oversight

Proliferation Security Initiative: Agencies Have Adopted Policies and Procedures but Steps Needed to Meet Reporting Requirement and to Measure Results

Published by the Government Accountability Office on 2012-03-27.

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

             United States Government Accountability Office

GAO          Report to Congressional Committees




March 2012
             PROLIFERATION
             SECURITY
             INITIATIVE
             Agencies Have
             Adopted Policies and
             Procedures but Steps
             Needed to Meet
             Reporting
             Requirement and to
             Measure Results




GAO-12-441
                                             March 2012

                                             PROLIFERATION SECURITY INITIATIVE
                                             Agencies Have Adopted Policies and Procedures but
                                             Steps Needed to Meet Reporting Requirement and to
                                             Measure Results
Highlights of GAO-12-441, a report to
congressional committees




Why GAO Did This Study                       What GAO Found
In 2003, the Bush Administration             U.S. agencies have adopted interagency guidance documents that establish PSI
announced the Proliferation Security         policies and procedures and have submitted annual reports; however, these
Initiative (PSI) to enhance U.S. efforts     reports do not contain expenditure data for all agencies as required by law. The
to prevent the spread of weapons of          agencies produced documents that contain general PSI policies and procedures.
mass destruction (WMD). PSI is not a         In addition, DOD and the Department of Homeland Security’s Customs and
program housed in only one agency,           Border Protection (CBP) developed policies and procedures specifically to guide
but instead is a set of activities with      their agencies’ PSI activities. The annual reports submitted in 2009, 2010, and
participation by multiple U.S. agencies      2011 met requirements to describe PSI-related activities planned for future years
and other countries. Congress
                                             and those that took place in the preceding year. Although the reports included an
recommended that the Department of
                                             account of DOD’s PSI expenditures, they did not contain all expenditures for
Defense (DOD) and Department of
State (State) establish policies,
                                             other agencies for PSI activities as required by law.
procedures, and indicators to measure        U.S. officials participated in a range of PSI activities since 2008 to meet their
results and required that they submit        objective of expanding and enhancing counterproliferation efforts, but it is unclear
annual reports. It also mandated that        to what extent these activities have achieved the objective because agencies
GAO report on PSI effectiveness. In          lack measures of results. The agencies either led or participated in 22 PSI
2008, GAO likewise recommended that          activities from fiscal year 2009 through fiscal year 2011 including multilateral
law enforcement agencies also                meetings and exercises. Officials stated that their outreach efforts contributed to
establish policies, procedures, and
                                             increased support for PSI since GAO’s 2008 report, such as the increase from 93
performance indicators.
                                             to 98 countries endorsing PSI. In addition, they have extended access to PSI
This report assesses (1) the progress        activities to more countries that are not part of the group of 21 PSI Operational
relevant agencies have made since            Experts Group countries, for example by holding regional planning meetings.
2008 in establishing recommended PSI         Despite recommendations of Congress and GAO that agencies develop PSI
policies and procedures and issuing          performance indicators, DOD, State, CBP, and the Federal Bureau of
required annual reports; and (2) the         Investigation have not developed indicators that can be used to systematically
extent to which PSI activities have          measure progress toward the stated PSI objective. Further, the agencies have
enhanced and expanded U.S.                   not systematically evaluated PSI activity results. Although some officials
counterproliferation efforts.                indicated plans to develop PSI performance indicators, officials from DOD and
GAO reviewed and analyzed agency             State also cited several challenges to developing indicators to measure PSI
documents and interviewed officials          activities’ results including difficulty quantifying how PSI activities improved
from State, DOD, and other agencies          capacity. However, GAO has previously reported that, despite such challenges,
with PSI responsibilities.                   developing measures that help link activities to results is possible. PSI agencies
                                             could develop a framework that links performance measures to outcomes. For
What GAO Recommends                          example, such a framework could link the number of participants trained to
GAO recommends that State and DOD            changes in national policies that strengthen participant countries’ authority to
provide all required expenditure             interdict the shipment of WMD, their delivery systems, and related materials.
information in PSI annual reports and
develop a framework for measuring
PSI’s results. DOD partially concurred
with both recommendations and State
partially concurred with the reporting
recommendation. State disagreed with
the framework recommendation, but
noted its support for analysis
consistent with it.
View GAO-12-441. For more information,
contact Thomas Melito at (202) 512-9601 or
melitot@gao.gov.

