Customs Service: Process for Estimating and Allocating Inspectional
Personnel (Letter Report, 04/30/98, GAO/GGD-98-107).

Pursuant to a congressional request, GAO reviewed selected aspects of
the Custom Service's drug enforcement operations, focusing on: (1) how
Customs assesses its needs for inspectional personnel and allocates such
resources to commercial cargo ports of entry; (2) whether Customs
received all the additional inspectional personnel its assessments
indicated it needed and, if not, why it did not receive them; and (3)
whether there were any known implications of Customs' not receiving all
of the personnel estimated to be needed and the impact of the additional
personnel that were appropriated on Customs' drug enforcement
operations.

GAO noted that: (1) Customs does not have an agencywide process for
annually determining its need for inspectional personnel--such as
inspectors and canine enforcement officers--for all of its cargo
operations and for allocating these personnel to commercial ports of
entry nationwide; (2) while Customs has moved in this direction by
conducting three inspectional assessments, these assessments: (a)
focused exclusively on the need for additional personnel to implement
Operation Hard Line and similar initiatives; (b) were limited to land
ports along the Southwest border and certain sea and air ports
considered to be at risk from drug smuggling; (c) were conducted each
year using generally different assessment factors; and (d) were
conducted with varying degrees of involvement by Customs headquarters
and field units; (3) Customs conducted the three assessments in
preparation for its fiscal year (FY) 1997, 1998, and 1999 budget request
submissions; (4) for FY 1998 and FY 1999, Customs officials stated that
they used factors such as the number and location of drug seizures and
the perceived threat of drug smuggling, including the use of rail cars
to smuggle drugs; (5) focusing on only a single aspect of its
operations; not consistently including the key field components in the
personnel decisionmaking process; and using different assessment and
allocation factors from year to year could prevent Customs from
accurately estimating the need for inspectional personnel and then
allocating them to ports; (6) the President's budgets did not request
all of the additional inspectional personnel Customs' assessments
indicated were needed; (7) the President's FY 1997 budget ultimately
requested 657 additional inspection and other personnel for Customs; (8)
Customs and Department of the Treasury officials cited internal and
external budget constraints, drug enforcement policy considerations, and
legislative requirements as the primary factors affecting the number of
additional personnel that Customs could ultimately request and the
manner in which it could allocate or reallocate certain personnel; (9)
further, for FY 1998, the Office of National Drug Control Policy
directed Customs to reallocate some of the additional 119 inspectors it
requested and was appropriated funds for Southwest border ports in
accordance with the priorities in the National Drug Control Strategy;
and (10) finally, Customs could not move certain existing positions to
the Southwest border because Congress had directed Customs to use them
for specific purposes at specific ports.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-98-107
     TITLE:  Customs Service: Process for Estimating and Allocating 
             Inspectional Personnel
      DATE:  04/30/98
   SUBJECT:  Strategic planning
             Customs administration
             Human resources utilization
             Law enforcement
             Drug trafficking
             Presidential budgets
             Search and seizure
             Smuggling
             Federal employees
IDENTIFIER:  National Drug Control Strategy
             
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Cover
================================================================ COVER


Report to the Honorable
Dianne Feinstein, U.S.  Senate

April 1998

CUSTOMS SERVICE - PROCESS FOR
ESTIMATING AND ALLOCATING
INSPECTIONAL PERSONNEL

GAO/GGD-98-107

Customs Service

(264439)


Abbreviations
=============================================================== ABBREV

  ASD - Anti-Smuggling Division
  CMC - Customs Management Center
  OFO - Office of Field Operations
  OMB - Office of Management and Budget
  ONDCP - Office of National Drug Control Policy

Letter
=============================================================== LETTER


B-278218

April 30, 1998

The Honorable Dianne Feinstein
United States Senate

Dear Senator Feinstein: 

You asked us to undertake a broad review of the drug enforcement
operations of the U.S.  Customs Service along the Southwest border of
the United States.  In September 1997, we provided you with
information on selected aspects of Customs' drug enforcement
operations.\1 In that letter, we detailed, among other things,
Customs' emphasis on its drug enforcement mission and its use of drug
information.  Our objectives for this report were to determine (1)
how Customs assesses its needs for inspectional personnel (inspectors
and canine enforcement officers) and allocates such resources to
commercial cargo ports of entry; (2) whether Customs received all the
additional inspectional personnel its assessments indicated it needed
and, if not, why it did not receive them; and (3) whether there are
any known implications of Customs' not receiving all of the personnel
estimated to be needed and the impact of the additional personnel
that were appropriated on Customs' drug enforcement operations. 

In developing the information in this report, we (1) obtained and
reviewed relevant budget, workload, personnel allocation, and drug
smuggling threat documents; (2) interviewed cognizant officials at
Customs headquarters, the Department of the Treasury, the Office of
National Drug Control Policy (ONDCP), and the Office of Management
and Budget (OMB); (3) telephonically interviewed Customs officials
from the Arizona Customs Management Center (CMC)\2 and the Nogales,
Arizona, port; and (4) visited two CMCs--Southern California and
South Texas--and two ports--Otay Mesa, California, and Laredo, Texas,
where we interviewed cognizant Customs officials.  We did not assess
the validity of Customs' needs assessments.  Our objectives, scope,
and methodology are discussed in more detail in appendix I. 

We requested comments on a draft of this report from the heads of
OMB, ONDCP, and the Department of the Treasury or their designees. 
On April 2, April 6, and April 8, 1998, respectively, cognizant
officials from these agencies provided us with their oral comments. 
These comments are discussed near the end of this letter.  We
performed our work between June 1997 and February 1998 in accordance
with generally accepted government auditing standards. 


--------------------
\1 See Customs Service:  Information on Southwest Border Drug
Enforcement Operations (GAO/GGD-97-173R, Sept.  30, 1997). 

\2 On October 1, 1995, Customs closed its 7 regional and 42 district
offices and replaced them with 20 CMCs. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Customs does not have an agencywide process for annually determining
its need for inspectional personnel--such as inspectors and canine
enforcement officers--for all of its cargo operations and for
allocating these personnel to commercial ports of entry nationwide. 
While Customs has moved in this direction by conducting three
separate assessments since 1995 to determine its need for additional
inspectional personnel, these assessments (1) focused exclusively on
the need for additional personnel to implement Operation Hard
Line--Customs' initiative to address border violence and drug
smuggling--and similar initiatives; (2) were limited to land ports
along the Southwest border and certain sea and air ports considered
to be at risk from drug smuggling; (3) were conducted each year using
generally different assessment factors; and (4) were conducted with
varying degrees of involvement by Customs headquarters and field
units. 

Customs conducted the three assessments in preparation for its fiscal
year 1997, 1998, and 1999 budget request submissions.  To estimate
the number of additional inspectors and canine enforcement officers
needed for fiscal year 1997, Customs combined factors such as the
need to (1) fully staff inspectional facilities and (2) balance
enforcement efforts against violators with (3) the need to move
legitimate cargo through the ports.  For fiscal years 1998 and 1999,
Customs officials stated that they used factors such as the number
and location of drug seizures and the perceived threat of drug
smuggling, including the use of rail cars to smuggle drugs. 

To allocate to the ports the additional personnel that were funded by
Congress in fiscal years 1997 and 1998 for Operation Hard Line and
similar initiatives, Customs used factors such as (1) commercial
cargo workloads and (2) specific aspects of the drug smuggling
threat, such as attempts by private sector employees at sea and air
ports to assist drug smuggling organizations in their efforts to
smuggle drugs (described by Customs as "internal conspiracies"). 

Focusing on only a single aspect of its operations (i.e., countering
drug smuggling); not consistently including the key field components
(i.e., CMCs and ports) in the personnel decisionmaking process; and
using different assessment and allocation factors from year to year
could prevent Customs from accurately estimating the need for
inspectional personnel and then allocating them to ports. 

