would need to be revised.

    Concerns about FLETC*s planning also involve the Master Plan*s cost
    estimates and future budget requests for construction and the extent to
    which the plan*s phase 1 recommendations would be implemented in time to
    begin alleviating the capacity constraints. Regarding the cost estimates,

    the Master Plan*s estimates should be treated with considerable caution.
    Specifically, although we did not analyze the plan*s estimates in detail,
    we note two broad concerns. First, because the plan*s recommendations have
    not proceeded beyond the conceptual or early design stage, the cost

    estimates are likely to be very *soft,* with considerable potential upside
    tendency* at the conceptual stage; costs are likely to vary by as much as
    50 percent. Second, the plan*s recommendations and their design may be
    altered by DHS as part of its ongoing review of the plan (discussed
    later),

    thus changing the estimated costs. Further, a FLETC official said he
    identified a number of cost errors as part of his review of the April 2003

    Page 23 GAO- 03- 736 Federal Law Enforcement Training version of the final
    draft of the plan* these errors involved life cycle- costs, O& M costs,
    and architectural and engineering fees. We also found, and

    brought to FLETC*s attention, cost discrepancies between the 90- percent
    and final draft versions of the plan*s phase 1 construction totaling over
    $100 million. For the entire plan, the discrepancies totaled over $200
    million. A FLETC official concurred that there were discrepancies and told
    us that FLETC was working to resolve them. In terms of future budget
    requests for construction, the estimated costs for the first phase of the
    Master Plan are more than five times the total appropriated amounts for
    new facilities and renovations for fiscal years 2001 through 2003 and the
    request for fiscal year 2004. A FLETC budget official said that in terms
    of lead time to fund the plan*s recommendations, FLETC, in keeping with
    its past practice, would likely request the entire amount up front for all
    approved projects. Based on capital acquisition best practices, this
    approach is not unusual in the construction field. In this regard, a DHS
    official said that a request for construction expenditures for training
    facilities was not expected until the fiscal year 2005 budget cycle.

    In terms of the timely implementation of the Master Plan*s
    recommendations, construction of the projects recommended in the plan*s
    first phase would not begin to be completed until 2008 at the earliest,
    leaving a gap of at least 5 years of continued strained capacity that
    would need to be addressed through other means.

    Adding to the long- term challenge of addressing its capacity constraints,
    FLETC does not currently have a formal written training contingency plan
    independent of the Master Plan for addressing its immediate training
    capacity challenges, or the challenges leading up to when the plan*s
    recommendations are expected to come on line in 2008. FLETC officials said
    that although they would like to have a written training contingency plan,
    and had been developing a contingency planning process, they were
    operating in an essentially reactive mode to address the more immediate
    issue of responding to continuing surges in the demand for training. In
    this regard, a FLETC official said that in this regard it would consider
    adding

    more shifts to the Glynco campus if needed. Further, FLETC neither has, as
    a routine practice, utilized alternative training assets to provide basic
    training for its federal POs (including offsite training locations, e-
    linkages, and satellite communications), nor does it have a formal plan
    for doing so. FLETC officials indicated that these measures were to be
    given more consideration in the future as a means of addressing campus
    capacity strains. FLETC officials explained that they FLETC Does Not Have
    a

    Contingency Plan to Address Capacity Constraints and Has Not Routinely
    Utilized Alternative Assets to Provide Basic Training

    Page 24 GAO- 03- 736 Federal Law Enforcement Training had been reluctant
    to provide PO training in facilities they did not own because they could
    not control the training schedule, given the absence of

    ongoing arrangements with the owners of such facilities. Instead,
    according to FLETC officials, on a limited and informal basis, FLETC
    facilitated the use of alternative training facilities by some law
    enforcement agencies when it could not immediately accommodate their
    training needs. A FLETC working group initiated by DHS is currently
    reviewing the extent to which training assets* in addition to the FLETC
    campuses* owned by DHS component agencies can be used for training. DHS
    officials said that the department was in the process of reviewing the
    Master Plan, to be followed by an OMB review. Without offering details,

    they also said that although useful in some respects, the plan might not
    be germane as the department develops its vision of law enforcement
    training for FLETC. These officials said they considered the plan useful
    as a tool in identifying the condition of existing FLETC facilities and
    the need for expansion. However, they did not view the plan as a roadmap
    for the future. A DHS official expected the review process of the plan to
    be completed by mid July 2003.

    In concert with its review of the Master Plan, DHS has tasked FLETC to
    chair a working group* the Training Academy Charter Committee* comprised
    of department component agencies to inventory their training assets and
    develop a coordinated strategy so that these assets are used effectively
    to provide training. FLETC*s specific task is to develop a survey
    instrument, collect and analyze the survey results, and play a role in
    developing recommendations. A FLETC official expects the committee*s work
    to be completed by July 2003.

    Within the context of strained training capacity, FLETC*s scheduling
    process poses internal control risks. FLETC relies on a predominantly
    manual scheduling process that does not ensure the efficient use of
    training resources and poses internal control risks due to potential loss
    of scheduling materials and the lack of backup documentation. FLETC has
    recognized these risks and is in the process of acquiring an automated
    system, SASS, to address them. Although FLETC*s plans and activities for
    acquiring SASS generally include performance of certain key acquisition

    management functions, FLETC officials have yet to address important risk
    management issues associated with its SASS acquisition. Moreover, with the
    exception of its SASS solicitation, FLETC*s plans and activities do not
    incorporate recognized best practices for acquiring commercial off- the
    DHS Is Reviewing FLETC*s

    Master Plan, but Considers It of Limited Future Use

    FLETC*s Current Scheduling System Is at Risk and Its Acquisition of an
    Automated System Raises Concerns

    Page 25 GAO- 03- 736 Federal Law Enforcement Training shelf- based
    systems. FLETC*s solicitation activities have not adequately addressed
    SASS security requirements. Taken as a whole, this means that

    FLETC*s SASS acquisition is currently at risk of not delivering a system
    solution to best meet its needs. While FLETC continues to develop the SASS
    request for proposals (RFP)* at our urging, it is also working with the
    Border Patrol to determine whether its existing ACMS can be used instead
    of acquiring SASS.

    FLETC*s current system for scheduling training places efficient delivery
    of training services at risk. FLETC*s scheduling system is predominantly
    manual and only partly automated. The manual part of the system involves,
    among other things, the use of large desk calendars, colored markers, and
    color- coded post- it notes to schedule things such as student classes,
    student housing, classrooms, instructors, language and computer
    laboratories, firing ranges, driving ranges, and mat rooms. As schedules
    change, for example, the notes are moved on the calendar to different
    dates; cut- and- pasting is also used to change schedules. Markers are
    used to color blocks of dates for training by particular POs. FLETC*s
    scheduling subsystems at three of the four 17 campuses are also
    predominantly manual systems that require labor- intensive corrections if
    even one course is changed. In addition, the scheduling subsystems do not
    interface with one another, thus requiring time- consuming efforts to
    communicate.

    The paper- intensive nature of the system raises issues of internal
    control. FLETC*s ability to adequately schedule training for most of its
    75 POs at its campuses is further hampered by its reliance on certain key
    schedulers to keep the system functioning. The campuses in Charleston and
    Artesia each

    have a single scheduler to handle all of the scheduling, without any
    backup. Further, at the Glynco campus, the loss of key scheduling
    documents that are currently kept in a single *master binder* without a
    backup could significantly hamper FLETC*s scheduling. FLETC schedulers
    said that if this binder were to be lost or destroyed, they would have to
    undertake a time- consuming process to manually recreate most of the

    training schedules by soliciting relevant information from affected POs.
    In this regard, according to the Comptroller General*s standards for
    internal 17 At FLETC*s fourth campus, in Cheltenham, Maryland, the Capitol
    Police reports its daily student throughput to FLETC*s Cheltenham
    Scheduling Office and schedules use of buildings and grounds. Current
    Scheduling System

    Places the Delivery of Training Services at Risk and Does Not Maximize Use
    of Existing Facilities

    Page 26 GAO- 03- 736 Federal Law Enforcement Training control, 18
    vulnerable assets, in this case the master binder, should be subject to
    secure physical control in order to be safeguarded against loss;

    in addition, a disaster recovery plan helps recover from a loss. The
    standards also call for the accurate and timely recording and
    documentation of transactions and significant events, in this case the
    scheduling of training. According to the standards, documentation of
    transactions and events needs to be complete and accurate to facilitate
    tracing from initiation to completion. FLETC has acknowledged the manual
    scheduling system*s shortcomings

    and its implications for efficiency and risk management. FLETC officials
    told us that its scheduling system does not provide for the optimal use of
    existing facilities, especially for sequencing classes. For example, only
    one class can use a 4- course driving range at any given time; while the
    class completes one course, the other three remain idle. More efficient
    scheduling would enable four classes to rotate through the driving range*s
    courses. The Master Plan*s analysis also suggests that automating the

    scheduling could help gain efficiencies in the use of existing facilities.
    FLETC officials have recognized the need for a fully automated system that
    can address FLETC*s vast scheduling needs, including quickly incorporating
    any changes once a schedule has been prepared. In this regard, FLETC
    listed in its draft SASS RFP the challenges, and their effects, associated
    with its manual system. The draft RFP stated that current business
    processes in support of FLETC*s student administration and scheduling were
    complex, not integrated, and were often performed

    manually. Historically, according to the draft RFP, this has resulted in
    (1) FLETC schedulers reacting to ever- changing training projections; (2)
    a manual, paper- laden, and slow student scheduling and registration
    process requiring student information to be entered into multiple data
    systems; and (3) inconsistent student information processed throughout the
    system and numerous changes caused by ever- changing projections in the
    demand for training. A FLETC official also said that a manual
    recalculation and

    distribution of class schedules each time a change is made to a single
    class.