                                                                                      United States Government Accountability Office
Contents


Letter                                                                                            1
               Background                                                                         3
               Agencies Have Adopted Policies and Procedures, but Annual
                 Reports Lack Some Required Information                                           5
               Extent to Which Activities Meet PSI Objective Is Unclear because
                 Agencies Lack Measures of Results                                               11
               Conclusions                                                                       19
               Recommendations for Executive Action                                              20
               Agency Comments and Our Evaluation                                                20

Appendix I     Scope and Methodology                                                             24



Appendix II    Full Text of the Statement of Interdiction Principles                             26



Appendix III   Proliferation Security Initiative Activities from Fiscal Year 2009
               to December 2011                                                                  29



Appendix IV    Comments from the Department of State                                             31



Appendix V     Comments from the Department of Defense                                           36



Appendix VI    GAO Contact and Staff Acknowledgments                                             39




               Page i                                    GAO-12-441 Proliferation Security Initiative
Tables
         Table 1: Annual Estimated Expenditures for Department of
                  Defense Support to PSI-Related Exercises and Other
                  Events, Fiscal Years 2012-2014                                                    8
         Table 2: Prior Year Expenditure Data Included in Annual Reports
                  to Congress                                                                       9
         Table 3: Number and Type of PSI Activities with U.S. Participation,
                  Fiscal Years 2009-2011                                                           12


Figure
         Figure 1: Sample Logic Model                                                              18


         Abbreviations

         9/11 Act          Implementing Recommendations of the 9/11 Commission
                           Act of 2007
         CBP               Customs and Border Protection
         CCP               Critical Capabilities and Practices
         DHS               Department of Homeland Security
         DOD               Department of Defense
         DOE               Department of Energy
         DOJ               Department of Justice
         FBI               Federal Bureau of Investigation
         OEG               Operational Experts Group
         PSI               Proliferation Security Initiative
         State             Department of State
         Treasury          Department of the Treasury
         WMD               weapons of mass destruction




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         Page ii                                          GAO-12-441 Proliferation Security Initiative
United States Government Accountability Office
Washington, DC 20548




                                   March 27, 2012

                                   Congressional Committees

                                   For almost 10 years, the United States has been actively participating in
                                   the Proliferation Security Initiative (PSI) to assist in U.S. efforts to break
                                   up black markets, detect and intercept weapons of mass destruction
                                   (WMD) materials in transit, and use financial tools to disrupt this
                                   dangerous trade. The U.S. government issued the National Strategy to
                                   Combat Weapons of Mass Destruction in 2002, and the proliferation of
                                   WMD, such as nuclear- or missile-related goods or technology, remains
                                   one of today’s key challenges to international security. 1 In May 2003,
                                   President Bush announced PSI, a multinational effort, including the
                                   United States, to focus on building WMD interdiction capabilities by
                                   endorsing the Statement of Interdiction Principles. According to the
                                   Department of State (State), PSI’s objective is to enhance and expand
                                   U.S. efforts to prevent the flow of WMD, their delivery systems, and
                                   related materials on the ground, in the air, and at sea, to and from states
                                   and nonstate actors of proliferation concern. The current administration
                                   has continued to support PSI, and agencies with PSI responsibilities have
                                   reaffirmed that objective. Furthermore, the administration has declared
                                   PSI an important global tool for countering the spread of WMD-related
                                   materials, while President Obama has called for it to be turned into a
                                   “durable international institution.” 2

                                   In our September 2006 report on PSI, we found that U.S. agencies did
                                   not have the policies and procedures in place to plan and manage their
                                   PSI activities or performance indicators to measure their results. We
                                   recommended that they correct these deficiencies. Following our report,
                                   Congress passed the Implementing Recommendations of the 9/11
                                   Commission Act of 2007 (the 9/11 Act), in which it expresses its sense
                                   that relevant agencies and departments take actions to expand and
                                   strengthen PSI, including establishing clear PSI policies and procedures




                                   1
                                    For example, a North Korean cargo ship was reportedly suspected of carrying short-
                                   range missiles to Burma in late May 2011. See Arms Control Today (July 2011-August
                                   2011).
                                   2
                                    See President Obama’s remarks in Prague, Czech Republic, April 5, 2009.




