oversight

DHS Has Limited Capabilities to Counter Illicit Unmanned Aircraft Systems

Published by the Department of Homeland Security, Office of Inspector General on 2020-06-29.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

DHS Has Limited Capabilities
to Counter Illicit Unmanned
Aircraft Systems




                     June 25, 2020
                        OIG-20-43
June 25, 2020
	
                                          DHS OIG HIGHLIGHTS

                             DHS Has Limited Capabilities to 

                         Counter Illicit Unmanned Aircraft Systems 

            

June 25, 2020                              What We Found
                                           DHS’ capability to counter illicit UAS activity remains
Why We Did                                 limited. On November 8, 2018, the former DHS
This Audit                                 Secretary issued an internal memorandum calling for a
                                           uniform approach to DHS’ expansion of its C-UAS
Unmanned Aircraft                          capability under the Preventing Emerging Threats Act.
Systems (UAS), commonly                    The Secretary assigned the Office of Strategy, Policy,
referred to as ‘drones,’                   and Plans (Office of Policy) as the Department’s lead
present an emerging threat                 over components with authorized C-UAS missions
to the Nation as their                     (United States Secret Service, United States Coast
popularity grows.                          Guard, Customs and Border Protection, and Federal
Terrorists, criminal                       Protective Service). The Secretary instructed these
organizations, and lone                    components to not take any actions toward C-UAS
actors have used UAS for                   expansion until the Office of Policy completed a uniform
malicious purposes. The                    approach for doing so.
Department of Homeland
Security is tasked with                    However, the Office of Policy did not execute a uniform
protecting and securing                    approach as directed because it did not request the
the homeland from these                    funding needed to obtain subject matter experts to fulfill
evolving threats. We                       all of the Secretary’s requirements for the uniform
conducted this audit to                    approach, including developing a realistic work plan
determine to what extent                   and issuing complete department-wide C-UAS guidance.
DHS counters illicit use of                According to DHS officials, funding for C-UAS
UAS while protecting the                   expansion unsuccessfully competed with other mission
homeland.                                  priorities for budget resources. Consequently, DHS will
                                           remain vulnerable to increased security risks and
What We                                    emerging threats from unmanned aircraft until it
Recommend                                  expands its capability to counter illicit UAS activity.

We made four
recommendations to
                                           Agency Response
improve the Department’s
management and                             DHS concurred with all four recommendations and
implementation of counter-                 initiated corrective actions to address the findings.
unmanned aircraft
systems (C-UAS) activities.

For Further Information:
Contact our Office of Public Affairs at
(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov


           www.oig.dhs.gov                                                                  OIG-20-43
                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

                                     Background

Unmanned Aircraft Systems (UAS), commonly referred to as ‘drones,’ present
an emerging threat to the Nation as their popularity grows. The FAA
Modernization and Reform Act of 2012 defines a UAS as an unmanned aircraft
and its associated elements. These elements include the pilot in command and
the aircraft that operate in the national airspace system. The Federal Aviation
Administration (FAA) projects the recreational UAS fleet to grow from 1.2
million units in 2018 to 1.4 million in 2023, an average annual growth rate of
2.2 percent. Additionally, the commercial UAS fleet is forecasted to nearly
triple from 277,386 in 2018 to 835,211 in 2023, an average annual growth rate
of 24.7 percent. Further with more than 900,000 UAS owners registered as of
December 31, 2018, the FAA estimated there were about 1.25 million model
drones in circulation. As described, the legitimate use of UAS is on the rise.
The increased availability of drones on the open market continues to amplify
security risks and emerging threats for the foreseeable future. Table 1 provides
a brief identification and explanation of UAS-related threats facing the
Department of Homeland Security.