    18 See U. S. General Accounting Office, Internal Control Standards:
    Internal Control Management and Evaluation Tool, GAO- 01- 1008G
    (Washington, D. C.: Aug. 2001).

    Page 27 GAO- 03- 736 Federal Law Enforcement Training The SASS acquisition
    project began in 1999, when Congress provided FLETC with $350, 000 to
    begin planning for automating its scheduling

    process. After completing requirements definition in December 2000 and its
    market research activities in December 2001, FLETC decided to expand the
    project to provide a training management system, rather than just a
    scheduling system. In researching SASS alternatives, FLETC officials
    determined that utilizing commercially available components or products
    was its preferred alternative. Accordingly, FLETC decided to pursue a
    COTS. FLETC began developing its request for vendor proposals in 2001 and
    in May 2002 FLETC issued a request for proposals, a solicitation package
    that included background on the project, project objectives, system
    requirements, and other information. However, according to FLETC
    officials, vendors were concerned about the time and expense required to
    submit an adequate proposal as well as the criteria proposed to evaluate
    potential solutions. As a result, FLETC withdrew the solicitation

    and is currently revising it to address these concerns. According to a
    FLETC official, issuance of the SASS RFP has been delayed, pending the
    outcome of an effort to determine whether a similar system being developed
    separately by the Border Patrol, Customs, and INS can be used by FLETC.
    This effort is discussed in the following sections.

    FLETC plans to implement SASS within a 1- year period after signing a
    contract, and officials estimate an approximate 5- year cost of $10
    million (1 base- year and 4 option- years, including maintenance). SASS is
    a subproject within an overall FLETC information technology (IT)
    modernization project. Because FLETC intends to encourage vendors to be
    innovative in offering possible solutions, the system requirements to be

    included in the solicitation are for information purposes only. For
    example, FLETC officials said that SASS may or may not be physically
    located at FLETC*s Glynco campus, depending on the selected solution, but
    all four facilities should have access to the system.

    FLETC*s plans and activities for acquiring SASS generally include the
    performance of certain key acquisition management functions, such as
    acquisition planning, solicitation, requirements management, and project
    management. However, first, FLETC has yet to focus on another key
    acquisition function* risk management. Second, with the exception of
    solicitation, FLETC*s attempt to obtain a COTS- based system lacks some
    acquisition best practices. These practices call for continuous tradeoff
    among such interdependent acquisition variables as system requirements,
    commercially available system products and components, cost and schedule
    constraints, and the architectural environment within which the Background
    on the SASS Acquisition

    FLETC Has Yet to Address Important SASS Acquisition Issues

    Page 28 GAO- 03- 736 Federal Law Enforcement Training system will operate.
    Third, FLETC solicitation activities have not adequately addressed SASS
    security requirements. Taken as a whole, this

    means that FLETC*s SASS acquisition is currently at risk of not delivering
    a system solution to best meet FLETC*s needs.

    Carnegie Mellon University*s Software Engineering Institute (SEI),
    recognized for its expertise in acquiring software- intensive systems, has
    published an acquisition management model that defines key acquisition
    functions and assigns them to five incremental stages of maturity. 19
    According to SEI, the following acquisition functions are part of a

    minimum set that need to be practiced in order for software- intensive
    systems to be acquired in a repeatable, effective manner: acquisition
    planning, solicitation, requirements management, and project management.

    On its SASS acquisition, FLETC is performing these functions in a manner
    that is generally consistent with SEI*s maturity model, as described
    later. According to FLETC officials, these functions are being performed
    because they are following agency IT guidance that specifies processes and
    procedures for acquiring and managing IT investments. By performing them,
    FLETC is providing a margin of assurance that SASS will be effectively
    acquired.

    Acquisition planning. The purpose of acquisition planning is to ensure
    that reasonable planning for the acquisition is conducted and that all
    elements of the project are included. Among other things, this involves
    assigning project responsibilities and documenting an acquisition strategy
    that specifies, for example, acquisition objectives and methods, project
    constraints, contract types and terms, and schedule and cost estimates.
    For SASS, FLETC is performing these activities. Responsibility for the
    acquisition has been assigned to IT and contracting personnel. FLETC has
    also documented an acquisition strategy that defines acquisition
    objectives and methods (e. g., maximum use of commercial products) and
    project constraints (e. g., FLETC*s right to inspect all services
    provided). FLETC has also defined a contract type and terms, (5- year,
    fixed cost with award fee), and it estimates that the selected system will
    be implemented within 1 year of contract award and cost about $10 million
    over the 5- year contract period.

    19 Software Engineering Institute, Software Acquisition Capability
    Maturity Model(R) Version 1.03, CMU/ SEI- 2002- TR- 010 (Pittsburgh, PA:
    March 2002). Certain Acquisition Functions

    Are Being Performed

    Page 29 GAO- 03- 736 Federal Law Enforcement Training Solicitation. The
    purpose of solicitation is to prepare a documentation package that
    identifies acquisition needs and selects the best provider and

    solution to meet those needs. Examples of solicitation practices include
    educating end users and others about the planned solicitation and engaging
    them in developing a solicitation package that includes objectives;
    technical and other product evaluation criteria; and contract acceptance
    procedures, criteria, and payments. FLETC has done this for the SASS
    acquisition. The SASS project office has engaged FLETC*s training
    divisions in developing the package and educated them about business
    process changes that may need to accompany the system*s implementation.
    Further, the solicitation package 20 (i. e., RFPs) contains FLETC*s
    objectives for the overall acquisition; evaluation criteria; and
    acceptance procedures, criteria, and payment methods.

    Requirements management. The purpose of requirements management is to
    establish a common and unambiguous definition of requirements that is
    understood by users, the project team, and suppliers. Requirements
    management includes, among other things, establishing the project scope,
    assigning specific responsibilities for managing the requirements,
    collecting end- user input, and establishing a baseline set of
    requirements before releasing the solicitation. FLETC has done this. For
    example, FLETC has defined the project scope to be a total system solution
    for student registration and scheduling. FLETC has also assigned
    requirements management responsibilities to an integrated process team,
    obtained user input by canvassing FLETC training divisions and having them
    verify the system requirements, and established a baseline requirements
    set in a December 2000 software requirements specification. Project
    Management. The purpose of project management is to manage

    project office activities and support units to ensure a timely, efficient,
    and effective acquisition. Examples of project management practices are
    defining project responsibilities, engaging user organizations, and
    identifying project costs and schedules. FLETC has performed each of
    these. Namely, an IT project manager, supported by a staff project office,
    is in place, training division heads are participating in the project, and
    cost and schedule estimates have been developed.

    20 FLETC issued a SASS RFP in 2002. However, because of vendor complaints
    about the potential costs involved in preparing their respective
    proposals, FLETC withdrew the request and is now revising it.

    Page 30 GAO- 03- 736 Federal Law Enforcement Training SEI*s acquisition
    model also recognizes the need to manage acquisition risks. Moreover, many
    software acquisition experts consider risk

    management to be one of the most important acquisition areas. The purpose
    of risk management is to identify risks as early as possible, manage those
    risks, and develop and implement a risk management process. Risk
    management includes identifying risks and categorizing them based on
    probability and impact, developing risk mitigation strategies,
    implementing the strategies, and tracking and reporting on progress.

    During our review, FLETC officials told us they had yet to begin risk
    management activities, or establish any type of risk management function,
    and they did not plan to begin such activities until they receive the

    vendors* proposals. Following our inquiry, officials told us they (1)
    recognize that risk management is important to overall project success;
    (2) have a rough draft of a risk management plan; and (3) in May 2003,
    developed a project risk assessment plan for SASS. FLETC has not

    provided us with these documents, and not having completed these actions
    at this point is not consistent with SEI guidance, which advocates early
    and continuous management of risks so as to minimize the chances

    of risks becoming actual problems (i. e., system cost, schedule, and
    capability shortfalls). By waiting to manage risks, FLETC is not
    proactively mitigating known SASS risks; such as those that SEI reports to
    be inherent in a COTS- based acquisition (e. g., volatility of the
    commercial market and

    organizational resistance to business process changes required by a
    COTSbased solution). The result is a reduced probability of delivering
    promised SASS capabilities on time and within budget.