                                   Page 1                                        GAO-12-441 Proliferation Security Initiative
and performance indicators to measure the results of PSI activities. 3 The
9/11 Act also required DOD and State to submit annual PSI reports and
mandated GAO to assess and report periodically on PSI’s effectiveness,
including progress made in implementing the law’s provisions. In 2008,
we reported that agencies had taken some steps but needed to do more
to strengthen and expand PSI, such as taking actions on some of the
law’s provisions. 4 This report updates and provides information on the
agencies’ actions and the progress evaluating PSI since our 2008 report.
Specifically, this report assesses (1) the progress relevant agencies have
made since 2008 in establishing recommended PSI policies and
procedures and issuing required annual reports; and (2) the extent to
which PSI activities have enhanced and expanded U.S.
counterproliferation efforts.

To assess what agencies have done since 2008 to establish
recommended PSI policies and procedures and issue required annual
reports, we reviewed the findings and recommendations in GAO’s 2006
and 2008 reports on PSI and the congressional mandate. We reviewed
documentation of policies and procedures developed since 2008. We also
requested and reviewed annual reports submitted to Congress by State
and the Department of Defense (DOD) and analyzed them for compliance
with the requirements in the 9/11 Act. We reported expenditure data as it
appeared in the annual reports to Congress and determined the data
were sufficiently reliable for the purposes of our report. To assess how
PSI activities have enhanced and expanded U.S. efforts to prevent the
flow of WMD materials and to determine what actions, if any, agencies
have taken to develop indicators of PSI’s success, we reviewed and
analyzed documents from DOD, State, the Department of Homeland
Security (DHS), and the Department of Justice (DOJ). For both
objectives, we also interviewed relevant officials from those agencies.
(See app. I for a detailed discussion of our scope and methodology.)

We conducted this performance audit from June 2011 to March 2012 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain



3
Pub. L. 110-53, sec. 1821(d).
4
 See GAO, U.S. Agencies Have Taken Some Steps, but More Effort Is Needed to
Strengthen and Expand the Proliferation Security Initiative, GAO-09-43 (Washington,
D.C.: Nov. 10, 2008).




Page 2                                         GAO-12-441 Proliferation Security Initiative
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             PSI is a multinational effort to prevent the trafficking of WMD, their
Background   delivery systems, and related materials to and from states and nonstate
             actors of proliferation concern. PSI has no formal organization or
             bureaucracy. In the United States, PSI is not a program housed in a
             single agency, but instead is a set of activities with participation by seven
             agencies and the intelligence community. 5 PSI encourages partnership
             among states to work together to develop a broad range of legal,
             diplomatic, economic, military, law enforcement, and other capabilities to
             prevent WMD-related air, land, or sea transfers to states and nonstate
             actors of proliferation concern. International participation is voluntary, and
             there are no binding treaties on those who choose to participate.
             Countries supporting PSI are expected to endorse PSI principles,
             embodied in four broad goals in the Statement of Interdiction Principles of
             September 2003, by a voluntary, nonbinding “political” commitment to
             those principles. See appendix II for the full text of the Statement of
             Interdiction Principles. They also voluntarily participate in PSI activities
             according to their own capabilities. According to the principles, PSI
             participants use existing national and international authorities to put an
             end to WMD-related trafficking and take steps to strengthen those
             authorities, as necessary.

             The U.S. government’s PSI efforts involve participation in three broad
             activities: multilateral PSI planning meetings called Operational Experts
             Group (OEG) meetings, PSI exercises, and other efforts to encourage
             support and capacity for interdictions, such as workshops and




             5
              U.S. agencies participating in PSI are the Departments of Defense, State, Homeland
             Security, Justice, Energy, Commerce, and the Treasury.




             Page 3                                         GAO-12-441 Proliferation Security Initiative
conferences. 6 According to State, at multilateral PSI planning meetings,
military, law enforcement, intelligence, legal, and diplomatic experts from
the United States and other OEG countries meet to consider ways to
enhance the WMD interdiction capabilities of PSI participants, build
support for the initiative, develop operational concepts, organize PSI
exercises, and share information about national legal authorities. The
policy office in the Office of the Secretary of Defense heads the U.S.
delegation to these multilateral meetings.

PSI exercises vary in size and complexity, and some involve military
personnel and assets from participating PSI countries. Other exercises
examine the use of law enforcement or customs authorities to stop WMD
proliferation. There are also “tabletop” exercises or simulations, which
explore scenarios and determine solutions for hypothetical land, air, or
sea interdictions. Among the most visible PSI exercises are those that
combine a tabletop and a live interdiction exercise using military assets
from multiple PSI countries, such as practicing the tracking and boarding
of a target ship.