The President's budgets did not request all of the additional
inspectional personnel Customs' assessments indicated were needed. 
For example, the assessment for fiscal year 1997 estimated that
Customs, at a minimum, needed an additional 1,036 inspectors, canine
enforcement officers, agents, and support staff for ports along the
Southwest border to adequately implement Operation Hard Line.  As a
result of an internal review, Customs revised its estimate to 912
additional positions.  Treasury further revised this estimate to 657
additional positions.  The President's fiscal year 1997 budget
ultimately requested 657 additional inspectional and other personnel
(agents and support staff) for Customs.  This represented about 63
percent of Customs' original 1,036-position estimate.  Congress
appropriated $65 million for Operation Hard Line.  The House
Appropriations Committee report accompanying the fiscal year 1997
appropriations bill agreed with the President's request for $65
million for Hard Line to be used for 657 additional positions and
equipment (H.R.  Rep.  No.  104-660, at 28 (1996)). 

Customs and Treasury officials cited internal and external budget
constraints, drug enforcement policy considerations, and legislative
requirements as the primary factors affecting the number of
additional personnel that Customs could ultimately request and the
manner in which it could allocate or reallocate certain personnel. 
For example, as discussed earlier, for fiscal year 1997, Treasury
reduced Customs' revised 912-position estimate for additional
inspectional personnel to 657 positions.  Treasury officials cited
limited budgetary resources as the reason behind this decision. 
Further, for fiscal year 1998, ONDCP directed Customs to reallocate
some of the additional 119 inspectors it requested and was
appropriated funds for to Southwest border ports in accordance with
the priorities in the National Drug Control Strategy.  Customs had
originally planned to allocate all of these inspectors to air and sea
ports considered to be at risk from drug smuggling, none of which
were located along the Southwest border.  Finally, Customs could not
move certain existing positions to the Southwest border because
Congress had directed Customs to use them for specific purposes at
specific ports.  Such positions included about 1,200 inspectors
funded by user fees. 

It is too early to definitively determine (1) whether there are any
implications resulting from Customs not receiving all of the
inspectional personnel that its needs assessments identified as
needed and (2) the impact of the additional inspectional personnel
that were appropriated for fiscal years 1997 and 1998 on Customs'
drug enforcement operations.  According to Customs officials, the
additional inspectors that were hired in fiscal year 1997 were still
in the process of being deployed and trained on-the-job; the fiscal
year 1998 inspectors are in the process of being hired and trained. 
According to these officials, Customs will not be able to assess the
full impact of the additional inspectors on its enforcement
operations until these inspectors gain experience, which may be up to
2 years from the time of their deployment.  As part of its strategic
plan, Customs plans to assess, among other things, the success of its
drug enforcement operations by employing performance measures and
conducting internal evaluations of its drug strategy's components. 

To successfully implement the Government Performance and Results Act
of 1993 (the Results Act), P.L.  103-62--enacted to improve the
efficiency and effectiveness of federal programs--Customs has to
determine its needs for inspectional personnel for all of its cargo
operations and ensure that available personnel are allocated where
they are needed most.  Accordingly, this report is making a
recommendation to the Commissioner of Customs to establish a process
to accomplish these tasks. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Created in 1789, Customs is one of the federal government's oldest
agencies.  Customs is responsible for collecting revenue from imports
and enforcing customs and related laws.  It also processes persons,
carriers, cargo, and mail into and out of the United States.  In
fiscal year 1997, Customs collected about $19 billion in revenues and
processed about 18 million import entries; about 128 million
vehicles; and about 446 million air, land, and sea passengers
entering the country. 

Customs performs its mission with a workforce of about 19,500
personnel at its headquarters in Washington, D.C., and at 20 CMCs, 20
Special Agent-in-Charge offices, and 301 ports of entry around the
country.  Of these 301 ports, 24 are located along the Southwest
border and--through 39 crossing points (such as bridges)--handle both
passengers and commercial cargo entering the United States.  At the
end of fiscal year 1997, Customs had deployed about 28 percent of its
inspectors and about 62 percent of its canine enforcement officers at
ports along the Southwest border.  This compared to about 24 percent
of its inspectors and about 50 percent of its canine enforcement
officers being deployed at the Southwest border in fiscal year 1992,
the earliest year that complete data were available.  This deployment
represented an increase of about 36 percent in the number of
inspectors and about 67 percent in the number of canine enforcement
officers at the Southwest border over the fiscal year 1992 level. 


      CUSTOMS' ANTI-DRUG SMUGGLING
      MISSION
---------------------------------------------------------- Letter :2.1

A major goal of Customs is to prevent the smuggling of drugs into the
country by attempting to create an effective drug interdiction,
intelligence, and investigation capability that disrupts and
dismantles smuggling organizations.  The Commissioner of Customs has
designated this goal to be the highest priority within Customs. 
Specifically, as 1 of more than 50 federal agencies involved in the
national drug control effort, Customs is responsible for stopping the
flow of illegal drugs through the nation's ports of entry.  In
addition to routine inspections to search passengers, cargo, and
conveyances (these include cars, buses, trucks, aircraft, and marine
vessels) for illegal drugs moving through the ports, Customs' drug
interdiction efforts include investigations and the use of contraband
enforcement teams\3 and canine enforcement officers. 

In February 1995, Customs initiated Operation Hard Line along the
Southwest border to address drug smuggling, including port running
(the practice of racing drug-laden conveyances through a Customs
inspection point), and related border violence through increased and
intensified inspections, improved facilities, and the use of
technology.  According to Customs officials, port running had
increased in part as a result of enforcement operations conducted by
the Immigration and Naturalization Service between the ports of entry
along the Southwest border.  Customs has expanded its anti-smuggling
initiative (called Operation "Gateway") beyond the Southwest border
to the southern tier of the United States to include the Caribbean
and Puerto Rico. 

According to Customs officials, in keeping with the need to perform a
multifaceted mission, Customs does not generally allocate inspectors
to ports of entry exclusively to perform drug enforcement. 
Accordingly, while it is the highest priority, drug enforcement is
only one of many functions that inspectors are expected to perform
when inspecting goods and persons.  However, in an effort to enhance
its drug enforcement operations, Customs has been using more
specialized drug enforcement units, such as contraband enforcement
teams, and assigning inspectors to such units on a rotational basis. 


--------------------
\3 Contraband enforcement teams are specialized teams of inspectors
dedicated to, among other things, intensive examinations of cargo
shipments to detect and interdict the movement of narcotics.  Their
efforts focus on identifying, selecting, and examining the highest
risk shipments. 


      THE RESULTS ACT AND
      STRATEGIC PLANNING
---------------------------------------------------------- Letter :2.2

The Results Act was enacted to improve the efficiency and
effectiveness of federal programs by establishing a system to set
goals for program performance and to measure results.  Under the
Results Act, executive agencies were to develop, by September 1997,
strategic plans in which they defined their missions, established
results-oriented goals, and identified the strategies they will use
to achieve those goals for the period covering at least fiscal years
1997 through 2002.  These plans are to be updated at least every 3
years.  Beginning in fiscal year 1999, agencies are also to develop
annual performance plans.  The Results Act requires that these plans
(1) identify annual performance goals and measures for each of an
agency's program activities, (2) discuss the strategies and resources
needed to achieve the performance goals, and (3) explain the
procedures the agency will use to verify and validate its performance
data. 

Customs' Strategic Plan for fiscal years 1997 through 2002
established a goal and a number of objectives designed to continue
Customs' multipronged drug enforcement effort to increase the risk of
being caught for those smuggling illegal drugs into the country.  The
plan also included measures, such as the number and amounts of
narcotics seizures, to gauge the success of the enforcement efforts
and proposed conducting internal evaluations of specific components
of the strategy, such as narcotics interdiction.  Customs' fiscal
year 1999 Annual Performance Plan detailed performance goals and
measures for each of its operational activities.  The plan also
discussed the strategies and proposed resources that would be
utilized to achieve the goals. 