Table 1: DHS’ UAS-Related Threats and Definitions
 UAS Threat                   Definition/Explanation
 Weaponized or                UAS are capable of transporting contraband, chemical,
 Smuggling Payloads           or other explosive/weaponized payloads.
 Prohibited Surveillance      UAS are capable of silently monitoring a large area
 and Reconnaissance           from the sky for nefarious purposes.
 Intellectual Property        UAS are capable of performing cybercrimes involving
 Theft                        theft of sensitive information.
 Intentional Disruption or    UAS are capable of disrupting and invading the privacy
 Harassment                   of individuals.
Source: DHS Cybersecurity and Infrastructure Security Agency

In a September 5, 2018 press release, “Rethinking Homeland Security in an
Age of Disruption”, the DHS Secretary remarked, “Terrorists are using drones
on the battlefield to surveil and to
destroy. Drug smugglers are using them
to monitor border patrol officers so they
can slip into America undetected. And
criminals are using them to spy on
sensitive facilities. Drones can also be
used to disrupt communications and or to
steal data on nearby Wi-Fi.” In January
2015, a drone crashed onto the lawn of
                                           Figure 1: Drone that Crashed onto the
the White House illustrating a drone’s
                                           White House Lawn
ability to evade detection and create      Source: Office of Inspector General (OIG)
challenges for secure facilities. Figure 1 obtained from internet

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shows the drone recovered from the White House lawn by the United States
Secret Service (Secret Service). Further, in August 2017, drug smugglers used
a drone to smuggle 13 pounds of methamphetamine across the Southwest
Border of the United States. Figure 2 shows the drone and methamphetamine
recovered by U.S. Customs and Border Protection (CBP).




Figure 2: A Drone Smuggling Methamphetamine across the Southwest Border
Source: OIG obtained from internet

These are just two examples of the illicit UAS activity DHS faces as it seeks to
expand its Counter Unmanned Aircraft Systems (C-UAS) capability.1

DHS Authorities

On October 5, 2018, the President signed into law the Preventing Emerging
Threats Act of 2018 (the Act), the first statutory grant of authority for DHS to
explicitly counter UAS threats. Prior to passage of the Act, only the Secret
Service and the United States Coast Guard (Coast Guard) had express
authority to counter illicit UAS activity. These components’ capabilities were
limited because C-UAS authority was either restricted to each component’s
specific mission or under the auspices of another department.

Secret Service

According to Secret Service officials, the Secret Service started its C-UAS
development in 2012 prior to passage of the Act, to support requirements of its
protective mission pursuant to 18 United States Code (U.S.C.) 3056, Powers,
                                                       
1 We define C-UAS capability as being able to perform all five authorized actions (detection,
identification, monitoring, tracking, and mitigation), and limited C-UAS capability as being able
to perform at least one, but not all, authorized actions.

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Authorities, and Duties of United States Secret Service and pursuant to
Executive Order 12333.

Coast Guard

In June 2017, the Deputy Commandant for Operations directed the Coast
Guard to pursue C-UAS authorized actions under Department of Defense
(DOD) authority to support its maritime escort mission. Therefore, the Coast
Guard’s C-UAS capability was restricted to operating during DOD maritime
escort missions. In this capacity, the Coast Guard operates under Title 10
U.S.C. Section 130i - Protection of Certain Facilities and Assets from Unmanned
Aircraft, whereby certain DOD assets require Coast Guard escorts when
operating in and out of their homeports.

CBP and Federal Protective Service

Passage of the Act expanded DHS legacy component authorities by granting
CBP and the Federal Protective Service (FPS) authority to obtain and operate
C-UAS mitigation capabilities. For example, CBP did not have the express
authority to mitigate a UAS threat before the passage of the Act. However, it
was able to passively detect UAS activities using its existing border surveillance
capabilities. Further, FPS had neither the authority nor the capability to
mitigate a UAS threat before passage of the Act empowered it to do so. At the
time of our audit, FPS was not actively pursuing a C-UAS capability.

Table 2 identifies DHS component authorities to counter illicit UAS prior to and
following the passage of the Act.

Table 2: DHS C-UAS Authorities Prior to and Following the Act
                           Secret      Coast Guard     CBP                 FPS
                           Service
       Prior to Act          Yes           Yes          No                 No
         Post Act            Yes           Yes          Yes                Yes
Source: DHS OIG analysis of authorities before and after the Act

In general, the Act permits authorized DHS component personnel to:

          detect, identify, monitor, and track UAS without prior consent;
          warn the operator of a UAS, including by electromagnetic means;
          disrupt control, seize control, or confiscate a UAS without prior
           consent; and
          use reasonable force to disable, damage, or destroy a UAS.