Other activities include both outreach to countries that have not endorsed
PSI principles and cooperation and collaboration with countries that have
endorsed PSI and are seeking assistance to increase their capacity to act
in accordance with the Statement of Interdiction Principles. These efforts
include workshops, training, conferences, and bilateral discussions with
foreign government officials. U.S. officials said they engage in bilateral
discussions, for example, to conclude PSI shipboarding agreements or to
seek ways to overcome obstacles to support for PSI principles. State
takes the lead in diplomatic outreach efforts.




6
 The 21 OEG countries are Argentina, Australia, Canada, Denmark, France, Germany,
Greece, Italy, Japan, the Netherlands, New Zealand, Norway, Poland, Portugal, Republic
of Korea, Russia, Singapore, Spain, Turkey, United Kingdom, and the United States.
According to State officials, the OEG is the steering committee for the initiative and
participants are generally best positioned to routinely contribute to and host PSI activities,
share best practices, and provide lessons learned on activities. OEG meetings provide an
essential coordination function and are a venue for nations to discuss counterproliferation
interdiction in a multinational setting.




Page 4                                             GAO-12-441 Proliferation Security Initiative
                           U.S. agencies have adopted interagency guidance documents that
Agencies Have              establish policies and procedures for all agencies participating in PSI
Adopted Policies and       activities. In addition, agencies have submitted annual reports, though
                           they lacked required estimated and actual expenditure information from
Procedures, but            most participating agencies.
Annual Reports Lack
Some Required
Information
Interagency PSI Policies   The 9/11 Act expresses Congress’ sense that DOD and State should
and Procedures             establish, among other things, clear policies and procedures and roles
Established                and responsibilities for PSI. 7 As we noted in our 2008 report, while DOD
                           and Customs and Border Protection (CBP) had established some policies
                           and procedures for their PSI activities, State and some law enforcement
                           agencies had not. 8 Since then, an interagency group, including
                           representatives from all agencies participating in PSI, produced two
                           companion guidance documents, Guidance for U.S. Government
                           Activities in Support of the Proliferation Security Initiative and Insuring the
                           Durability of PSI: An Action Plan, that the interagency group adopted in
                           2010 and 2011, respectively. 9 According to National Security Staff
                           officials, these documents are a primary source of policies and
                           procedures for all relevant agencies—defining PSI activities, providing
                           guidance on interagency communication, and addressing objectives and
                           responsibilities. 10 For example, they establish that State has primary
                           responsibility for diplomatic outreach activities and that DOD leads the
                           U.S. delegation at OEG meetings. 11 According to officials, such



                           7
                           Pub. L. 110-53, sec. 1821.
                           8
                            In our 2008 report, since PSI activities had been increasingly focused on law
                           enforcement issues, we recommended that some law enforcement agencies also
                           establish clear PSI policies and procedures. These agencies concurred with our
                           recommendation.
                           9
                            See appendix I for more information on GAO’s access to these interagency policy
                           documents.
                           10
                             While not otherwise directly involved in PSI activities, the National Security Staff
                           participates in interagency meetings and is the official custodian of these documents.
                           11
                             Within DOD, the Office of the Secretary of Defense for Policy is directly responsible for
                           this function.




                           Page 5                                            GAO-12-441 Proliferation Security Initiative
                           interagency policies and procedures also allow all U.S. agencies involved
                           in PSI to plan activities without duplicating efforts and to properly and
                           coherently articulate the U.S. government’s vision and strategy on PSI.

                           In addition to interagency guidance, DOD and CBP also have their own
                           PSI-specific policy documents. As we reported in our 2008 review of PSI,
                           DOD had PSI-specific policies and procedures in place, specifically those
                           encouraging combatant command participation in PSI exercises. 12 DOD
                           Joint Staff provided guidance directing combatant commands to leverage
                           the staff, assets, and resources of the existing DOD exercise program in
                           support of PSI exercises. This Joint Staff guidance provided procedures,
                           including roles and responsibilities, for the planning and execution of U.S.
                           military support to PSI. Among other things, the guidance encouraged
                           combatant commands to change existing DOD exercises by adding a PSI
                           component. Our 2008 review also reported that CBP, a component of
                           DHS, produced a PSI-specific directive that provides roles and
                           responsibilities, policies and procedures, and PSI-relevant definitions.
                           Approved in 2006, CBP is currently revising this document to reflect
                           updated roles and responsibilities.