   NO SYSTEMATIC APPROACHES TO
   DETERMINE CUSTOMS' INSPECTIONAL
   PERSONNEL NEEDS AND ALLOCATE
   PERSONNEL
------------------------------------------------------------ Letter :3

Customs does not have an agencywide process for annually determining
its need for inspectional personnel--such as inspectors and canine
enforcement officers--and for allocating these personnel to
commercial cargo ports of entry nationwide.  Customs officials were
not aware of any such process to determine inspectional personnel
needs prior to 1995.  While Customs has moved in this direction by
conducting three assessments to determine its need for additional
inspectional personnel since 1995, these assessments (1) focused
exclusively on the need for additional personnel to implement its
anti-drug smuggling initiatives, such as Operation Hard Line and
similar initiatives; (2) were limited to land ports along the
Southwest border and certain sea and air ports at risk from drug
smuggling; (3) were conducted each year using different assessment
and allocation factors; and (4) were conducted with varying degrees
of involvement by Customs headquarters and field units.  Focusing on
only a single aspect of its operations (i.e., countering drug
smuggling); not consistently including the key field components
(i.e., CMCs and ports) in the decisionmaking process; and using
different assessment and allocation factors from year to year could
prevent Customs from accurately estimating the need for inspectional
personnel and then allocating them to ports. 


      NO KNOWN EFFORTS PRIOR TO
      1995 TO DETERMINE
      INSPECTIONAL PERSONNEL NEEDS
---------------------------------------------------------- Letter :3.1

According to Customs officials, they were not aware of any agencywide
efforts prior to 1995 to determine the need for additional
inspectional personnel at commercial cargo ports of entry.  Rather,
CMCs (then called districts) requested additional personnel primarily
when new ports were established.  For example, when the new port at
Otay Mesa, California, was established, the Southern California CMC
(then called the San Diego District) requested from headquarters, and
was allocated, some additional personnel to staff the port. 
Separately, according to Customs officials, as part of the annual
budget request development process, CMCs can also submit requests for
inspectional personnel to fill vacancies in existing positions
created by attrition. 

On a broader basis, according to officials at Customs' Anti-Smuggling
Division (ASD),\4 beginning in the late 1980s, Customs redeployed
some existing inspectional personnel in response to the increasing
workload and drug smuggling threat along the Southwest border.  For
example, as shown in figures 1 and 2 (see also app.  II), prior to
the Hard Line buildup, there was an increase in inspectional
personnel--inspectors and canine enforcement officers --at Southwest
border ports between fiscal years 1993 and 1994.  According to ASD
officials, this was done in preparation for the implementation of the
North American Free Trade Agreement and the anticipated increase in
related workload.  According to these officials, Customs accomplished
the pre-Hard Line buildup by reallocating positions that had become
vacant through attrition from ports around the country--such as those
on the border with Canada--to the Southwest border. 

   Figure 1:  Customs Inspector
   Staffing Levels, Fiscal Years
   1992 to 1997

   (See figure in printed
   edition.)

Note:  Fiscal year 1992 was the earliest year for which complete data
were available. 

Source:  GAO analysis of Customs data. 

   Figure 2:  Customs Canine
   Enforcement Officer Staffing
   Levels, Fiscal Years 1992 to
   1997

   (See figure in printed
   edition.)

Note:  Fiscal year 1992 was the earliest year for which complete data
were available. 

Source:  GAO analysis of Customs data. 


--------------------
\4 ASD is part of Customs' Office of Field Operations (OFO).  ASD,
among other things, serves as the focal point for assessing the need
for inspectional personnel and then allocating them to ports in
support of Customs' anti-drug initiatives.  OFO is the organizational
element within Customs responsible for performing primary (initial)
inspections of persons, cargo, and conveyances at air, land, and sea
ports of entry.  Nationwide, OFO has over 7,000 inspectors and 500
canine enforcement officers to perform inspections. 


      RECENT NEEDS ASSESSMENTS
      FOCUSED ON ANTI-SMUGGLING
      INITIATIVES
---------------------------------------------------------- Letter :3.2

Customs' personnel needs assessment process for fiscal years 1997
through 1999 focused exclusively on its anti-drug smuggling
initiatives, namely Operations Hard Line and Gateway.  In focusing on
only one aspect of its cargo and passenger operations (i.e.,
countering drug smuggling), Customs is not identifying the need for
inspectional personnel for its overall cargo processing operations. 

According to Customs and Treasury officials, the impetus for the
focus of the needs assessements on the anti-smuggling initiatives,
beginning with Hard Line, was provided by a June 1995 visit by the
Deputy Secretary of the Treasury to ports within the Southern
California CMC to observe how Hard Line was being implemented. 
According to these officials, the Deputy Secretary expressed concern
about Hard Line's implementation, especially about the extensive use
of overtime and the apparent lack of results in terms of drug
seizures.  According to the officials, the Deputy Secretary concluded
that the Southwest border ports did not have a sufficient number of
inspectors and other personnel to adequately implement Hard Line.  As
a result, the Deputy Secretary asked Customs officials to review the
staffing situation at the Southwest border ports and prepare a
proposal for additional staffing and other measures to enhance Hard
Line's implementation. 

In response to the Deputy Treasury Secretary's concerns about
Operation Hard Line, Customs conducted a needs assessment in 1995 for
its fiscal year 1997 budget submission.  Specifically, in June 1995,
ASD asked the four Customs districts (now called CMCs) along the
Southwest border to develop estimates of their inspectional personnel
needs.  The four districts were San Diego, California (now the
Southern California CMC); El Paso, Texas (now the West Texas CMC);
Laredo, Texas (now the South Texas CMC); and Nogales, Arizona (now
the Arizona CMC).  The factors used in this assessment and its
results are discussed later in this report. 


      RECENT INSPECTIONAL
      PERSONNEL NEEDS ASSESSMENTS
      LIMITED TO CERTAIN PORTS
---------------------------------------------------------- Letter :3.3

Because they focused on Customs' anti-smuggling initiatives, the
inspectional personnel needs assessments that began in 1995 were
accordingly limited to ports along the Southwest border and the
southern tier of the United States, and to sea and air ports
determined to be at risk from drug smuggling.  Also, these
assessments focused only on the need for additional personnel at
these ports.  Specifically, Customs did not conduct a review of its
301 ports to determine (1) the appropriate staffing levels at each
one of these ports and (2) whether it was feasible to permanently
reallocate inspectors to the Southwest border ports and other
high-risk ports from other ports around the country that potentially
had, at that time, higher levels of inspectors than justified by
workload and other factors, before assessing the need for additional
personnel. 

In addition, Customs' strategic plan and the fiscal year 1999 Annual
Performance Plan did not provide the detail necessary to determine
the level of personnel needed and how Customs planned to align, or
allocate, these personnel to meet its plans' goals and objectives. 
The strategic plan, however, recognized the need to assess the
allocation of resources, including personnel, and their effectiveness
and to address any necessary redeployments, while Customs' fiscal
year 1998 Annual Plan identified the linkage of its goals with
available and anticipated resources as an area that needed attention. 

Customs officials said that they did not conduct broad-based
assessments because the results of these assessments would likely
indicate the need to move inspectional personnel.  These officials
stated that moving personnel would be difficult for four primary
reasons.  First, about 1,200 current inspectional positions are
funded through revenues from user fees established by the
Consolidated Omnibus Budget Reconciliation Act of 1985 as amended,
codified at 19 U.S.C.  58c.  These positions are funded for specific
purposes at specific locations, such as processing arriving
passengers at air and sea ports, in proportion to the revenues
contributed by each user fee category.  For example, according to
Customs officials, since air passenger fees contributed about 85
percent of all user fee revenues, air ports would receive 85 percent
of all inspectors funded by the fee revenues.  Consequently, Customs
cannot redeploy such positions to other locations for other purposes,
such as inspecting cargo at commercial cargo ports. 

Second, under the terms of its union contract, to permanently move
inspectors from one CMC to another, Customs needed to ask for
volunteers before directing the reassignment of any inspectors. 
However, when Customs asked for 200 volunteers--a number far short of
what was ultimately estimated as being needed--to be detailed to the
Southwest border to help implement Operation Hard Line, very few
volunteers emerged.  Consequently, Customs abandoned its call for
volunteers and decided to implement Hard Line with existing personnel
by relying on the use of overtime.  In other instances that would
require inspectors to move, according to Customs officials, if
volunteers did not emerge, Customs would need to select the most
junior inspectors to move.  However, for operational reasons having
to do primarily with inspector experience, this was not an option
preferred by Customs. 