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C-UAS Capability

Authorized component personnel may operate C-UAS capabilities to eliminate
credible threats2 posed by a UAS. These capabilities include systems or
devices capable of performing five authorized actions to secure and protect
covered facilities or assets:3 detect, identify, monitor, track, and mitigate.
C-UAS capabilities may require a layered approach that integrates the following
actions necessary to mitigate a potential threat.

                   Detect – Discovering a UAS by visual or electronic means.
                   Identify – Distinguishing UAS threats from lawful activity.
                   Monitor – Continuous observation of a UAS to determine intent.
                   Track – Observation of a UAS to determine its path.
                   Mitigate – Acting to deter, prevent, or minimize the consequences of
                    safety and security threats posed by certain UAS. DHS may use both
                    nonkinetic force, such as electronic means, and reasonable physical
                    force to mitigate UAS threats.

We conducted this audit to determine to what extent DHS counters illicit use of
UAS while protecting the homeland.

                                                          Results of Audit

DHS’ C-UAS Capabilities Remain Limited

The Department’s capability to counter illicit UAS activity remains limited.
DHS’ components with authorized C-UAS missions (Secret Service, Coast
Guard, CBP, and FPS) could not expand their C-UAS capabilities as permitted
by the Act because the Office of Policy did not execute a uniform approach by
which to do so, as the Secretary had directed. Specifically, the Office of Policy
did not request the funding required to obtain subject matter experts to fulfill
all of the Secretary’s requirements of the uniform approach, including
developing a realistic work plan and issuing complete department-wide C-UAS
guidance. According to DHS officials, funding for C-UAS expansion
unsuccessfully competed with other Department mission priorities for budget
resources. Consequently, DHS will remain vulnerable to increased security
risks and emerging threats from unmanned aircraft until it expands its
capability to counter illicit UAS activity.

                                                       
2 Credible threat is the reasonable likelihood a UAS, if unabated, would disrupt DHS 

operations.

3 Covered facilities and assets are (i) located in the United States, (ii) directly related to certain 


DHS missions, and (iii) identified as high-risk and potential targets for unlawful UAS activity. 


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DHS Did Not Expand Its C-UAS Capabilities

On November 8, 2018, the former DHS Secretary issued an internal
memorandum, Preparing for Implementation of the Preventing Emerging Threats
Act of 2018, outlining a uniform approach to expanding DHS’ C-UAS capability.
The Secretary assigned DHS’ Office of Strategy, Policy, and Plans (Office of
Policy) as the lead over Department components authorized to conduct C-UAS
operations. Further, the Secretary instructed the components to not take any
C-UAS implementation actions under the Act until Office of Policy had
completed the uniform approach.

However, the Office of Policy did not proceed with executing the desired
uniform approach, preventing components from expanding their capabilities as
permitted by the Act. The Secret Service continued operating a C-UAS
capability for its protective mission and the Coast Guard did not expand its
capability beyond its DOD maritime escort mission. Additionally, CBP and FPS
did not obtain C-UAS capabilities. Table 3 identifies DHS’ capability to counter
illicit UAS prior to and following passage of the Act and issuance of the former
Secretary’s memo.

    Table 3: DHS C-UAS Capability Prior to and Following the Act
                                             Secret            Coast Guard          CBP   FPS
                                             Service
                                              Yes –
          Pre Act /                                         Yes – DOD Maritime
                                            Protective                              No    No
           Memo                                               Escort Mission
                                             Mission
                                              Yes –
         Post Act /                                         Yes – DOD Maritime
                                            Protective                              No    No
           Memo                                               Escort Mission
                                             Mission
 Source: DHS OIG analysis of C-UAS capability before and after the passage of the Act

Office of Policy Remained Unfunded

The Office of Policy did not execute a uniform approach to expand DHS’ C-UAS
capability because it did not request funding as directed by the Secretary. The
Secretary’s memo directed the Office of Policy to work with the Office of the
Chief Financial Officer (OCFO) to prepare a request for reprogramming4 of prior
year funds. However, according to Office of Policy officials, they did not believe
the OCFO would approve a reprogramming request for C-UAS implementation
efforts because of numerous competing budgetary priorities. Therefore, the
Office of Policy did not submit a formal reprogramming request to the OCFO as
directed in the Secretary’s memorandum and did not obtain the funding it
                                                       
4Reprogramming is the moving of funds within an appropriation or from one budget activity to
another.