Agencies Submitted         The 9/11 Act required DOD and State to submit to Congress in February
Reports, but They Lacked   an annual comprehensive joint report, beginning in 2008. 13 The report is
Some Required              to consist of a 3-year plan describing PSI-related activities and identifying
                           estimated expenditures for these activities, and a description of the PSI-
Information
                           related activities and associated expenditures carried out during the fiscal
                           year preceding the year of the report. 14 DOD and State co-author each
                           report, although responsibility for leading the annual effort alternates


                           12
                             Through DOD’s Joint Staff, we submitted questions to and received responses from the
                           following DOD combatant commands: U.S. Africa Command, U.S. Central Command,
                           U.S. European Command, U.S. Northern Command, U.S. Pacific Command, U.S.
                           Southern Command, and U.S. Strategic Command.
                           13
                             Pub. L. 110-53, sec. 1821(b). The 9/11 Act required that the 2008 report include a
                           description of PSI-related activities carried out during the 3 fiscal years preceding the year
                           of the report, and for the reports submitted in 2009 and each year thereafter, a description
                           of the PSI-related activities carried out during the fiscal year preceding the year of the
                           report. In November 2008, GAO reported that the relevant agencies had not submitted the
                           2008 report as required.
                           14
                             The 3-year plan in each report is to begin with the fiscal year for the current budget
                           request; for example, the 2011 report includes a 3-year plan covering fiscal years 2012 to
                           2014.




                           Page 6                                            GAO-12-441 Proliferation Security Initiative
between the two. The lead agency solicits input from all U.S. agencies
participating in PSI and consolidates the information provided to produce
the final report for submission to Congress. State and DOD have
submitted annual PSI reports in 2009, 2010, and 2011 including
descriptions of PSI activities, but these reports do not include all required
estimated expenditures for PSI activities over the next 3 fiscal years and
the amount expended in the prior year. 15

DOD is the only agency performing PSI activities that has provided all
required planned and prior year expenditure information for these reports.
For example, the 2011 report includes information from DOD stating that
it plans to conduct a regional PSI exercise called Leading Edge in Central
Asia in fiscal year 2012 and in the Middle East in fiscal year 2014 and that
each exercise is estimated to cost $600,000 for staff travel to support
planning events and exercise execution. Table 1 shows annual planned
expenditures from that report for PSI-related exercises in fiscal years
2012 to 2014 for DOD combatant commands and Joint Staff only,
including many of the major PSI-related activities expected in that period.
The report indicates that these expenditures include travel expenses,
conference hosting fees, contracting support, training expenses, and
other uniquely PSI-attributable expenses and lists all agencies consulted
in the preparation of the report. 16




15
 According to DOD officials, all three reports were submitted to Congress after the
February deadline due to interagency coordination issues. For example, the 2011 report
was submitted about 6 months late, in September 2011.
16
  The 2011 report states that the following U.S. departments and agencies were consulted
in the preparation of the report: DOD, including the Office of the Secretary of Defense, the
Joint Staff, and pertinent combatant commands; State; DHS, including CBP, U.S. Coast
Guard, and Immigration and Customs Enforcement; the Department of the Treasury; the
Department of Energy, including the National Nuclear Security Administration; DOJ,
including the Federal Bureau of Investigation; the Department of Commerce; and the
intelligence community.




Page 7                                           GAO-12-441 Proliferation Security Initiative
Table 1: Annual Estimated Expenditures for Department of Defense Support to PSI-Related Exercises and Other Events,
Fiscal Years 2012-2014

Expenditures rounded to nearest thousands
                                                                                                                                   Total estimated
Fiscal year              Anticipated activities                                                                                      expenditures
2012                     •   Approximately 1 Operational Experts Group (OEG) meeting                                                     $1,063,000
                         •   Approximately 3 regional OEG meetings
                         •   U.S. Central Command (CENTCOM) - 1 regional exercise
                         •   U.S. Pacific Command (PACOM) - 1 regional exercise
                         •   U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise
                         •   U.S. European Command (EUCOM) - unspecified
                         •   U.S. Africa Command (AFRICOM) - 2 PSI scenarios in 2 exercises
2013                     •   Approximately 1 OEG meeting                                                                                 $1,123,000
                         •   Approximately 3 regional OEG meetings
                         •   U.S. Pacific Command (PACOM) - 1 regional exercise
                         •   U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise
                         •   U.S. European Command (EUCOM) - unspecified
                         •   U.S. Africa Command (AFRICOM) - 1 PSI scenario in 1 exercise
2014                     •   Approximately 1 OEG meeting                                                                                   $973,000
                         •   Approximately 3 regional OEG meetings
                         •   U.S. Central Command (CENTCOM) - 1 regional exercise
                         •   U.S. Pacific Command (PACOM) - 1 regional exercise
                         •   U.S. Southern Command (SOUTHCOM) – 1 PSI scenario in 1 exercise
                         •   U.S. European Command (EUCOM) - unspecified
                         •   U.S. Africa Command (AFRICOM) - 1 PSI scenario in 1 exercise
                                        Source: GAO analysis of the 2011 PSI annual report to Congress.