Third, funding historically was not requested in the President's
budgets or appropriated by Congress for permanent changes of station
(i.e., permanent moves) because of the high cost involved.  Customs
officials estimated that it cost between $50,000 and $70,000 to move
an inspector, thus making any substantial number of moves
prohibitively expensive.  However, more recently, the President's
budgets have requested funding for redeploying Customs agents, and
Congress has appropriated such funding.  For example, in the fiscal
year 1998 budget, $4 million was requested for agent redeployments,
and Congress appropriated the requested amount. 

Fourth, by 1995, Customs had already reallocated positions to the
Southwest border from other ports as the positions became vacant
through attrition.  However, according to ASD officials, Customs
could no longer reallocate positions in this manner because some
non-Southwest border ports were experiencing staffing shortages due
to attrition and growing workloads and needed to fill their
vacancies. 


      CUSTOMS USED DIFFERENT
      FACTORS IN ITS NEEDS
      ASSESSMENTS
---------------------------------------------------------- Letter :3.4

Customs' three needs assessments utilized different factors from year
to year to determine the need for additional inspectional personnel. 
However, Customs' decision not to consider factors critical to
accomplishing its overall mission every year--such as the
configuration of the ports that was used in the fiscal year 1997
assessment--could have prevented Customs from estimating the
appropriate level of personnel at each port. 


         FACTORS USED IN FISCAL
         YEAR 1997
-------------------------------------------------------- Letter :3.4.1

For the fiscal year 1997 assessment, ASD provided the Southwest
border districts with a number of factors to use in determining the
need for additional inspectors and canine enforcement officers for
their cargo and passenger operations.  The factors were based
primarily on the configuration of ports, which, in addition to its
drug enforcement functions, is a reflection of Customs' mission
critical functions.  The factors were (1) the need to fully staff all
primary passenger lanes, taking into account agreements with the
Immigration and Naturalization Service (INS),\5 including inspectors
to conduct preprimary roving;\6 (2) the need to fully staff cargo
facilities (primary booths and examination docks), while taking into
account the balance between Customs' enforcement mission and the need
to facilitate the movement of legitimate conveyances and their cargo;
and (3) the need for canine enforcement officers to support all cargo
and passenger processing operations.  The districts were also asked
to (1) assume that they were going to at least maintain the
examination rates being achieved at the time of the assessment, based
on the national standard to examine a minimum of 20 percent of a
selected conveyance's cargo, and (2) consider the overall drug
smuggling threat at ports. 


--------------------
\5 Both Customs and INS inspect incoming passengers at ports of
entry. 

\6 Preprimary roving is the process through which Customs inspectors
target passengers for intensive inspections.  Rovers are teams of
inspectors who, along with canine enforcement officers, attempt to
identify potential smugglers through behavioral analysis, prior
intelligence, or canine alert. 


         FACTORS USED IN FISCAL
         YEARS 1998 AND 1999
-------------------------------------------------------- Letter :3.4.2

Unlike the fiscal year 1997 needs assessment process that was based
on the configuration of ports, ASD officials said they used the
threat of drug smuggling at commercial cargo land ports along the
Southwest border and at air and sea ports on the southern tier of the
United States and other locations to estimate the number of
additional inspectors needed in fiscal years 1998 and 1999.  However,
in not considering land border port configurations, Customs did not
take into account changes in the configurations that could have
implications for the number of inspectional personnel needed. 

For fiscal year 1998, ASD officials said they focused on three
aspects of the drug smuggling threat:  (1) the number and location of
drug seizures, since they were evidence of the threat; (2) the use of
rail cars by drug smugglers to smuggle drugs; and (3) the existence
of internal conspiracies by individuals, such as dock workers at
ports, to smuggle drugs.  According to the ASD officials, the latter
two factors represented the evolving nature of the drug smuggling
threat and needed to be addressed. 

For fiscal year 1999, in addition to the latter two factors used in
fiscal year 1998, ASD said it also considered the need to address the
continued evolution of the drug smuggling threat, namely (1) an
increase in drug smuggling using waterways bordering the United
States and (2) an expansion in the number of drug smuggling
organizations operating in U.S.  cities.  According to an ASD
official, the factors used in fiscal years 1998 and 1999 were meant
to balance Customs' continued emphasis on the drug smuggling threat
along the Southwest border and the need to address new threats in
other areas, such as Miami and Los Angeles. 


      FISCAL YEAR 1997 AND 1998
      INSPECTIONAL PERSONNEL
      ALLOCATIONS UTILIZED
      DIFFERENT NEEDS ASSESSMENT
      FACTORS
---------------------------------------------------------- Letter :3.5

The processes to allocate the inspectional personnel funded by
Congress in fiscal years 1997 and 1998 generally used different needs
assessments factors.\7 For fiscal year 1997, ASD used commercial
truck volume to allocate the new cargo inspectors to the Southwest
border ports.\8 According to ASD officials, they used the workload
data because they believed that the drug smuggling threat ultimately
manifested itself in terms of conveyance and passenger
traffic--commercial trucks, passenger vehicles, and pedestrians at
land ports; aircraft and passengers at air ports; and vessels, cargo,
and passengers at sea ports--and the likelihood that any one of these
conveyances or passengers could carry drugs through any port at any
time. 

ASD used an estimated ratio of 10 inspectors for every 100,000 laden
(full) trucks and 5 inspectors for every 100,000 empty trucks to
allocate the additional personnel to the Southwest border ports.  An
ASD official said that the ratio was based on ASD's experience with
the number of inspectors and the length of time needed to inspect
laden and empty trucks.  In addition, according to this official, ASD
used the ratio because it was relatively easy to understand and
implement and was generally supported by the CMCs and ports receiving
the resources, such as the Otay Mesa port. 

For fiscal year 1998, ASD officials stated that they used the same
aspects of the drug smuggling threat used for that year's needs
assessment to allocate the inspectional personnel that were funded. 
Accordingly, to address the use of commercial rail cars to smuggle
drugs, for example, ASD estimated that a team of between four to
eight inspectors was needed to inspect a commercial cargo train,
depending on the number of rail cars.  Using this estimate, ASD
allocated inspectors to ports with rail car inspection operations
that were facing a drug smuggling threat, such as Laredo and
Brownsville, Texas.  However, because Customs did not consider its
entire workload, it did not take into account the anticipated growth
in trade volume and the potential resulting need for additional
inspectional personnel to handle this growth.  Further, considering
that Customs has identified workload as an indicator of the drug
smuggling threat, it could not respond to the escalation of the
threat as represented by the growth in its entire workload.  Customs
officials commented that, since a limited number of additional
inspectors were available for allocation to rail operations, they
allocated a minimum number of inspectors to each port with such
operations, without considering the workload. 

In fiscal year 1997, ASD officials stated that, working with Customs'
Canine Branch,\9 they used workload and the extent of the drug
smuggling threat to allocate the additional canine enforcement
officers to ports.  No canine enforcement officers were requested or
appropriated for fiscal year 1998. 


--------------------
\7 As discussed later in this report, the President's fiscal year
1999 budget did not request any additional inspectional resources
specifically for cargo processing.  Consequently, Customs has not
developed an inspectional resource allocation proposal. 

\8 Customs considered INS' passenger allocation model to allocate
inspectors to its passenger processing operations.  Since this report
focuses on cargo operations, we do not discuss the allocation of
passenger inspectors. 

\9 The Canine Branch is a unit within OFO that is responsible for the
training and operational oversight of Customs' canine enforcement
units. 


      NEEDS ASSESSMENTS AND
      ALLOCATIONS CONDUCTED WITH
      VARYING DEGREES OF
      INVOLVEMENT BY CUSTOMS UNITS
---------------------------------------------------------- Letter :3.6

Customs' needs assessments and allocations were conducted with
varying degrees of involvement by headquarters and field units.  ASD
had the lead role in the assessments and allocations, while other
units--CMCs and ports--had more limited roles.  Specifically, while
Southwest border CMCs and ports conducted the fiscal year 1997
assessment, they were not involved in the subsequent allocation of
the personnel that were funded.  In its role, ASD compiled the
results of the needs assessment.  Customs' Office of
Investigations\10 estimated the number of investigative agents and
other staff needed to support the inspectors and canine enforcement
officers.  The Canine Branch estimated the number of canine
enforcement officers needed to provide operational support to
inspectors.  As described earlier, ASD also allocated the inspectors
and, working with the Canine Branch, the canine enforcement officers
that were funded by Congress.  The Office of Investigations allocated
the agents and support staff. 