    Notwithstanding the fact that FLETC is performing key SASS acquisition
    functions, it is deficient in its performance of these functions in two
    ways. First, its solicitation package does not adequately address system
    security. Second, with the exception of solicitation, FLETC has not
    adequately provided for the use of COTS- based system acquisition best
    practices in performing these functions. According to FLETC officials, the
    former is an oversight that they have hired a security manager to address,
    and the latter is a byproduct of their focus to date on solicitation
    activities. They added that they plan to incorporate COTS- based system
    acquisition best

    practices in their performance of other SASS acquisition function as soon
    as the solicitation is released. Until they do, the SASS acquisition is at
    risk of not delivering FLETC users with a secure, long- term, cost-
    effective system to support FLETC*s mission needs. Acquisition Risk
    Management

    Is Not Being Performed Approach to Performing Acquisition Functions Lacks
    Two Key Elements

    Page 31 GAO- 03- 736 Federal Law Enforcement Training Security. Since
    1997, we have designated information security as a governmentwide, high-
    risk area because of significant and pervasive

    agency weaknesses in controls over computerized operations, due, in part,
    to the government*s increasing reliance on commercially available
    information technology. 21 Addressing these risks requires that agencies
    ensure that adequate security controls are part of every new system
    acquisition and deployment. In the case of SASS, this means that FLETC

    needs to, among other things, adequately specify its security requirements
    in the SASS solicitation package. However, FLETC has not done so. For
    example, the SASS security requirements reference the Computer Security
    Act of 1987 22 but do not specify relevant National Institute of Standards
    and Technology guidelines. 23 These guidelines, for example, specify
    authorization and access controls. After we brought this to the attention
    of FLETC officials, they said that this was an oversight, that they have
    hired a

    security manager to address this area of concern, and that the revised
    solicitation package will include missing security requirements. If it
    does not, FLETC risks acquiring and deploying a system that will not be
    secure.

    COTS- based System Acquisition Practices. SEI research shows that the
    market- driven capabilities embedded in commercial products and components
    necessitate that organizations not be overly requirements focused when
    acquiring COTS- based systems. Rather, SEI advocates that organizations
    plan and execute these acquisitions in a manner that recognizes the
    competing interests* and necessary tradeoffs* among four acquisition
    variables: system requirements, the organization*s architectural
    environment (current and future) that the system needs to operate within,

    21 U. S. General Accounting Office, High Risk Series: Protecting
    Information Systems Supporting the Federal Government and the Nation*s
    Critical Infrastructures,

    GAO- 03- 121 (Washington, D. C.: Jan. 2003). 22 The Computer Security Act
    of 1987, as amended, (P. L. 100- 235, 101 Stat. 1724 (1988) requires
    federal agencies with computer systems that process sensitive information
    to identify and develop security plans for the systems and to provide
    periodic computer security training to personnel managing, using, and
    operating these systems. The Act defines sensitive information as any
    information that if lost, misused, or accessed or

    modified without proper authorization could adversely affect either the
    national interest or conduct of federal programs, or the privacy to which
    individuals are entitled under the Privacy Act of 1974 (P. L. 93- 579).

    23 See, for example, National Institute of Standards and Technology,
    Guidelines to Federal Organizations on Security Assurance and Acquisition/
    Use of Tested/ Evaluated Products: Recommendations of the National
    Institute of Standards and Technology, NIST SP 800- 23 (Aug. 2000) and
    Guide For Developing Security Plans for Information Technology Systems,

    NIST SP 800- 18 (Dec. 1998).

    Page 32 GAO- 03- 736 Federal Law Enforcement Training the cost and
    schedule constraints that limit the system acquisition, and the
    commercially available system products and components (current and

    future). 24 According to SEI, analyzing and understanding the tradeoffs
    among these variables are vital to informed decision- making and thus
    should be addressed early and continuously throughout a project*s life
    cycle. As such, provision for performing this fundamental tradeoff
    analysis and decision- making should be embedded in each acquisition
    function, including the ones that we reviewed for SASS.

    To FLETC*s credit, its solicitation plans and activities provide for
    employing these COTS- based system practices. For example, the
    solicitation does not prescribe a solution that is based upon customized,
    *must- have* requirements. Rather, FLETC provided *information- only*
    requirements, intended to provide an understanding of the nature of its
    scheduling process needs and environment so as to maximize the flexibility
    afforded vendors in proposing approaches to meet these needs. 25 However,
    FLETC*s SASS acquisition planning, requirements management,

    and project management efforts do not similarly provide for performing
    these COTS- based system acquisition practices. For example, the SASS
    acquisition strategy does not describe how FLETC will evaluate the
    tradeoffs among the four acquisition variables. Also, the SASS
    requirements document, although specifying requirements in a manner to
    provide prospective offerors flexibility, does not address the FLETC

    architectural environment (current and future) that the SASS solution will
    need to operate within. According to FLETC officials, they have not
    addressed this variable because they want the proposed SASS solution to
    drive this environment. Last, SASS project management planning does not
    include, for example, designated resources or a specific analytical

    approach and tool for performing the tradeoff analysis. Following our
    inquiries, FLETC officials told us that they have yet to incorporate these
    COTS- based system best practices into each SASS acquisition function
    because they have focused on the solicitation function. However, they
    added they recognize the need to address these issues and plan to complete
    them after the solicitation package is released. They also noted

    24 Software Engineering Institute, Evolutionary Process for Integrating
    COTS- Based Systems (EPIC): An Overview, CMU/ SEI- 2002- TR- 009
    (Pittsburgh, PA: July 2002). 25 FLETC*s solicitation utilizes a
    performance- based statement of objectives methodology that provides high-
    level business needs and describes the objectives that prospective
    offerors will be expected to achieve. FLETC officials said that this is
    intended to allow offerors to prepare their own statements of work and to
    propose innovative and costeffective approaches.

    Page 33 GAO- 03- 736 Federal Law Enforcement Training that while they had
    followed the best acquisition practices as defined by the SEI*s Software
    Acquisition Capability Maturity Model(R), they had not documented these
    efforts, but would do so in the future. We agree that

    FLETC has followed some, but not all of these best practices. As we stated
    earlier, FLETC has not followed software acquisition risk management best
    practices. In addition, SEI has issued best practices for acquiring COTS-
    based systems that FLETC is not following. Until they do,

    the SASS acquisition will be at risk of not meeting its cost, schedule,
    and performance commitments.

    During our work, we learned that the Border Patrol Academy, in conjunction
    with INS*s Immigration Officers Academy and the Customs Academy, were in
    the process of adding an automated scheduling module to their ACMS. The
    Border Patrol and Immigration Officer Academies currently use this system
    for processing non scheduling- related class management activities. We
    asked a Border Patrol Academy official, who brought the acquisition of the
    ACMS scheduling module to our attention, whether the module the academy
    was acquiring would potentially

    duplicate the scheduling functions of the proposed SASS that FLETC was
    about to acquire. The Border Patrol official said he did not know whether
    there would be any duplication between the systems. He also said that the
    Border Patrol Academy was acquiring its own system because it did not want
    to wait until FLETC acquired its system, suggesting that this process was
    moving too slowly. Furthermore, he said that the three academies had found
    an economically feasible way to add an automated scheduling module to
    ACMS.

    We encouraged academy officials, and a FLETC official involved in FLETC*s
    SASS acquisition, to meet and discuss the feasibility of FLETC using the
    ACMS scheduling module instead of acquiring its SASS. Although FLETC
    stated that it evaluated ACMS two years ago, these officials met and
    according to one FLETC official, agreed FLETC could, instead of
    potentially spending over $10 million in the cost of implementing SASS,
    invest considerably less to merge FLETC*s requirements into the ACMS
    automated scheduling module, which is still under development. Separately,
    according to FLETC, as a result of a request of the DHS Chief Information
    Officer, a FLETC- chaired working group looking at capacity issues within
    DHS was tasked to seek input on the SASS from its participants. That
    review was to obtain input toward identifying an enterprise- wide solution
    to training scheduling for all of the DHS. Another FLETC official said
    that the FLETC- chaired working group was FLETC Is Exploring the

    Use of an Existing Automated Scheduling System

    Page 34 GAO- 03- 736 Federal Law Enforcement Training considering whether
    to recommend SASS as the standard training scheduler, or, possibly, use
    ACMS as the standard.