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needed to support C-UAS expansion.

Lack of Subject Matter Experts

In its response to the FY 2020 DHS Appropriations Bill Technical Assistance
Request, the Office of Policy identified a need for specific subject matter experts
to guide its C-UAS expansion across six lines of effort:

      1.   policy development;
      2.   interagency coordination / driving implementation;
      3.   requirements, research, development, and testing and evaluation;
      4.   operations coordination;
      5.   external training, education and engagement; and
      6.   program management.

However, inadequate funding prevented the Office of Policy from obtaining the
subject matter experts it needed to fulfill all of the Secretary’s requirements for
DHS’ C-UAS expansion, including developing a work plan and issuing
department-wide C-UAS guidance. As such, the Office of Policy relied on
detailees who did not possess the technical expertise needed to facilitate DHS'
C-UAS implementation. According to Office of Policy officials, their office did
not possess the full complement of skills needed to drive progress and ensure
department-wide coordination of C-UAS activities.

Unrealistic Work Plan

The Secretary’s memorandum directed the Office of Policy to develop a C-UAS
work plan describing implementation actions and including milestones to aid
DHS’ C-UAS efforts. The work plan the Office of Policy developed enabled DHS
to complete some, but not all, required C-UAS expansion tasks, and not always
on time. The plan was also unrealistic, resulting in DHS missing target dates
for completing several tasks outlined in the Secretary’s memorandum. For
example, DHS issued C-UAS guidance in September 2019, significantly later
than the target date of April 2019. Additionally, guidance for resource
allocation plans for FY 2019 funding, the incident reporting process, and
covered facility prioritization remain incomplete. DHS officials from three
offices confirmed the work plan was outdated and no longer relevant. Table 4
shows selected implementation actions with estimated and actual completion
dates.




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Table 4: Selected Work Plan Target Dates versus Actual Completion Dates
               Task Name                    Target Date    Actual Date
 Establish Executive Steering
                                          November 2018 November 2018
 Committee and Working Groups
 Provide Guidance for Resource
 Allocation Plans for FY19 Funding        December 2018 Incomplete
 Develop Incident Reporting Process       January 2019  Incomplete
 Covered Facility or Asset Identification
                                          December 2018 Incomplete
 and Prioritization Process
 Departmental Guidance*                   April 2019    September 2019
Source: DHS OIG analysis of Office of Policy C-UAS work plan
* Although Department policy guidance was issued, we determined it was incomplete, as we
identify later in the report.

C-UAS Guidance Is Incomplete

The Secretary’s memorandum required the Office of Policy to develop and issue
C-UAS guidance for DHS prior to any implementation efforts. The Office of
Policy issued the Secretary’s Counter-Unmanned Aircraft Systems Policy
Guidance on September 10, 2019, but the guidance was incomplete. Although
the guidance referred to six annexes specifying processes and procedures DHS
components authorized to conduct C-UAS operations should follow to ensure
program uniformity and consistency, the annexes were missing from the
document. The six annexes were to describe the key processes and procedures
related to covered facilities, coordination, privacy, external support, reporting,
and key definitions. As of the final report issuance, DHS officials confirmed the
Office of Policy had not completed the six annexes.

                                     Conclusion

Until DHS funds the C-UAS initiative, and authorized components expand their
capability to counter illicit UAS activity, the homeland will remain vulnerable to
increased security risks and emerging threats for the foreseeable future.
Without subject matter experts, a realistic work plan, and fully developed
C-UAS guidance, DHS’ ability to coordinate component C-UAS efforts will
continue to be hindered. Further, without proper coordination across
components and a uniform approach to expansion, C-UAS capabilities could be
significantly delayed or altogether ineffective. Specifically:

       	 C-UAS policies may be fragmented and vary from component to
          component, potentially leading to inconsistent applications of C-UAS
          capabilities and authorities.