ASD conducted the fiscal year 1998 needs assessment and allocation
processes and the fiscal year 1999 needs assessment.  CMCs and ports
affected by ASD's proposed fiscal year 1998 allocations were asked to
comment on them.  Five CMCs and two ports submitted written comments. 
Three CMCs indicated that they were satisfied with the number of
additional inspectors to be allocated to them.  Two CMCs and two
ports indicated that additional inspectors were needed.  ASD
officials said that they took these comments into consideration when
finalizing the allocation. 

According to ASD officials, they assumed a leading role because the
needs assessments and subsequent allocations were being conducted
exclusively in support of Customs' anti-drug smuggling initiatives,
such as Operation Hard Line.  These initiatives are conducted under
ASD's oversight.  In addition, an ASD official explained that ASD was
fully cognizant of the threat, workload, and other factors relevant
to the needs assessment and allocation processes at the CMCs and
ports; thus, it was able to conduct them without the need to consult
extensively with the CMCs and ports.  However, because it did not
fully involve the two key field components responsible for day-to-day
operations (i.e., the CMCs and ports) throughout the needs assessment
and allocation processes, Customs received no input from those who,
by virtue of their operational roles, are in the best position to
know the levels of inspectional personnel they need. 


--------------------
\10 The Office of Investigations has about 2,500 special agents and
about 1,100 other personnel in its aviation, marine, and intelligence
units.  Among other things, special agents investigate drug seizures
at ports and develop cases that implicate smuggling organizations. 


      EFFECTIVE IMPLEMENTATION OF
      THE RESULTS ACT REQUIRES THE
      ESTABLISHMENT OF A LINK
      BETWEEN THE DEPLOYMENT OF
      RESOURCES AND THE
      ACHIEVEMENT OF PERFORMANCE
      GOALS
---------------------------------------------------------- Letter :3.7

The Results Act specifies that all agencies' strategic plans should
have six critical components.  Among these is the establishment of
approaches or strategies to achieve general goals and objectives.  In
addition, the Results Act requires that, beginning in fiscal year
1999, agencies must develop annual performance plans to establish a
link between their budget requests and performance planning efforts. 
The Act also envisioned that the strategic and annual performance
planning cycles would be iterative, mutually reinforcing processes. 

We have previously reported\11 that under strategic planning
envisioned by the Results Act, as part of establishing strategies to
achieve goals, strategic plans and annual performance plans need to
describe, among other things, (1) the human and other resources
needed and (2) how agencies propose to align these resources with
their activities to support mission-related outcomes.  We have
accordingly pointed out that in order to effectively implement the
Results Act, and as part of the annual performance planning process,
agencies will need to consider how they can best deploy their
resources to create a synergy that effectively and efficiently
achieves performance goals. 

Consequently, to effectively implement the Results Act, Customs will
need to consider the relationship or link between the personnel it
will have available and the results it expects these personnel to
produce.  However, its most recent estimates of the need for
inspectional personnel and allocations of such personnel to ports
were too narrowly focused on certain aspects of its operations and
limited to certain ports to clearly achieve such a link for all of
its operations. 

As discussed earlier, in its strategic plan, Customs has already
recognized the need to review the deployment of its resources,
including personnel; evaluate their effectiveness; and address any
necessary redeployments.  In addition, in its fiscal year 1998 Annual
Plan, Customs has identified the linkage of available and anticipated
resources with achieving performance goals as an area that needs
attention. 


--------------------
\11 See Executive Guide:  Effectively Implementing the Government
Performance and Results Act (GAO/GGD-96-118, June 1996), Government
Reform:  Goal Setting and Performance (GAO/AIMD/GGD-95-130R, Mar. 
27, 1995), and Agencies' Annual Performance Plans Under the Results
Act:  An Assessment Guide to Facilitate Congressional Decisionmaking
(GAO/GGD/AIMD-10.1.18, Feb.  1998). 


   NOT ALL OF THE INSPECTIONAL
   PERSONNEL CUSTOMS ESTIMATED IT
   NEEDED WERE REQUESTED
------------------------------------------------------------ Letter :4

The President's budgets did not request all of the additional
personnel Customs' assessments indicated it needed.  According to
Customs and Treasury officials, budget constraints, drug enforcement
policy considerations, and legislative requirements affected the
number of personnel Customs could request and how it could allocate
those it received. 


      FISCAL YEAR 1997 ADDITIONAL
      PERSONNEL ESTIMATES AND
      REQUESTS
---------------------------------------------------------- Letter :4.1

For its fiscal year 1997 personnel needs assessment, Customs' four
districts (now CMCs) along the Southwest border estimated that they
needed 931 additional inspectors and canine enforcement officers to
adequately implement Operation Hard Line.  While reviewing this
assessment, the Office of Investigations determined that an
additional 75 agents and 30 support staff for the agents were needed
to complement the districts' request.  This raised the estimate to a
total of 1,036 additional positions.  According to ASD, CMC, and port
officials, this estimate represented the minimum number of additional
positions needed to adequately implement Hard Line. 

The President's fiscal year 1997 budget ultimately requested 657--or
about 63 percent of Customs' original estimate--additional
inspectors, canine enforcement officers, agents, and support staff. 
Congress appropriated funds for the 657 positions.  In terms of
inspectional personnel specifically for commercial cargo, Customs
received funding for about 80 percent (260 of 325) of the additional
inspectors, 63 percent (157 of 249) of the additional canine
enforcement officers, and about 96 percent (101 of 105) of the
additional agent and support positions originally estimated as being
needed.  Figure 3 provides a position-by-position comparison of what
Customs estimated it needed for fiscal year 1997 and what was
actually requested and appropriated. 

   Figure 3:  Comparison of
   Customs' Original Estimated
   Inspectional Personnel Needs
   With Its Actual Appropriation,
   Fiscal Year 1997.

   (See figure in printed
   edition.)

Source:  GAO analysis of Customs data. 

Tables 1 and 2 show how the funded inspector and canine enforcement
officer positions in fiscal year 1997 were allocated to CMCs and how
these allocations compared with the original Customs estimates. 



                                Table 1
                
                     Fiscal Year 1997 Estimates and
                  Allocations of Additional Inspectors

                                             Origin          Allocatio
                                                 al               n as
                                             Custom          percentag
                                                  s               e of
                                             estima  Alloca   original
Location                                         te    tion   estimate
-------------------------------------------  ------  ------  ---------
Overall                                         325     260        80%
Southern California CMC                          83      53        64%
Arizona CMC                                      30      24        80%
West Texas CMC                                  131      47        36%
South Texas CMC                                  81     128       158%
South Florida CMC                                 0       8        N/A
----------------------------------------------------------------------
Source:  GAO analysis of Customs data. 



                                Table 2
                
                     Fiscal Year 1997 Estimates and
                    Allocations of Additional Canine
                          Enforcement Officers

                                           Origin            Allocatio
                                               al                 n as
                                           Custom            percentag
                                                s                 e of
                                           estima  Allocati   original
Location                                       te        on   estimate
-----------------------------------------  ------  --------  ---------
Overall                                       249       157        63%
Southern California CMC                        37        37       100%
Arizona CMC                                    32        32       100%
West Texas CMC                                 33        32        97%
South Texas CMC                               147        55        37%
South Florida CMC                               0         1        N/A
----------------------------------------------------------------------
Source:  GAO analysis of Customs data. 


      FISCAL YEAR 1998 ADDITIONAL
      PERSONNEL ESTIMATES AND
      REQUESTS
---------------------------------------------------------- Letter :4.2

Fewer inspectional positions were requested for Customs than it
originally determined were needed in fiscal year 1998.  For that
year, Customs initially estimated that it needed 200 additional cargo
inspectional positions.  However, the President's fiscal year 1998
budget requested 119--or about 60 percent of Customs' original
estimate--additional cargo inspectional positions.  Congress
appropriated funding for the 119 positions.  Table 3 shows how funded
inspector positions were allocated and how these allocations compared
with the original Customs estimates. 