    As of late July 2003, FLETC was in the process of obtaining its
    procurement and legal approvals to conduct a benchmark test on ACMS*s
    scheduling module, once it is completed and tested, to determine whether
    ACMS*s module could provide at least about 80 percent of the functions
    that the proposed SASS system could provide. 26 If ACMS was able to

    provide the needed functionality, FLETC would cancel its SASS RFP and
    merge into ACMS*s automated scheduling system, thus saving money while
    also meeting FLETC*s considerable training scheduling needs of its 75 POs.

    The status of FLETC*s Board of Directors is unclear. Further, the Board*s
    membership, roles and responsibilities, and past practices are not fully
    consistent with prevailing governance and management control best
    practices. Moreover, given its recent transition into DHS, FLETC needs
    guidance and oversight to address its transformational challenges. A DHS
    official said that DHS has recently assumed responsibility for FLETC and
    has begun to work with its officials on ways to address these challenges.
    The official also said DHS also recognizes the role an effective FLETC
    Board could play in enhancing governance.

    Prior to its most recent meeting in November 2002, FLETC*s Board of
    Directors had not met for 3- 1/2 years, according to a FLETC official.
    However, according to our review of Board minutes, the Board had not met
    for a period of 5 years prior to its November 2002 meeting (the last
    recorded meeting was held in November 1997). According to the agenda of
    its November 2002 meeting, the Board was to address, among other things,
    26 According to a FLETC official, ACMS*s scheduling component does not
    have two

    elements that SASS would provide; he also said that the absence of these
    functions could either be overcome or were acceptable to FLETC. The first
    element is a *conflict resolution* capability to help resolve the
    sequencing of classes. According to the FLETC official, this could be
    resolved by using ACMS*s *priority* capability, under which schedulers
    would be able to schedule classes and facilities by placing them in
    priority order. For example, legal classroom training would have a higher
    priority than the subsequent mock courtroom training and, accordingly,
    would be scheduled before the courtroom training. The second element is
    speed* ACMS is not as fast as SASS would be. The FLETC official said that
    ACMS*s slower speed was acceptable because it was still

    faster than the current paper- intensive process. The Status of FLETC*s
    Board of Directors Is

    Unclear, and DHS Has Begun to Provide Oversight and Guidance

    The Status of the FLETC Board of Directors Is Unclear

    Page 35 GAO- 03- 736 Federal Law Enforcement Training its roles and
    responsibilities, the fiscal year 2003 and 2004 budgets, and FLETC*s
    Master Plan. The draft minutes from that meeting indicate that

    the Board discussed, in broad terms, Justice Department concerns about
    FLETC*s training services, including the availability of on- campus
    dormitory space. The Board also discussed the status of the FLETC MOU and
    the Master Plan, respectively, but did not discuss budget matters.
    Subsequent to the November meeting, a FLETC official who attended the
    meeting informed us that within the context of debating the Board*s roles
    and responsibilities, the matter of whether the Board would continue as an
    ongoing entity became unclear.

    In June 2003, a DHS official said an effective FLETC Board was important
    to the overall governance of FLETC activities. He also pointed out that
    DHS was in the process of determining how the training mission was to be
    managed in the new department. Issues under consideration include how PO
    training needs would be identified, where training would be offered, and
    how capacity and demand issues would be addressed. Determining the status,
    roles and responsibilities of the FLETC Board will be done within this
    context. Nevertheless, the DHS official acknowledged that having an
    effective Board would help FLETC to address its challenges.

    Notwithstanding the uncertainty surrounding its status, the Board*s
    membership, roles and responsibilities, and past practices are not fully
    consistent with prevailing best practices for governance and internal and
    management control. 27 Membership. Regarding the size of a board,
    prevailing governance best

    practices consider smaller boards to be often more cohesive and to work
    more effectively* in this regard, the FLETC Board is composed of eight
    members. Specifically, FLETC*s Board presently has five
    termrepresentatives who are voting members (one of whom has a 2- year
    rotational term) and three nonvoting members. FLETC*s Director serves as
    the nonvoting Executive Secretary of the Board. As of June 2003, the

    27 To identify the relevant prevailing best practices, we relied primarily
    on the May 2002

    Principles of Corporate Governance by the Business Roundtable, an
    association of chief executive officers of leading U. S. corporations;
    GAO*s 2001 Internal Control Standards: Internal Control Management and
    Evaluation Tool, (GAO- 01- 1008G, Washington, D. C.: Aug. 2001); and OMB*s
    1995 Circular No. A- 123, Management Accountability and

    Control. We also drew from our August 2002 report (unnumbered
    correspondence), on the governance of the U. S. Capitol Police, titled
    Information on Capitol Police Board Roles and Responsibilities,
    Operations, and Alternative Structures.

    Board*s Membership, Roles and Responsibilities, and Past Practices Are Not
    Fully Consistent with Prevailing Governance and Management Control Best
    Practices

    Page 36 GAO- 03- 736 Federal Law Enforcement Training Board*s five voting
    members were DHS*s Under Secretary for Border and Transportation Security,
    Justice*s Acting Assistant Attorney General for

    Administration, the Department of the Interior*s Deputy Assistant Attorney
    for Law Enforcement, the General Services Administration*s Inspector
    General, and the Administrator of TSA. The three nonvoting members of the
    Board are the Office of Personnel Management*s Senior Advisor for Learning
    and Knowledge, OMB*s Associate Director for General Government Programs,
    and the U. S. Capitol Police Board*s Chairman.

    Regarding the composition of the Board*s membership, there are two
    departures from governance best practices. First, the Director of FLETC is
    not a member of the Board, but, rather, its nonvoting Executive Secretary.
    Under governance best practices, the head of the organization being
    overseen by a board of directors is a full member of that board and, in
    fact, in many cases also serves as the chair of the board. There is
    currently a strong debate about this point. On the one hand, the Business
    Roundtable best practices view this dual role as serving as a bridge
    between an organization*s management and its board, ensuring that they
    both act with a common purpose. On the other hand, the Conference Board
    Commission on the Public Trust and Private Enterprise 28 recommends
    splitting the role of chief executive and chairman of the board to ensure
    an *appropriate

    balance* between the board and chief executive. Second, there is not a
    substantial degree of independence of FLETC Board members from its
    operations. As currently configured, all Board members are either related
    to a FLETC PO (e. g., TSA and Capitol Police) and/ or have a role in
    reviewing and/ or setting its budget (OMB) or policies (Office of
    Personnel Management). Governance best practices stress that a substantial
    part* in most cases, a majority* of a board*s membership should be
    independent of the entity it is overseeing. Such independence could help
    avoid, among other things, potential conflicts of interest. Further,
    independent board members, knowledgeable of information about the
    organization they are overseeing, can provide a useful perspective on the
    significant risks and challenges facing that organization 28 See, for
    example, a report by The Conference Board Commission on Public Trust and
    Private Enterprise titled Findings and Recommendations, New York, New
    York, January

    2003. The Conference Board is a leading business network that creates and
    disseminates knowledge about management and the marketplace. According to
    its report, the Conference Board created the Commission to help address
    the causes of declining public and investor trust in companies, their
    leaders, and capital markets. The 12- member commission included a former
    Comptroller General of the United States and the current Secretary of the
    Treasury.

    Page 37 GAO- 03- 736 Federal Law Enforcement Training and help ensure the
    exercise of independent judgment that is at the core of a board*s
    oversight function. The 1970 FLETC MOU that established the Board allows
    for the expansion* and, implicitly, a change in its

    composition* of its membership by a majority vote of its members.

    Roles and Responsibilities. The 1970 FLETC MOU, as amended, enumerates the
    Board*s *final authority* over training policy, programs, criteria, and
    standards of FLETC for resolving matters of conflicting training
    requirements. This authority includes (1) establishing priority systems
    governing the scheduling of courses and use of training facilities; (2)
    establishing policy as to student residence requirements, leave, and other
    matters relating to student administration; (3) reviewing FLETC*s budget
    as to whether it meets its mission and making budget recommendations to,
    now, the Secretary of DHS; and (4) evaluating the effectiveness of the
    overall training program. The Board also has authority to establish
    criteria for the selection of the FLETC Director and to approve the
    selection; it may also recommend the removal of the Director to, now, the
    Secretary of DHS.

    Current FLETC officials have implemented the Board*s roles and
    responsibilities under the MOU as pertaining only to training issues, and
    not operational issues concerning FLETC, such as the budget and the
    selection of the FLETC Director. In this regard, the current FLETC
    Director who was appointed by the Secretary of the Treasury was selected
    independently of the Board because, at the time, it was dormant. Under
    governance best practices, however, the selection and oversight of an
    organization*s head is a board*s paramount duty to help ensure competent
    and ethical operation. As discussed earlier, under the FLETC MOU, the
    Board has the authority to establish criteria for the selection of the
    FLETC Director and to approve the selection. Additional oversight
    responsibilities for boards include reviewing and monitoring the
    implementation of strategic plans; reviewing annual operating plans and
    budgets; advising management on significant issues facing the
    organization; reviewing and approving significant actions; and nominating
    directors, and overseeing effective governance, including the composition,
    structure, practices, and evaluation of the Board. Past Practices. As
    discussed earlier, our review of minutes from past

    Board meetings showed that the Board did not meet for 5 years prior to its
    November 2002 meeting. The Board has not met since November 2002,

    Page 38 GAO- 03- 736 Federal Law Enforcement Training pending a decision
    on its status. 29 In this regard, FLETC*s own MOU stipulates that the
    Board shall meet quarterly, and at such other times as

    may be determined by a majority of the Board or its presiding officer.
    Further, governance best practices call for boards to meet as frequently
    as needed in order for members to discharge properly their
    responsibilities.