                                        Note: Amounts above represent estimated expenditures for DOD’s combatant command and Joint
                                        Staff support. They reflect minimum anticipated annual expenditures and do not account for unknown
                                        funding requirements resulting from future exercises and other activities hosted by PSI partner
                                        nations.

                                        In addition, DOD has fully reported its prior year expenditures and, in
                                        many cases, includes expenditure amounts by activity. For example, the
                                        2011 report states that DOD’s total PSI expenditures for that year were
                                        approximately $519,000. Further, the report includes activity-specific
                                        expenditure information, such as the $31,400 DOD spent for training aids
                                        and staff travel in support of the Phoenix Express PSI exercise. 17


                                        17
                                          DOD amounts do not include expenditures for pay and salaries, ship fuel, other
                                        operating costs of military assets, or general overhead costs related to the offices and
                                        departments whose personnel participate in PSI activities.




                                        Page 8                                                            GAO-12-441 Proliferation Security Initiative
The annual reports do not uniformly include expenditure data for any
other agencies participating in PSI. For example, the 2010 report states
that the United States hosted an OEG meeting in Miami, Florida, for
which the United States had a delegation of 34 representatives from
DOD, State, DHS, the Federal Bureau of Investigation (FBI), the
Department of the Treasury (Treasury), and the Department of Energy
(DOE), among others. The report states that DOD contributed about
$145,000 but does not include expenditure data from other agencies for
the event. Table 2 shows the extent to which PSI annual reports include
expenditure information for U.S. agencies participating in PSI activities.

Table 2: Prior Year Expenditure Data Included in Annual Reports to Congress
                                                                      a                          a
                                   2009 report            2010 report              2011 report
    DOD                            Yes                    Yes                      Yes
    State                          Partial                No                       No
                                                               b
    DHS                            No                     No                       No
    DOJ (FBI)                      No                     Partial                  No
    DOE                            Yes                    Yes                      No
    Treasury                       Yes                    No                       No
                                                                                         c
    Commerce                       Yes                    No                       ——
Source: GAO analysis of PSI annual reports to Congress.

a
 The 2010 and 2011 reports state that all unreported expenditure amounts in fiscal years 2009 and
2010 were for PSI-related travel.
b
 DHS provided its PSI expenditures to State for the 2010 report; however, these data were not
included in the report.
c
 There is no indication in the report that Commerce participated in PSI activities this year.

Although reports contain some expenditure data from agencies other than
DOD, none of the other agencies provide this data for all of the annual
reports. For example, for fiscal years 2008 and 2009, DOE reported total
PSI expenditures of $69,000 and $55,000 respectively. Also, FBI reported
that it spent a total of about $750,000 to organize and sponsor PSI events
in Hungary and Australia in fiscal year 2009. However, no expenditure
data were provided for activities in which DOE participated for fiscal year
2010 and for FBI’s activities in fiscal years 2008 and 2010. From DHS,
CBP officials could document submitting PSI-specific expenditures of
about $35,000 for the 2010 report; however, the report did not include this




Page 9                                                     GAO-12-441 Proliferation Security Initiative
information, stating that the only costs DHS incurred were associated with
travel to PSI events. 18 According to State officials, State does not identify
and track its PSI-related expenditures because it made the decision that
such a breakout is unnecessary. However, officials said they could
calculate State’s total PSI-related expenditures because these are almost
entirely for travel to OEG meetings or bilateral negotiations. FBI officials
also reported that they do not separately track PSI expenditures.