                                Table 3
                
                     Fiscal Year 1998 Estimates and
                  Allocations of Additional Inspectors

                                           Origin            Allocatio
                                               al                 n as
                                           Custom            percentag
                                                s                 e of
                                           estima  Allocati   original
Location                                       te       ons   estimate
-----------------------------------------  ------  --------  ---------
Overall                                       200       119        60%
High-risk air and sea ports                   200        72        36%
Southwest border ports                          0        47        N/A
----------------------------------------------------------------------
Source:  GAO analysis of Customs data. 


      FISCAL YEAR 1999 ADDITIONAL
      PERSONNEL ESTIMATES
---------------------------------------------------------- Letter :4.3

For fiscal year 1999, Customs estimated that it needed an additional
479 inspectors, 85 canine enforcement officers, 211 agents, 33
intelligence analysts, and 68 marine enforcement officers, for a
total of 876 additional positions.  However, the President's fiscal
year 1999 budget requested 27 agents as part of a separate initiative
called the "Narcotics and Drug Smuggling Initiative" to counter drug
smuggling.  This request represented 3 percent of Customs' total
estimate and about 13 percent of the estimate for agents. 


      BUDGET CONSTRAINTS, POLICY
      CONSIDERATIONS, AND
      LEGISLATIVE REQUIREMENTS
      CITED AS REASONS AFFECTING
      PERSONNEL REQUEST AND
      ALLOCATION DECISIONS
---------------------------------------------------------- Letter :4.4

Customs and Treasury officials cited internal and external budget
constraints, drug enforcement policy considerations, and legislative
requirements as the primary factors affecting the number of
additional personnel that Customs requested and the manner in which
it allocated appropriated personnel or reallocated existing
personnel.



         BUDGET CONSTRAINTS
         AFFECTED PERSONNEL
         REQUESTS
-------------------------------------------------------- Letter :4.4.1

Budget constraints affected the number of additional inspectional
personnel that Customs requested for fiscal years 1997, 1998, and
1999.  Specifically, according to Customs officials, internal budget
constraints resulted in their reducing the original fiscal year 1997
1,036-position request to 912 positions.  Customs subsequently
submitted its request for 912 additional positions to Treasury. 
Treasury officials, also citing budget constraints, including their
decision to maintain budget requests within OMB's overall targets for
Treasury, further reduced Customs' request to 657 additional
positions. 

Customs' fiscal year 1997 request was transmitted by Treasury as part
of its departmental request to OMB for an initial review.  According
to Customs and Treasury officials, upon review, OMB denied the
request.\12 Instead, OMB recommended that Customs move 240 existing
inspectional positions to the Southwest border to help implement
Operation Hard Line.  OMB's decision was appealed by Treasury and
ONDCP, which had already certified Customs' request for 657
additional positions as adequate to meet the National Drug Control
Strategy's goals.\13 In its appeal, Treasury cited the detrimental
effect OMB's denial would have on Customs' drug enforcement
operations, including its inability to increase the number of cargo
examinations.  In its own appeal, ONDCP identified the level of
personnel for Customs as a critical issue and argued that the
requested inspectional personnel were needed to strengthen the
Southwest border against drug smuggling. 

According to Customs officials, through subsequent negotiations
following Treasury's appeal involving, among others, the Treasury
Secretary and the OMB Director, OMB approved the 657-position
request.  The 657 positions--and $65 million to fund them--were
ultimately funded when Treasury received an additional $500 million
from Congress as part of its budget appropriation, according to
Treasury officials. 

As discussed earlier, for fiscal year 1998, Customs originally
estimated that 200 additional cargo inspectors were needed for air
and sea ports determined to be at risk from drug smuggling.  None of
the ports were located along the Southwest border.  Treasury
initially denied Customs' request for 200 positions and later
approved for submission to OMB a request for 119 additional
positions.  Customs and Treasury officials again cited budget
constraints as the reason for the reduction.  As part of its role
(see footnote 12), ONDCP certified the submission as adequate. 
According to Customs budget documents, the 119 positions were funded
for 1 year with appropriations from the Violent Crime Reduction Trust
Fund.\14 For fiscal year 1999, the President's budget is proposing
that these positions be funded from Customs' Salaries and Expenses
account. 

For fiscal year 1999, Customs estimated that it needed an additional
876 inspectional and related positions for its anti-drug smuggling
initiatives at the Southwest border and at air and sea ports believed
to be at risk from drug smuggling.  According to an ASD official,
Treasury supported and ONDCP certified this estimate, which was then
transmitted to OMB for review.  OMB denied the request.  Instead, the
President's fiscal year 1999 budget included a separate 27-agent
anti-narcotics initiative. 


--------------------
\12 OMB officials would not discuss the details of their
decisionmaking process or provide relevant documents related to
Customs' request for inspectional personnel.  The OMB officials
stated that they could neither provide nor discuss such information
because it involved internal administration budget deliberations. 

\13 By law (21 U.S.C.  1502(c)), all departments, bureaus, and
independent agencies with responsibilities under the National Drug
Control Strategy are required to submit their drug budget requests to
ONDCP.  ONDCP is to review the drug budgets to determine if they are
adequate to implement the goals of the strategy.  ONDCP then is to
send a letter to the cognizant entity advising it either that its
budget is adequate or that changes are needed prior to its submission
to OMB. 

\14 The Violent Crime Reduction Trust Fund was established by the
Violent Crime Control and Law Enforcement Act of 1994 (P.L. 
103-322).  Among other things, the Trust Fund provides funding for
drug-related programs. 


         PERSONNEL ALLOCATION
         AFFECTED BY POLICY
         CONSIDERATIONS AND
         LEGISLATIVE REQUIREMENTS
-------------------------------------------------------- Letter :4.4.2

The resource allocation process was affected by policy considerations
related to the drug smuggling threat.  Specifically, for fiscal year
1997, ASD changed its initial allocation of inspectional personnel to
include a port not located at the Southwest border.  ASD had
originally planned to allocate all of the additional inspectional and
canine enforcement officers exclusively to Southwest border ports. 
According to an ASD official, ASD modified the allocation because the
South Florida CMC appealed to the Commissioner of Customs for
additional inspectional personnel, citing a significant drug
smuggling threat as indicated by the number of cocaine
seizures--totaling about 10,000 pounds--at Port Everglades port.  The
Commissioner agreed with the appeal.  Consequently, ASD adjusted its
allocation to provide nine inspectors and canine enforcement officers
to this port. 

For fiscal year 1998, during the course of its review of Customs'
request for the additional resources and its plans to allocate them,
ONDCP directed Customs to change its allocation to include cargo
ports along the Southwest border.  According to Customs and ONDCP
officials, this was done to maintain the National Drug Control
Strategy's emphasis on the Southwest border.  Subsequently, Customs
reallocated 47 of the 119 positions to Southwest border ports. 

According to Customs officials, the potential reallocation of
existing inspectional personnel has also been affected by legislative
requirements.  As discussed earlier, positions funded with the user
fees established in the Consolidated Omnibus Budget Reconciliation
Act of 1985 as amended, cannot be redeployed because these positions
are funded for specific purposes at specific ports.  In addition,
according to the officials, the positions funded in the fiscal year
1997 appropriation for Operation Hard Line were to be used
exclusively at Southwest border ports. 


   TOO EARLY TO DETERMINE
   PERSONNEL ASSESSMENT AND
   ALLOCATION IMPLICATIONS
------------------------------------------------------------ Letter :5

It is too early to definitively determine (1) any implications of
Customs not receiving all of the inspectional personnel it originally
estimated to be needed and (2) the effect of the additional personnel
that were appropriated on Customs' drug enforcement operations. 
According to Customs officials, the new inspectors need to gain
experience before they are fully effective.  Further, while many of
the fiscal year 1998 inspectors have been hired, few, if any, have
finished basic training.  Customs plans to assess the effectiveness
of drug enforcement operations by establishing performance measures
and conducting internal evaluations. 