    In this regard, the *typical* board of a large publicly traded corporation
    meets about eight times a year.

    Other than what is broadly described in the FLETC MOU, the Board*s
    functions and processes implementing its roles and responsibilities are
    not documented. According to the relevant governance best practices, it is

    important that each board review its policies and practices on governance
    matters* the standard defers the formalization of such policies and
    practices in written form to the boards themselves, depending on the
    circumstances they face. On one hand, the standard points out that
    insufficient formalization often leads to a lack of clarity, while on the
    other hand, it cautions that over- formalization can lead to rigidity*
    emphasizing form over substance. GAO and OMB standards for internal and
    management control respectively, stress the need for written
    documentation. GAO*s standards for internal control require that an
    agency*s policies, directives, and operating procedures be clearly
    documented and available for examination. OMB*s standards for management
    control state that an organization*s authority, responsibility, and
    accountability should be defined and documented.

    The Board did not periodically review its structure, functions, and
    processes. According to governance best practices, boards should, from
    time to time, review their own structure, governance principles,
    composition, agenda, and processes to consider whether they are
    functioning well in view of their responsibilities and help ensure sound
    governance and oversight. GAO and OMB standards broadly suggest that
    periodic external evaluations of, among other things, an organization*s

    structure and functions help ensure that they are responsive to changing
    conditions. In this regard, FLETC is facing significant changes in its
    environment* the post- September 11 surge in demand for its services and
    its transition to DHS.

    29 FLETC officials said that at the conclusion of the Board*s November
    2002 meeting, a follow- up meeting was planned for January 2003. However,
    by early December 2002, the decision had been made to transfer FLETC to
    the newly created DHS. They said that taskings resulting from the
    transition delayed decisions regarding the Board. FLETC officials,
    however, said they would review the duties and purview of the Board.

    Page 39 GAO- 03- 736 Federal Law Enforcement Training DHS has the
    opportunity to help FLETC face its challenges during the current period of
    transformational change. DHS officials said that other

    competing priorities, such as building the organizational structure of the
    new department and addressing its role in the ongoing war on terrorism,
    did not permit them to focus extensively on providing policy or other
    guidance to FLETC about planning, scheduling, and governance (e. g.,
    oversight and accountability). A DHS official said that the department had
    recently started focusing on specific FLETC issues. In this regard, DHS
    plans to begin focusing on a broad range of issues, including the Master
    Plan and the FLETC Board of Directors.

    With respect to the Master Plan, the DHS officials said that in general,
    they viewed the plan as a useful document but not as the department*s
    guiding plan for the future of FLETC and its facilities. One official said
    that DHS was considering a new business plan for FLETC, one that would
    make DHS *more than just a landlord* regarding federal law enforcement
    training. This official further said* and a FLETC official separately
    corroborated* that DHS*s vision for FLETC would include expanding its
    authority on decisions related to federal law enforcement training.

    Overall, FLETC and DHS find themselves at a crossroads for defining and
    planning for the future of federal law enforcement training. The demands
    placed on FLETC and DHS by the new security environment facing the country
    are considerable. Yet, we note that while demand for training continues to
    surge, the fiscal year 2004 budget request for FLETC is about $26 million
    less than the fiscal year 2003 enacted level; the request for staffing
    calls for about 120 fewer permanent positions than those enacted for
    fiscal year 2003. The decline in resources risks exacerbating FLETC*s
    already- strained capacity to provide training.

    To meet the demands placed upon them, collective planning and execution by
    FLETC and its many stakeholders, and active and sustained oversight and
    guidance by DHS, are necessary to  achieve a proper balance between the
    surging demand for training and the

    necessary capacity to meet it;  schedule vital training in an efficient
    and timely manner; and  provide for effective governance and oversight
    that ensures that all

    stakeholders* interests are addressed. Despite the capacity constraints,
    FLETC generally received good marks from POs about its ability to meet
    their basic training needs. However, DHS Has Begun to Provide

    Oversight and Guidance to FLETC

    Conclusions

    Page 40 GAO- 03- 736 Federal Law Enforcement Training FLETC is facing
    considerable challenges in responding to the demand for training in a
    systematic manner. For example, FLETC*s overall planning effort is
    essentially reactive, rather than proactive. Specifically, FLETC

    does not currently have a formal contingency plan to help guide management
    decision- making with respect to capacity planning, although it has
    developed some planning documents (i. e., its 1989 Master Plan with

    updates and the current Master Plan). Although having an updated Master
    Plan to guide short- and long- term planning is a step in the right
    direction and may help provide some guidance to DHS, the final draft of
    the plan has methodological limitations and inaccurate cost estimates. In
    addition, FLETC has taken very limited action thus far in planning for the
    use of alternative training such as off- site training and e- learning.

    FLETC*s capacity challenges are likely to be compounded during its
    transition into DHS. This transformational change for FLETC and a number
    of its POs will likely bring considerable uncertainty, as the new
    department is equally likely to redefine the POs* missions to focus on
    homeland security. The redefined mission could result in the need for
    updated training programs and modules that, in turn, would require new or
    modified training facilities. A further uncertainty involves the type and
    scale of future terrorist attacks and the response by the federal
    government. A comprehensive planning process, encompassing, among other
    things, sound methodologies and contingency planning, is essential to help
    meet the current capacity challenges facing FLETC, and also will help
    position it to meet future challenges.

    FLETC faces a challenge to automate the scheduling of training for its 75
    POs. Notwithstanding its performance of certain important system
    acquisition functions, FLETC is not doing enough to ensure that it
    acquires a system that will optimally support its current and future
    mission needs.

    Without instituting a proactive risk management function, FLETC increases
    the risk that avoidable potential problems will become costly actual
    problems, meaning they would result in a less capable system being
    delivered late and/ or over budget. Further, and equally important, delays
    in making both security and COTS- based acquisition best practices
    integral

    to its SASS project could exacerbate potential problems. Without
    adequately addressing both, FLETC increases the risk of the system not
    being adequately protected against unauthorized access and corruption, not
    being available when needed, and not performing as intended. It is
    important that FLETC address its SASS acquisition management weaknesses
    before the project advances much farther. Although FLETC is in the initial
    stages of acquiring SASS, we are encouraged that through in part our
    intervention, it is also in consultation with the Border Patrol

    Page 41 GAO- 03- 736 Federal Law Enforcement Training whether its ACMS,
    with some modification, might serve FLETC scheduling needs, thus saving an
    estimated $10 million cost over 5 years, while

    spending considerably less to adopt the ACMS. Reconvening the FLETC Board
    of Directors in November 2002, albeit briefly, was a step in the right
    direction; however, the Board*s status is unclear. Given FLETC*s recent
    transition into DHS, the Board, consistent with its mandate under the
    FLETC MOU, needs to be retained in order to offer sustained governance and
    oversight to ensure transparency and

    accountability. In this regard, governance, in the form of boards of
    directors, has the important role of overseeing management performance and
    ensuring independent and objective decision- making. As FLETC considers
    revising its MOU, it has an opportunity to incorporate prevailing
    governance and internal and management control best practices about the
    functioning of the Board to help FLETC address its challenges and achieve
    transformational change. To address FLETC*s capacity constraints and
    planning challenges, we

    recommend that the Secretary of Homeland Security instruct the Director of
    FLETC to  develop a formal contingency plan that incorporates both
    physical and

    human resource solutions for at least the major potential constraints or
    choke points that can impede the law enforcement training delivery system;

     consider alternative approaches to estimating future facility
    construction needs in its Master Plan, including (a) specification of a
    range of training workload scenarios, and (b) after consultation with
    experts, application of risk analysis techniques; and

     develop plans for the use of alternative or additional law enforcement
    training campuses should circumstances limit or prohibit the use of
    available facilities.

    To enable FLETC to monitor and reduce the risk associated with the
    degradation of FLETC facilities and infrastructure, we recommend that
    FLETC

     closely monitor overall facility conditions through establishment of
    periodic facility condition assessments of mission critical facilities and
    Recommendations for

    Executive Action

    Page 42 GAO- 03- 736 Federal Law Enforcement Training infrastructure and
    use of a computerized backlog of maintenance and repair and  adopt a
    performance measurement, such as FCI, to monitor the trend of

    FLETC facilities condition and to also offer a benchmark indicator for
    comparison to industry standards.