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         Components may develop and use different standards to assess and
          propose assets and locations for C-UAS protection.
         Some components may acquire and deploy less capable systems than
          other components, hindering DHS’ overall ability to counter the UAS
          threat.

                             Recommendations

Recommendation 1: We recommend the Under Secretary for Strategy, Policy,
and Plans identify its budget requirements and convey those requirements to
the Office of the Chief Financial Officer for consideration as identified in the
Secretary of Homeland Security’s memorandum dated November 8, 2018.

Recommendation 2: We recommend the Under Secretary for Strategy, Policy,
and Plans conduct an objective workforce analysis of the C-UAS Program
Management Office to determine the appropriate staff needed to accomplish the
office’s mission cost-effectively.

Recommendation 3: We recommend the Under Secretary for Strategy, Policy,
and Plans develop a timeline with achievable goals for C-UAS capability
implementation across the Department.

Recommendation 4: We recommend the Under Secretary for Strategy, Policy,
and Plans complete the Secretary’s Counter Unmanned Aircraft Systems Policy
Guidance, including the annexes specifying processes and procedures the
Department needs to conduct C-UAS operations and ensure program
uniformity and consistency.

              Management Comments and OIG Analysis

The Office of Policy concurred with our four recommendations and is taking
steps, or has implemented actions to address them. Although the Office of
Policy did not concur with our overall report conclusion, we still contend that it
did not execute a uniform approach to address the Secretary’s
November 8, 2018 memorandum, Preparing for Implementation of the Preventing
Emerging Threats Act of 2018. The Office of Policy cites that the approach it
developed and implemented to include establishment of the C-UAS Program
Management Office (PMO) facilitated meaningful progress in its efforts to
address the Secretary’s requirements. We likewise acknowledge the
establishment of the C-UAS PMO and other initiatives it undertook as
important steps toward meeting the Secretary’s mandate. However, the C-UAS
PMO did not fully carry out the steps outlined in the Secretary’s memo, which
prevented implementation of a uniform approach and deployment of a

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department-wide C-UAS capability. Consequently, the Department’s C-UAS
capability was not expanded beyond the capabilities that the Secret Service and
Coast Guard already possessed.

The Office of Policy also questioned, "The value added in recommending actions
the audit team was told were already being taken" to correct the deficiencies we
identified. We recognize that the Office of Policy proactively implemented some
actions towards resolving our recommendations. However, providing formal
recommendations in our report holds the audited entity accountable to ensure
these deficiencies ultimately are fully implemented. Although the Office of
Policy satisfied one of the four recommendations we made in its entirety, this is
only one step needed to achieve the Secretary’s uniform department-wide C-
UAS approach.

Appendix A contains the Office of Policy’s management comments in their
entirety. We also received technical comments to the draft report and revised
the report where appropriate. A summary of the Office of Policy's responses
and our analysis follow.

DHS Comments to Recommendation 1: Concur. The Office of Policy’s PMO
manages all C-UAS coordination across the Department and related
interagency efforts. A fully functional PMO requires approximately $5 million
annually to support nine full-time equivalent staff and operating funds. The
Office of Policy submitted this requirement to the OCFO on April 5, 2020, as
part of the formal Fiscal Years 2022–2026 Resource Allocation Planning
process.

OIG Analysis of DHS Comments: The Office of Policy has taken steps to
satisfy the intent of this recommendation. We obtained and analyzed the
Resource Allocation Plan Program Decision Option for FYs 2022–2026 and
determined that the Office of Policy identified and conveyed necessary budget
requirements to the OCFO. If the Office of Policy receives the full budget as
requested, it should be able to complete many of the requirements to
implement a C-UAS capability throughout the Department. We consider this
recommendation resolved and closed.
DHS Comments to Recommendation 2: Concur. In addition to the
$5 million budget requirement submitted to DHS’ OCFO on April 5, 2020, the
Office of Policy will scope and execute a workforce analysis tailored to meet
requirements for a future state C-UAS PMO. The Office of Policy will identify
an appropriate funding source and the appropriate resource to perform the
workforce analysis. The PMO will also collaborate with component partners to
clearly delineate roles and responsibilities as well as prioritize its functions to
better identify required subject matter expertise, as appropriate. Estimated
Completion Date: April 30, 2021.