      NEW INSPECTORS NEED TO GAIN
      EXPERIENCE
---------------------------------------------------------- Letter :5.1

One reason that it is too early to determine the impact of the
additional inspectional personnel on Customs' drug enforcement
operations is that new inspectors need to gain experience.  For
example, according to a Southern California CMC official, the CMC's
policy is to provide extensive on-the-job training lasting up to 1
year to new inspectors at its passenger processing port before
deploying them to cargo processing.  New inspectors are effective in
interdicting drugs in the passenger processing environment, but must
receive commercial operations training to be proficient at drug
interdiction in the truck and rail environments on the Southwest
border.  As a result, according to this official, it may take up to 2
years to fully train new inspectors in the skills needed in all areas
of this CMC's operations.  Also, the South Texas CMC Director said
that, once the new inspectors were hired and trained, they were sent
to this CMC for an additional 10 weeks of specialized training, of
which 2 weeks were for cargo inspections.  The Director estimated
that it then takes about 6 months before new inspectors are fully
productive on their own. 


      ADDITIONAL INSPECTORS FUNDED
      IN FISCAL YEAR 1998 HAVE NOT
      BEEN DEPLOYED
---------------------------------------------------------- Letter :5.2

A second reason why it is too soon to determine the full impact of
the additional resources is that, while many of the 119 inspector
positions funded for fiscal year 1998 have been filled, few, if any
of these inspectors have completed basic training.  An ASD official
said that, as of early April 1998, about 60 percent of the inspectors
had been hired and were in basic training, and thus had not been
deployed in the field. 


      CUSTOMS PLANS TO EVALUATE
      EFFECTIVENESS OF ENFORCEMENT
      INITIATIVES
---------------------------------------------------------- Letter :5.3

Customs plans to evaluate the effectiveness of its anti-drug
smuggling initiatives.  To this end, in its fiscal year 1997 to 2002
Strategic Plan, Customs established seven measures or improvement
targets, including the number and amount of drug seizures and the
ratio of seizures to the number of cargo examinations conducted. 
Three other measures or targets--including the number of internal
conspiracies disrupted--were being reviewed at the time of the
Strategic Plan's introduction by Customs management for possible
permanent inclusion in the Plan.  Customs also proposed to conduct
internal evaluations of its strategies, including the narcotics
strategy.  For example, it plans to evaluate the interdiction
component of that strategy in fiscal year 1999. 

We have previously reported\15 that, while Customs' goals and
objectives appear to be results-oriented and measurable, it still
faces challenges in evaluating its drug interdiction mission.  For
example, according to several Customs officials, it is unclear
whether an increase in drug seizures indicates that Customs has
become more effective or that the extent of drug smuggling has
increased significantly. 


--------------------
\15 See Customs Service:  Drug Interdiction Efforts
(GAO/GGD-96-189BR, Sept.  26, 1996) and Customs Service:  Comments on
Strategic Plan and Resource Allocation Process (GAO/T-GGD-98-15, Oct. 
16, 1997). 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

Customs does not have an agencywide process for annually determining
its need for inspectional personnel--such as inspectors and canine
enforcement officers--for all of its cargo operations and for
allocating these personnel to commercial ports of entry.  Customs has
moved in this direction since 1995 by conducting three assessments to
determine its need for additional inspectional personnel.  However,
these assessments (1) focused exclusively on the need for additional
resources to implement Operation Hard Line and other anti-smuggling
initiatives, (2) were limited to land ports along the Southwest
border and certain sea and air ports at risk from drug smuggling, (3)
were conducted each year using different assessment factors, and (4)
were conducted with varying degrees of involvement from Customs
units. 

Focusing on only a single aspect of its operations (i.e., countering
drug smuggling), not consistently including the key field components
(i.e., CMCs and ports) in the decisionmaking process, and using
different assessment and allocation factors from year to year could
prevent Customs from accurately estimating the need for inspectional
personnel and then allocating them to ports. 

In conducting its strategic planning under the Results Act, Customs
will need an annual approach that considers all of its commercial
ports, its mission-related functions, and the impact of technology
and related equipment so that it can determine the inspectional
personnel it would need to achieve the desired mission outcomes it
details in its strategic and annual performance plans.  Customs, in
its strategic planning documents, has already recognized the need to
review its personnel deployments, evaluate their effectiveness, and
address any necessary changes and to address the link between
performance goals and existing and anticipated resources, including
personnel. 

We recognize that Customs' requests for inspectional personnel will
continue to be influenced by budget, policy, and legislative
constraints.  However, we believe that by developing a process that,
in addition to considering drug enforcement activities, also
considers mission-critical functions related to processing cargo at
commercial ports, Customs would be able to provide Treasury, OMB,
ONDCP, and Congress with more systematically developed personnel
needs estimates and rationales for these estimates. 


   RECOMMENDATION
------------------------------------------------------------ Letter :7

We recommend that, as a sound strategic planning practice, and taking
into account budget and other constraints, the Commissioner of
Customs establish a systematic process to ensure, to the extent
possible, that Customs' inspectional personnel are properly aligned
with its goals, objectives, and strategies, including those for drug
enforcement.  Such a process should include conducting annual
assessments to determine the appropriate staffing levels for its
operational activities related to processing cargo at commercial
ports. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :8

We requested comments on a draft of this report from the Director of
OMB, the Director of ONDCP, and the Secretary of the Treasury, or
their designees.  On April 2, April 6, and April 8, 1998,
respectively, the Chief of OMB's Treasury Branch; the Director of
ONDCP's Office of Programs, Budget, Research, and Evaluation; and the
Assistant Commissioner of Customs' Office of Field Operations
provided us with their agencies' oral comments on the draft.  These
officials generally agreed with our conclusions and recommendation. 
The officials also provided technical comments and clarifications,
which we have incorporated in this report where appropriate.  The
Assistant Commissioner indicated that Customs had already undertaken
steps to begin implementing the recommendation. 


---------------------------------------------------------- Letter :8.1

We are sending copies of this report to the Secretary of the
Treasury, the Commissioner of Customs, and to the Chairmen and
Ranking Minority Members of the congressional committees that have
responsibilities related to these issues.  Copies also will be made
available to others upon request. 

The major contributors to this report are listed in appendix III.  If
you or your staff have any questions about the information in this
report, please contact me on (202) 512-8777 or Darryl Dutton,
Assistant Director, on (213) 830-1000. 

Sincerely yours,

Norman J.  Rabkin
Director, Administration
 of Justice Issues


OBJECTIVES, SCOPE, AND METHODOLOGY
=========================================================== Appendix I

Our objectives in this review were to determine (1) how Customs
assesses its needs for inspectional personnel and allocates these
personnel to commercial ports of entry, (2) whether Customs received
all the inspectional personnel its assessments indicated it needed,
and (3) whether there are any known implications of Customs' not
receiving all of the personnel estimated to be needed and the impact
of the additional personnel that were appropriated on Customs' drug
enforcement operations. 

To determine how Customs assesses its needs for inspectional
personnel and allocates these personnel to commercial ports of entry,
we obtained and reviewed relevant documentation.  The documentation
included (1) a headquarters directive to the then districts--now
Customs Management Centers (CMC)--and ports initiating an assessment
of the needs for inspectional personnel, (2) CMCs' detailed responses
to this directive, (3) budget proposals and requests, and (4)
matrices developed by Customs headquarters that are used to allocate
the inspectional personnel appropriated by Congress to ports of
entry.  The documentation also included summaries of current and
historical workloads and staffing levels and assessments of the drug
smuggling threat.  We discussed these documents and related issues
with cognizant officials from Customs' Anti-Smuggling Division within
the Office of Field Operations, the Budget Division within the Office
of Finance, and the CMCs and ports we visited or contacted. 

We also held discussions with officials from the Department of the
Treasury's Office of Finance and Administration and Office of Budget,
the Office of Management and Budget's (OMB) Treasury Branch, and the
Office of National Drug Control Policy (ONDCP). 

To determine whether Customs received all the inspectional personnel
it estimated were needed, we obtained and reviewed relevant budget
documents, such as internal Customs and Treasury memorandums,
reports, and budget request reviews, and congressional appropriations
legislation.  We compared the appropriated levels with those that
were estimated as needed and discussed discrepancies with cognizant
Customs, Treasury, and OMB officials. 