    To increase the chances of SASS success, we recommend that the Secretary
    of Homeland Security instruct the Director of FLETC to make proceeding
    with the SASS acquisition conditional upon improvements in SASS
    acquisition management activities. We further recommend that these
    improvements, at a minimum, include adding risk management as a SASS
    acquisition function and ensuring that this function provides for

     the identification and documentation of risks;  the categorization of
    risk severity based on probability of occurrence and

    potential impact;  the development and implementation of risk mitigation
    strategies; and  the reporting of risk status, including progress in
    implementing mitigation

    strategies. We further recommend that the improvements in SASS acquisition
    management activities should also

     treat known risks in acquiring COTS- based systems as SASS- specific
    risks, including volatility of the commercial market and an organization*s
    resistance to the business process changes introduced by a COTS- based
    solution;

     ensure that security is made a clear, explicit, and visible component of
    system requirements in the SASS solicitation package; and

     ensure that COTS- based system acquisition best practices are made a
    clear, explicit, and visible aspect of all acquisition functions,
    particularly with respect to continuously assessing the tradeoffs among
    system requirements, FLETC*s architectural environment, the project*s cost
    and schedule constraints, and the commercially available system products
    and components.

    To help provide sustained oversight and enhance accountability, we
    recommend that the Secretary of Homeland Security retain the FLETC

    Page 43 GAO- 03- 736 Federal Law Enforcement Training Board of Directors.
    We further recommend that working with FLETC*s POs, their parent
    departments and agencies, and the Board*s current

    members, the Secretary of Homeland Security review the Board*s mission,
    roles and responsibilities, and functions and practices to better align
    them with prevailing standards of governance and internal and management
    control.

    We provided a draft of this report to the Secretary of DHS and the
    Attorney General for comment. We received comments from the Under
    Secretary of DHS for Border and Transportation Security that are reprinted
    in appendix IV and discussed later. In addition to DHS*s written comments,
    FLETC provided technical comments and clarifications,

    including updates on its SASS acquisition, which are incorporated in this
    report where appropriate. Justice did not provide formal written comments;
    the Associate Assistant Attorney General for Federal Law Enforcement
    Training submitted an email with two general comments about the issues of
    FLETC training capacity and governance, respectively. In their comments,
    DHS and FLETC generally agreed with the information

    presented in the report and with our conclusions and recommendations, and
    outlined actions they either had taken or were planning to take to
    implement the recommendations. DHS noted, for example, that the issues
    related to capacity, scheduling, and governance discussed in the report
    were already being considered by the department and would be given its
    full attention. Regarding specific actions to implement our
    recommendations, FLETC said that it was developing a formal contingency
    plan to respond to future capacity constraints and choke points and to
    identify alternative or additional training assets that could help in this
    response. Also, FLETC indicated that it had taken action to reconstitute
    the Board of Directors; FLETC also indicated that it was taking action to
    determine the prospective membership, and roles and responsibilities of
    the reconstituted Board.

    At the same time, FLETC expressed some concerns regarding the report. In
    its general comments, FLETC said, first, that it *strongly disagreed* with
    the report*s title, asserting that it implied broader concerns about
    capacity planning and management oversight than the report*s contents
    supported. We believe that the report clearly and exhaustively describes
    the challenges FLETC faces in planning for future capacity and articulates
    the importance of sustained management oversight of, among other things,
    the planning effort to help ensure its success, and that the report*s
    title accurately reflects these challenges. Second, FLETC said that the
    report Agency Comments

    and Our Evaluation

    Page 44 GAO- 03- 736 Federal Law Enforcement Training did not point out
    that the flow of federal law enforcement personnel was not constrained by
    training capacity, but by the inability of POs to recruit

    such personnel. We note that because it was beyond the scope of our work,
    the report did not address recruitment as a distinct issue, but did point
    out that shortfalls in POs* recruiting contributed to projected demand for
    training not materializing. We also note that the core issue is FLETC*s
    ability to train those personnel who actually need to be trained. In this
    regard, the report clearly describes how FLETC*s 5- day/ 8- hour

    capacity is strained; accordingly, additional recruits would only serve to
    exacerbate FLETC*s capacity challenges. Third, FLETC said that the report
    did not adequately recognize the *extraordinary success* of FLETC and the
    POs in meeting critical law enforcement training requirements. We believe
    that the report clearly recognizes that FLETC has been able to generally
    meet its POs* demands for basic training during a time of constrained
    capacity and surging demand, and highlights the actions FLETC has taken to
    accomplish this. Fourth, FLETC said that projected workloads (i. e.,
    demand for training) were so dynamic that some of those cited in the
    report were already obsolete and urged caution in their treatment. We note
    that during our work we repeatedly corroborated* through interviews with
    FLETC officials and related documentary verification* the currency and
    validity of the projected workloads as presented in the report; further,
    FLETC did not provide us with any updated workload projections as part of
    its written comments. Fifth, FLETC said that the report implied that it
    was accountable for variables beyond its control, such as the timeliness
    of recruitment, operational needs, class cancellations, shifts in training
    strategies, and funding, all of which impact capacity planning. We believe
    that the report adequately describes these factors as contributing to the
    level of training actual attendance, and does not imply that FLETC is
    accountable for them.

    In its technical comments, FLETC acknowledged that its predominantly
    manual scheduling process was time- consuming and required modernization.
    FLETC questioned, however, that automating the scheduling process would
    result in significant increases in capacity. We note that, first, FLETC*s
    own Master Plan indicated that if the scheduling

    process were to be automated, capacity efficiencies would likely result
    and the plan would need to be revised, and second, FLETC*s documentation
    related to the SASS acquisition indicated that automation would result in
    capacity efficiencies. In commenting on our use of an example to
    illustrate the effect of choke points, FLETC said that resurfacing the
    Charleston campus* emergency response driving range did not result in the
    cancellation of any Border Patrol classes. We note that a

    FLETC official cited the resurfacing as a specific example of a capacity-

    Page 45 GAO- 03- 736 Federal Law Enforcement Training constraining choke
    point that resulted in the cancellation of three Border Patrol classes,
    which have not been rescheduled. In commenting on the

    possible use of ACMS as an alternative to its proposed acquisition of
    SASS, FLETC said, among other things, that the evaluation of ACMS*s
    scheduling component was in the preliminary stages. Accordingly, it was
    too early to tell whether ACMS*s scheduling component would meet FLETC*s

    requirements, and whether significant cost savings would be realized. We
    note that a FLETC official involved in the evaluation of ACMS, in
    responding to our questions, provided a written response, stating that if
    ACMS provided about 80 percent of the functionality sought by FLETC it
    could be adopted as the scheduling system at considerably less cost than
    the estimated $10 million cost of SASS.

    In its comments, regarding training capacity, Justice stated that if
    FLETC*s Glynco campus (as well as the Charleston) campus were used to
    provide basic training and the Artesia Campus was used to provide advanced
    and specialized training, then FLETC would be able to achieve a better
    balance in the utilization of its campuses and mitigate the capacity
    strains it is experiencing. Regarding governance, Justice stated that the
    FLETC Board of Directors would work well as currently configured, if it
    were allowed to function under its original mandate as defined in the MOU
    that created

    FLETC. We are sending copies of this report to the Chairmen and Ranking
    Minority Members of the Senate and House Committees on Appropriations. In
    addition, we are sending copies to the Secretaries of Homeland Security
    and the Interior; the Attorney General of the United States; and the
    Director of OMB. We will also make copies available to others on request.
    In addition, the report will be available at no charge on GAO*s Web site
    at http:// www. gao. gov.

    Page 46 GAO- 03- 736 Federal Law Enforcement Training If you have any
    questions about this report or wish to discuss it further, please contact
    me at (202) 512- 8777 or Seto J. Bagdoyan, Assistant

    Director, at (202) 512- 8658. Key contributors to this report are listed
    in appendix V. Richard M. Stana

    Director, Homeland Security and Justice Issues

    Appendix I: Objectives, Scope, and Methodology

    Page 47 GAO- 03- 736 Federal Law Enforcement Training Given concerns about
    whether the Federal Law Enforcement Training Center (FLETC) can continue
    to meet the rising training demands of its

    75 federal partner organizations (PO) following the September 11th
    attacks, the House Appropriations Committee asked us to develop
    information on the following topics:

     The extent to which FLETC is able to meet the current and projected
    demand for training, how FLETC is planning to meet the demand, and the
    associated costs and the extent to which FLETC coordinates or uses
    existing, non- FLETC government training assets, and any associated costs.

     FLETC*s current organizational structures and processes for coordinating
    and scheduling training activities and whether FLETC plans any changes to
    these structures and processes.

     FLETC*s oversight and governance structures and the extent to which
    these structures are providing guidance to FLETC as it addresses its
    capacity and planning challenges during a period of transformational
    change.