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OIG Analysis of DHS Comments: The Office of Policy has taken steps to
satisfy the intent of this recommendation. We consider this recommendation
resolved, but it will remain open until the Office of Policy provides
documentation to support that all planned corrective actions are completed.

DHS Comments to Recommendation 3: Concur. Establishing the DHS
C-UAS PMO within the Office of Policy’s Office of Counterterrorism and Threat
Prevention Policy enhances DHS’ implementation and oversight capacity, and
enables completion of tasks within established deadlines, along with
improvements in interagency communications. The C-UAS PMO and
components made significant progress completing activities identified in the
current work plan. The PMO and components will work with partners to
refresh the work plan by closing out completed milestones, prioritizing current
activities, and establishing new milestones based on relevant projects. The
C-UAS PMO will account for funding and staffing while developing milestones
and deliverable due dates. Estimated Completion Date: April 30, 2021.

OIG Analysis of DHS Comments: The Office of Policy has taken steps to
satisfy the intent of this recommendation. We consider this recommendation
resolved, but it will remain open until the Office of Policy provides
documentation to support that all planned corrective actions are completed.

DHS Comments to Recommendation 4: Concur. As of May 12, 2020, the
Office of Policy had completed three of the six required annexes, and was
coordinating the remaining three draft annexes through the Department-wide
clearance processes, as appropriate. Estimated Completion Date: December
31, 2020.

OIG Analysis of DHS Comments: The Office of Policy has taken steps to
satisfy the intent of this recommendation. We consider this recommendation
resolved, but it will remain open until the Office of Policy provides
documentation to support that all planned corrective actions are completed.

                  Objective, Scope, and Methodology

The Department of Homeland Security Office of Inspector General was
established by the Homeland Security Act of 2002 (Public Law 107−296) by
amendment to the Inspector General Act of 1978.

Our audit objective was to determine to what extent DHS counters illicit use of
UAS while protecting the homeland. To accomplish our objective, we reviewed
Federal laws and regulations related to countering unmanned aircraft systems
and DHS’ internal controls, policies, procedures, and guidance associated with
UAS.

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We interviewed DHS personnel from the Office of Policy, Office of the General
Counsel, Coast Guard, CBP, Cybersecurity and Infrastructure Security Agency,
U.S. Immigration and Customs Enforcement, Secret Service, Transportation
Security Administration, OCFO, Science and Technology Directorate, Office of
Intelligence and Analysis, and FPS.

We reviewed Secret Service, CBP, Coast Guard, and FPS policy and guidance
relevant to C-UAS. We analyzed components’ UAS sighting data. This
included sightings from Secret Service, Coast Guard, CBP, FPS, and the
Transportation Security Administration. However, we are not relying on the
data to support our findings or conclusions. Therefore, we did not perform
data reliability testing.

We conducted this performance audit between February 2019 and October
2019 pursuant to the Inspector General Act of 1978, as amended, and
according to generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based upon our audit objectives. We believe the evidence obtained
provides a reasonable basis for our findings and conclusions based upon our
audit objectives.

Office of Audits major contributors to this report are Maryann Pereira, Director;
Anthony Colache, Audit Manager; Mark Lonetto, Auditor-in-Charge; Ryan
McCarthy, Auditor; Zachary Wilkolaski, Auditor; Tessa Clement, Independent
Reference Reviewer; James Lazarus, Attorney Advisor; and Thomas Hamlin,
Communications Analyst.




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Appendix A
Office of Policy Comments to the Draft Report




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Appendix B
Report Distribution

Department of Homeland Security

Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Under Secretary, Office of Strategy, Policy, and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Senior Official Performing the Duties of Under Secretary, Office of Strategy,
Policy, and Plans
CBP Commissioner
Coast Guard Commandant
Secret Service Director
FPS Director
TSA Administrator

Office of Management and Budget

Chief, Homeland Security Branch
DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees




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