To determine the known implications, if any, of Customs' not
receiving all of the personnel it estimated were needed, we obtained
and reviewed relevant documents, such as summaries of Operation Hard
Line and Customs' Strategic Plan.  We also interviewed cognizant
Customs officials at headquarters and at CMCs and ports of entry. 
During these interviews, we focused on the effect, if any, of
Customs' not receiving the level of personnel it originally estimated
were needed on its enforcement activities at ports of entry.  We also
used this information to determine if the potential contributions of
the additional personnel that were provided to Customs could be
identified. 

We visited the Southern California and South Texas CMCs and contacted
the Arizona CMC by telephone because they represented three of the
four CMCs along the Southwest border of the United States.  We
visited the Otay Mesa, California, and Laredo, Texas, ports of entry
and contacted the Nogales, Arizona, port of entry by telephone
because they each were among the busiest ports within their
respective CMCs in terms of the number of vehicles and commodities
entering the United States each day.  The ports also processed a
diverse mix of imports, including produce, television sets, and
liquor. 

Laredo consists of two separate cargo facilities:  the downtown
Laredo facility and the Colombia Bridge facility; combined, they form
the busiest commercial cargo port along the Southwest border.  For
the purposes of this review, we focused only on the operations of the
Laredo facility, the busier of the two facilities.  During fiscal
year 1996, the Laredo facility handled about 732,000 vehicles, which
was an average of 2,007 vehicles per day.\1 The Laredo facility had
13 dock spaces to examine trucks and cargo and, as of July 1997, had
a staff of 49 inspectors, canine enforcement officers, and
supervisors.  The Laredo facility is located 154 miles south of San
Antonio, Texas. 

Otay Mesa was the third busiest commercial cargo port on the
Southwest border.  In fiscal year 1996, Otay Mesa handled over
516,000 vehicles, which was an average of 1,422 vehicles per day. 
The port had over 100 dock spaces available for inspections and, as
of July 1997, had 110 inspectors, canine enforcement officers, and
supervisors.  Otay Mesa is located about 15 miles south of San Diego. 

Nogales, Arizona, was the fifth busiest commercial cargo port on the
Southwest border, handling about 208,000 vehicles during fiscal year
1996, which was an average of 572 vehicles per day.  Nogales had 92
dock spaces dedicated to Customs inspections and, as of April 1997,
had a staff of 27 inspectors, canine enforcement officers, and
supervisors.  The port is located 67 miles south of Tucson, Arizona. 

Since it was not material for the purposes of this review, we did not
independently verify the accuracy and validity of Customs' workload
and personnel data.  However, to obtain some indication about the
overall quality of the data and Customs' own confidence in their
accuracy and validity, we held discussions with a cognizant Customs
official.  According to this official, the personnel data resided in
Customs' Office of Human Resources database.  The workload data
resided in its Port Tracking System database.  The Customs official
expressed general confidence in the accuracy and validity of the
data.  He said his confidence was based on the fact that the data
were compiled using standardized definitions and entry formats. 


--------------------
\1 The average number of vehicles per day reflects the traffic
average over a 1-year period, which includes both weekdays, when the
traffic volume is much higher, and weekends, when the traffic volume
is much lower. 


CUSTOMS' INSPECTIONAL PERSONNEL
LEVELS
========================================================== Appendix II

The number of Customs inspectional personnel--inspectors and canine
enforcement officers--increased overall between fiscal year 1992, the
earliest year for which complete data were available, and fiscal year
1997.  During the same period, the number and percentage of
inspectional personnel deployed at the Southwest border, while
increasing overall, fluctuated from year to year. 

According to Customs officials, year-to-year fluctuations in
personnel levels could be attributed in part to the effects of
attrition.  For example, while additional positions may have been
funded for a particular year or purpose (for example, in fiscal year
1997, for Operation Hard Line), others may have become vacant through
retirement. 

In addition, according to Customs and Treasury officials, other
positions could be lost because of the effects of reductions in
Customs' baseline funding.  For example, in fiscal year 1997, Customs
had to absorb a reduction of $38 million in its baseline funding to
address unfunded mandates.  As a result, 733 positions were removed
through a comparability adjustment by OMB because they could not be
funded.  According to OMB officials, a comparability adjustment
brings an agency's authorized staffing levels more into line with
actual funded levels.  The loss of the 733 positions more than offset
the 657 additional positions appropriated for Operation Hard Line,
according to Customs officials. 

The Customs officials also cautioned that end-of-year data
represented only a point-in-time snapshot of personnel levels. 
Accordingly, funded personnel levels throughout a particular year
could have been lower or higher than the end-of-year number. 


      CUSTOMS' INSPECTOR PERSONNEL
      LEVELS (FISCAL YEARS 1992
      THROUGH 1997)
------------------------------------------------------ Appendix II:0.1

Table II.1 shows that the number of Customs inspectors overall grew
by about 17 percent between fiscal years 1992 and 1997.  During the
same period, while fluctuating from year to year, the number of
inspectors deployed at the Southwest border grew by about 36 percent. 
The number of inspectors deployed at the Southwest border as a
percentage of all Customs inspectors also fluctuated from year to
year, but grew from about 24 percent of the total in fiscal year 1992
to about 28 percent in fiscal year 1997. 



                               Table II.1
                
                 Number of Customs Inspectors Deployed
                  Overall and at the Southwest Border,
                       Fiscal Years 1992 to 1997

                                                             Percentag
                                                                     e
                                                              deployed
                                                     Southw         at
                                             Overal     est  Southwest
Fiscal year                                       l  border     border
-------------------------------------------  ------  ------  ---------
1992                                          6,159   1,488      24.2%
1993                                          6,258   1,592       25.4
1994                                          6,421   1,673       26.1
1995                                          6,588   1,664       25.3
1996                                          6,835   1,654       24.2
1997                                          7,207   2,023       28.1
Percentage change, fiscal years 1992-1997     17.0%   35.9%
----------------------------------------------------------------------
Note 1:  Fiscal year 1992 was the earliest year that complete data
were available. 

Note 2:  Inspector numbers could not be separated by passenger and
cargo processing functions.  According to Customs, ports shift
inspectors between functions, depending on workload. 

Source:  GAO analysis of Customs data. 


      CUSTOMS' CANINE ENFORCEMENT
      OFFICER PERSONNEL LEVELS
      (FISCAL YEARS 1992 THROUGH
      1997)
------------------------------------------------------ Appendix II:0.2

Table II.2 shows that the number of Customs canine enforcement
officers overall increased between fiscal years 1992 and 1997 by
about 37 percent.  The number of canine enforcement officers deployed
at the Southwest border fluctuated during the same period, while
growing by about 67 percent.  The number of canine enforcement
officers deployed at the Southwest border as a percentage of the
total, while also fluctuating from year to year, increased from about
50 percent in fiscal year 1992 to about 62 percent in fiscal year
1997. 



                               Table II.2
                
                  Number of Customs Canine Enforcement
                  Officers Deployed Overall and at the
                 Southwest Border, Fiscal Years 1992 to
                                  1997

                                                             Percentag
                                                                     e
                                                              deployed
                                                     Southw         at
                                             Overal     est  Southwest
Fiscal year                                       l  border     border
-------------------------------------------  ------  ------  ---------
1992                                            405     204      50.4%
1993                                            417     204       48.9
1994                                            444     236       53.1
1995                                            467     256       54.8
1996                                            469     236       50.3
1997                                            553     340       61.5
Percentage change, fiscal years 1992-1997     36.5%   66.7%
----------------------------------------------------------------------
Note 1:  Fiscal year 1992 was the earliest year that complete data
were available. 

Note 2:  Canine enforcement officer numbers could not be separated by
passenger and cargo processing functions.  According to Customs,
ports shift canine enforcement officers between functions, depending
on workload. 

Source:  GAO analysis of Customs data. 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

GENERAL GOVERNMENT DIVISION,
WASHINGTON, D.C. 

Darryl W.  Dutton, Assistant Director
Seto J.  Bagdoyan, Evaluator-in-Charge
Wendy C.  Graves, Evaluator

OFFICE OF THE GENERAL COUNSEL,
WASHINGTON, D.C. 

Ann H.  Finley, Senior Attorney

LOS ANGELES FIELD OFFICE

Kathleen H.  Ebert, Senior Evaluator


*** End of document. ***