    Overall, to develop the information in this report, we conducted our work
    at FLETC, the Office of Management and Budget (OMB), Clark Nexsen (the
    architectural/ engineering firm retained by FLETC to develop a Master

    Plan for facilities development at FLETC- owned campuses), and at the
    following selected departments and agencies engaged in federal law
    enforcement training.  The Department of Justice (the Immigration &
    Naturalization Service, the Border Patrol, the Federal Bureau of Prisons,
    and the U. S. Marshals

    Service),  The Department of the Treasury (the Bureau of Alcohol,
    Tobacco,

    Firearms, and Explosives, the Internal Revenue Service, the U. S. Customs
    Service, and the U. S. Secret Service), and  The Department of
    Transportation (the Transportation Security

    Administration, the Federal Air Marshals, and the U. S. Coast Guard). The
    Department of Homeland Security (DHS) was created during our work. Many of
    the FLETC POs* identified above as components of other departments* moved
    to DHS* temporary headquarters after January 24, 2003* see appendix II for
    a listing of the POs now in DHS. We interviewed officials from DHS,
    including the Director of Operations for Border and Transportation
    Security. We also interviewed FLETC and PO officials in Washington, D. C.,
    and at each of the four domestic training campuses Appendix I: Objectives,
    Scope, and

    Methodology

    Appendix I: Objectives, Scope, and Methodology

    Page 48 GAO- 03- 736 Federal Law Enforcement Training where FLETC POs
    train: Brunswick, Ga. (commonly referred to as *Glynco,* for Glynn
    County); Artesia, N. Mex.; Charleston, S. C.; and

    Cheltenham, Md. We reviewed applicable public laws and regulations;
    memorandums of understanding (MOU); best practices and guidelines related
    to facilities and information technology acquisition, governance, and
    management and internal control; various drafts of the Master Plan, and
    supporting documentation; budget submissions and justifications; training
    curriculum and accreditation documents; and various reports related to
    FLETC and federal law enforcement training.

    We conducted our work between May 2002 and June 2003 in accordance with
    generally accepted government auditing standards. We requested comments on
    a draft of this report from the Secretary of Homeland Security and the
    Attorney General. (See appendix IV for DHS* comments.)

    To determine the extent to which FLETC is able to meet the current and
    projected demand for training, how FLETC is planning to meet the demand,
    and the associated costs; and the extent to which FLETC coordinates or
    uses existing, non- FLETC government training assets, and any associated
    costs, we interviewed FLETC, OMB, Clark Nexsen, and

    department and component agency officials regarding specific training
    demand and availability issues, including agency training projections and
    the factors influencing these projections, physical and human resource
    *choke points* (or training obstacles) at the training campuses, agency
    satisfaction levels with the current delivery of training services, and
    the resources needed to meet future demands for training. We did not
    evaluate the quality or the effectiveness of the training programs nor
    reviewed how agencies assessed the training provided. We also reviewed the
    following documents obtained from FLETC and other officials:

     Aggregate agency training projections for both basic and advanced
    courses for fiscal years 1997- 2008 and FLETC*s adjustments to some of
    these projections.  Agency training projections for FLETC participants
    interviewed during our

    site visits.  The actual student attendance statistics at the FLETC
    training campuses

    for fiscal years 1983- 2002.  The 35-, 65-, 90- percent, and final draft
    submittals of FLETC*s Master Plan.  The June 1989 Master Plan and its
    April 1996 update.  The latest FLETC 5- year construction plan
    allocation.  FLETC, Treasury, and DHS budget documents and related
    justifications.  FLETC research and development studies on particular
    training issues. Capacity, Planning,

    and Coordination

    Appendix I: Objectives, Scope, and Methodology

    Page 49 GAO- 03- 736 Federal Law Enforcement Training In addition, we
    reviewed the extent to which FLETC*s current infrastructure was supporting
    the delivery of training at each of the

    campuses and whether infrastructure (e. g., water supply, sewage, and
    power grid) concerns were being addressed in FLETC*s Master Plan. We did
    this by reviewing relevant sections of the plan, conducting campus visits
    and observing infrastructure, and interviewing facilities management
    officials. We also determined whether Master Plan proposals regarding
    infrastructure were aligned with FLETC*s Strategic Plan and recent budget
    enactments and requests. Further, we determined whether FLETC has any
    contingency plans to address potential sudden surges in demand for
    training (e. g., Border Patrol hiring in the mid- 1990s and the recent PO
    training ramp- up following the September 11th attacks).

    To determine FLETC*s current organizational structures and processes for
    coordinating and scheduling training activities, and whether FLETC plans
    any changes to these structures and processes, we interviewed FLETC and PO
    officials in Washington, D. C., and at each of the four training campuses
    regarding their perceptions of the training programs and their views about
    FLETC*s ability to schedule and coordinate training activities. In
    addition, we interviewed FLETC officials about the status of the computer
    automation process for scheduling training. We observed how FLETC staff
    perform their scheduling activities. Also, we reviewed the following
    documents:

     Provisions of the 1970 Treasury order creating FLETC.  The Treasury and
    FLETC Strategic Plans of FY2000- 2005, which identify FLETC*s latest
    mission statements, goals, and objectives.

     FLETC*s organizational chart.  FLETC*s request for proposals on
    computer automation.  Records of interviews conducted by Clark Nexsen
    regarding POs* training

    needs. Further, we reviewed FLETC*s MOUs with several of the larger
    agencies to obtain an understanding of FLETC*s formal management and
    coordination responsibilities with respect to the POs.

    To determine whether FLETC has effective controls in place for acquiring a
    new student administration and scheduling system (SASS) by focusing on
    whether the center was performing five key acquisition management
    functions: acquisition planning, solicitation, requirements management,
    project management, and risk management. We reviewed these areas
    Scheduling and

    Coordination of Training Activities

    Appendix I: Objectives, Scope, and Methodology

    Page 50 GAO- 03- 736 Federal Law Enforcement Training because they are
    critical to successfully acquiring systems. These practices were derived
    from the work and research of Carnegie Mellon

    University*s Software Engineering Institute (SEI). 1 In addition, we
    reviewed whether FLETC was incorporating SEI best practices for acquiring
    COTS- based systems 2 in these five functions. In conducting our review,
    we interviewed SASS project officials and other FLETC staff involved in
    the acquisition, including staff from the information systems division,
    the procurement division, legal counsel, and the training analysis and
    coordination division. We also interviewed potential SASS users from two
    FLETC training divisions.

    To determine whether FLETC was performing these acquisition management
    functions, we compared the center*s actions to those defined by SEI as key
    in establishing at least basic acquisition management controls for the
    five functions. In addition, we compared the center*s actions to those SEI
    has redefined as being key to effectively leveraging the COTS- based
    systems. To document FLETC*s actions, in addition to interviewing staff,
    we reviewed documentation including SASS program documentation such as
    contractor reports; the SASS solicitation package, including the SASS
    software and database requirements; training model

    schedule templates; the 2002 master class schedule; information technology
    modernization 2004 capital asset plan; National Institute of Standards and
    Technology security publications; and fiscal year 2000 congressional
    reports.

    To determine FLETC*s oversight and governance structures and the extent to
    which these structures are providing guidance to FLETC as it addresses its
    capacity and planning challenges during a period of transformational
    change, we reviewed FLETC*s 1970 MOU establishing, among other things, its
    Board of Directors, and governance and management and internal control
    best practices* these were the Business Roundtable*s 2002

    Principles of Corporate Governance and a 2003 report by the Conference
    Board*s Commission on Public Trust and Private Enterprise titled

    Findings and Recommendations; and GAO*s 1999 Standards for Internal
    Control in the Federal Government and OMB*s 1995 Circular No. A- 123,

    1 Software Engineering Institute, Software Acquisition Capability Maturity
    Model (R) Version 1.03, CMU/ SEI- 2002- TR- 010 (Pittsburgh, PA: March
    2002). 2 Software Engineering Institute, Evolutionary Process for
    Integrating COTS- Based Systems (EPIC): An Overview, CMU/ SEI- 2002- TR-
    009 (Pittsburgh, PA: July 2002). Governance and

    Oversight Structure and Guidance

    Appendix I: Objectives, Scope, and Methodology

    Page 51 GAO- 03- 736 Federal Law Enforcement Training Management
    Accountability and Control. We drew from our August 2002 report on the
    governance of the U. S. Capitol Police, *Information on Capitol Police
    Board Roles and Responsibilities, Operations, and

    Alternative Structures.* We discussed governance issues in general and the
    Board in particular, including its mission, roles and responsibilities,
    current and past practices, and its status with cognizant FLETC and DHS
    officials. We compared the governance and management and internal control
    best practices with those of the Board to determine the extent to which
    they were consistent.

    Appendix II: FLETC*s 75 Partner Organizations

    Page 52 GAO- 03- 736 Federal Law Enforcement Training Following is a
    listing of the current (as of June 2003) Federal Law Enforcement Training
    Center (FLETC) partner organizations (PO).

    Agriculture

    Forest Service Office of Inspector General

    Amtrak

    Northeast Corridor Police

    Central Intelligence Agency

    Office of Inspector General Office of Security

    Commerce

    National Institute of Standards and Technology National Marine Fisheries
    Service Bureau of Industry and Security Office of Inspector General Office
    of Security

    Defense

    Pentagon Force Protection Agency Naval Criminal Investigative Service
    National Security Agency

    Defense Criminal Investigative Service Office of Inspector General Air
    Force Office of Special Investigations

    Education

    Office of Inspector General

    Energy

    Office of Inspector General Appendix II: FLETC*s 75 Partner

    Organizations

    Appendix II: FLETC*s 75 Partner Organizations

    Page 53 GAO- 03- 736 Federal Law Enforcement Training Environmental
    Protection Agency Office of Criminal Investigations

    Federal Deposit Insurance Corporation

    Office of Inspector General

    General Services Administration

    Office of Inspector General

    Health and Human Services

    Food and Drug Administration National Institutes of Health Office of
    Inspector General

    Homeland Security

    Customs and Border Protection (includes Customs, INS, and Agriculture*s
    Animal and Plant Health Quarantine inspectors, and the Border Patrol, a
    division of CBP) Federal Emergency Management Agency Immigration and
    Customs Enforcement (includes Federal Protective Service) Federal
    Protective Service) Transportation Security Administration

    U. S. Coast Guard U. S. Secret Service Office of Inspector General

    Housing and Urban Development

    Office of Inspector General

    Appendix II: FLETC*s 75 Partner Organizations

    Page 54 GAO- 03- 736 Federal Law Enforcement Training Interior

    Bureau of Indian Affairs Bureau of Land Management Bureau of Reclamation
    National Park Service

    U. S. Park Police Office of Inspector General Office of Surface Mining,
    Reclamation and Enforcement U. S. Fish and Wildlife Service

    Justice

    Bureau of Alcohol, Tobacco, Firearms and Explosives Bureau of Prisons Drug
    Enforcement Administration Office of Inspector General U. S. Marshals
    Service

    Labor

    Office of Inspector General

    National Aeronautics and Space Administration

    Office of Inspector General

    Nuclear Regulatory Commission

    Office of Inspector General

    Office of Personnel Management

    Office of Inspector General

    Railroad Retirement Board

    Office of Inspector General

    Small Business Administration

    Office of Inspector General

    Appendix II: FLETC*s 75 Partner Organizations

    Page 55 GAO- 03- 736 Federal Law Enforcement Training Smithsonian

    National Zoological Park Office of Protection Services

    Social Security Administration

    Office of Inspector General

    State

    Agency for International Development - Office of Inspector General Bureau
    of Diplomatic Security Department of State* Office of Inspector General
    Supreme Court

    Supreme Court Police

    Tennessee Valley Authority

    TVA Police Office of Inspector General

    Transportation

    Office of Inspector General

    Treasury

    Bureau of Engraving and Printing Financial Crimes Enforcement Network
    Internal Revenue Service Office of Inspector General Treasury Inspector
    General for Tax Administration U. S. Mint

    Appendix II: FLETC*s 75 Partner Organizations

    Page 56 GAO- 03- 736 Federal Law Enforcement Training U. S. Congress

    Government Printing Office* Office of Security Library of Congress Police
    Government Printing Office* Office of Inspector General U. S. Capitol
    Police

    U. S. Postal Service

    Office of Inspector General Postal Inspection Service* Postal Police

    Veterans Affairs

    Office of Inspector General

    Appendix III: Training Programs and Seminars Provided by FLETC

    Page 57 GAO- 03- 736 Federal Law Enforcement Training FLETC offers eight
    variations of training programs and seminars. A priority system is
    employed to fund, schedule, and deliver these training

    programs. FLETC basic training programs are delivered in two formats:
    Center Basic followed by an Agency- Specific Basic either on or off site,
    or a single Center Integrated Basic program that combines the Center Basic
    and Agency- Specific Basic concepts into one program. A Center Integrated
    Basic program is granted for those agencies that have such a unique
    mission that their training requirements cannot be met in a Center Basic
    program. The categories of training, in priority order, are:

    1. Center Basic* law enforcement entry- level recruit training designed to
    meet the training needs for multiple agencies. The job tasks and course
    content are identified and validated by the participating agencies and 100
    percent of the training is managed and delivered through FLETC staffing
    resources. These staffing resources are comprised of approximately 50
    percent of FLETC*s permanent staff and 50 percent of Partner Organization
    staff. The three Center Basic programs offered by FLETC are the Criminal
    Investigator Training Program, the Mixed Basic Police Training Program,
    and the Natural Resource Police Training Program.

    2. Center Integrated Basic*- law enforcement entry- level training
    designed to meet the mission- specific or unique requirements of a single
    agency. The job tasks and course content are identified and validated by
    the user agency and the training is managed and delivered through the
    combined efforts of the agency and FLETC staffing resources. Like the
    Center Basic and Agency- Specific Basic, the Center Integrated Basic
    provides both the foundational knowledge, skills, and abilities and the
    specific mission requirements for that agency. FLETC is responsible for
    teaching the common basic recruit training and the agency is responsible
    for teaching the mission- specific courses. FLETC can and does provide
    instructional resources when the agency does not have sufficient staffing.
    FLETC currently offers 10 Center Integrated Basic programs. Some examples
    are the United States Border Patrol Integrated, the United States Park
    Police Integrated, and the United States Marshal Service Integrated.

    3. Agency- Specific Basic* law enforcement entry- level training that
    supplements and follows Center Basic training programs for individual
    agencies. The job tasks and course content are identified by the user
    agency and the training is managed and delivered by agency staffing
    resources. However, FLETC does provide staffing resources as requested.
    The program builds on the foundational knowledge, skills, and abilities
    that were developed in the Center Basic program and Appendix III: Training
    Programs and

    Seminars Provided by FLETC

    Appendix III: Training Programs and Seminars Provided by FLETC

    Page 58 GAO- 03- 736 Federal Law Enforcement Training focuses on the
    specific mission requirements of that law enforcement agency.

    4. Center Advanced* center advanced training is developed, managed, and
    delivered through FLETC staffing resources by the individual training
    divisions to meet a specific or specialized need for instructor or
    mission- specific training. These programs address the specialized and
    instructor needs of the various Partner Organizations. Some examples of
    Center Advanced training include the Firearms Instructor Training Program,
    the Technical Investigative Equipment Training Program, and the Weapons of
    Mass Destruction Training Program.

    5. Agency Advanced* agency advanced training is developed, managed, and
    delivered by the user agency and addresses the specialized training
    requirements for that agency. These training courses are generally
    conducted for mid- and senior- level law enforcement personnel.

    6. State, local, and international training* state, local, and
    international training is primarily delivered on an off- site basis. FLETC
    collaborates with these entities to deliver a variety of training programs
    and in support of various law enforcement initiatives.

    7. Agencies without Partner Organization status participate in training in
    a space available basis. Training programs are developed and delivered as
    appropriate.

    8. Conferences, seminars, and non law enforcement training are also
    provided.

    Appendix IV: Comments from the Department of Homeland Security Page 59
    GAO- 03- 736 Federal Law Enforcement Training Appendix IV: Comments from
    the

    Department of Homeland Security

    Appendix IV: Comments from the Department of Homeland Security Page 60
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 61
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 62
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 63
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 64
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 65
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 66
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 67
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 68
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 69
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix IV: Comments from the Department of Homeland Security Page 70
    GAO- 03- 736 Federal Law Enforcement Training

    Appendix V: GAO Contacts and Staff Acknowledgments Page 71 GAO- 03- 736
    Federal Law Enforcement Training Richard M. Stana (202) 512- 8777 Seto J.
    Bagdoyan (202) 512- 8658

    In addition to those named above, the following teams and individuals
    contributed to this report: Wendy C. Simkalo, Jared Hermalin, Nettie
    Richards, Elizabeth Lessmann, Grace A. Coleman, Brenda Rabinowitz, R.
    Rochelle Burns, Kim Hutchens, Homeland Security and Justice; Terrell Dorn,
    Physical Infrastructure; Carl L. Higginbotham, Dave Hinchman, Information
    Technology; Susan Ragland, K. Scott Derrick, Trina Lewis, Strategic
    Issues; Kenneth Bombara, Leo Barbour, Donna L. Miller, Evan Gilman,
    Applied Research & Methodology; Jan B. Montgomery, Geoffrey Hamilton,
    General Counsel; Susan Conlon, Shirley A. Perry, Product Assistance Group.
    Appendix V: GAO Contacts and Staff

    Acknowledgments GAO Contacts Staff Acknowledgments

    (440125)

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