Of the four agencies we spoke with, only DOD makes a specific budget
request for PSI-related activities. U.S. Strategic Command has a fiscal
year 2011 budget of $800,000 to provide financial assistance for
combatant commanders to plan, participate in, and execute WMD
interdiction exercises. This fund is used routinely but not exclusively to
support PSI activities such as hosting a PSI exercise, embedding PSI
scenarios into broader military exercises, ensuring that appropriate
subject matter experts can participate in PSI exercises, or purchasing
interdiction-related training aids. According to State officials, they prefer
funding PSI expenditures from their general operating accounts because
this practice allows them greater flexibility and the ability to fund PSI-
related travel when the need arises. FBI and CBP officials also reported
that they provide PSI funding when necessary through more general
operating accounts. 19

Agencies that do not track and report their expenditures are not providing
Congress sufficient information for Congress to assess U.S. participation
in PSI. If agencies are unable to provide requested assistance, but are
not tracking or reporting on expenditures, it is difficult for the agencies to
determine and demonstrate to Congress whether they are effectively
prioritizing their use of limited resources. For example, FBI officials stated
they could not provide PSI-related training requested in 2011 by
Colombian national police because they did not have sufficient funding. 20



18
  CBP officials also provided documentation of having submitted PSI-specific expenditure
data for inclusion in the 2012 report.
19
  FBI draws funding for its PSI-related expenditures from its External Policy and Planning
Unit budget. CBP draws funding for its PSI-related expenditures from its Security
Initiatives budget.
20
  In this case, FBI officials were able to use the PSI network to put the Colombian officials
in contact with officials from Spain’s law enforcement community who already scheduled
relevant training for Latin American countries.




Page 10                                           GAO-12-441 Proliferation Security Initiative
                               Moreover, the lack of required expenditure information limits Congress’
                               ability to oversee agencies’ commitment to the PSI objective.


                               DOD, State, CBP, and FBI officials participated in a range of PSI activities
Extent to Which                since 2008 to meet their objective of expanding and enhancing
Activities Meet PSI            counterproliferation efforts, but it is unclear to what extent these activities
                               have achieved the objective because agencies lack measures of results.
Objective Is Unclear           The agencies either led or participated in 22 PSI activities from fiscal year
because Agencies               2009 through fiscal year 2011, including multilateral meetings and
Lack Measures of               exercises. In addition, they have extended access to PSI activities to
                               more countries that are not part of the 21-country OEG. Despite
Results                        recommendations in the 9/11 Act and by GAO that agencies develop PSI
                               performance indicators, DOD, State, CBP, and FBI have not developed
                               indicators that can be used to systematically measure progress toward
                               the stated PSI objective. 21 Further, the agencies have not systematically
                               evaluated PSI activity results. Although some officials indicated plans to
                               develop PSI performance indicators, officials from DOD and State also
                               cited several challenges to developing indicators to measure PSI
                               activities’ results, including difficulty quantifying how PSI activities
                               improved capacity. However, GAO has previously reported that, despite
                               challenges, evaluating results and developing measures are possible.
                               One approach PSI agency officials could consider is developing a
                               framework to link performance measures, such as number of participants
                               trained, to outcomes, such as changes in national policies that strengthen
                               their authority to perform interdictions.


U.S. Agencies Participated     PSI’s objective is to enhance and expand our capacity to prevent the flow
in PSI Activities to Support   of WMD, their delivery systems, and related materials on the ground, in
PSI’s Objective                the air, and at sea, to and from states and nonstate actors of proliferation
                               concern. Agency officials provided us with a range of PSI activities they
                               have participated in since our 2008 report to support the PSI objective.
                               U.S. agencies led or participated in 22 PSI activities from fiscal year 2009
                               through fiscal year 2011 and State officials reported numerous informal
                               bilateral consultations designed to provide tools that increase countries’


                               21
                                 In our 2008 report, we specifically recommended that relevant law enforcement
                               agencies work toward developing performance indicators because of the increasing focus
                               of PSI activities on law enforcement issues. DHS and FBI concurred with this
                               recommendation.




                               Page 11                                       GAO-12-441 Proliferation Security Initiative
capacity to interdict illicit shipments of WMDs and WMD-related materials.
As table 3 shows, these activities fall under the three broad categories of
the U.S. government’s PSI efforts: multilateral OEG meetings, PSI
exercises, and other activities such as workshops and training sessions.
See appendix III for a summary of each of the PSI activities with U.S.
participation from fiscal year 2009 to December 2011. For example, the
U.S. Naval Forces Africa hosted an exercise in May 2010 that included a
PSI maritime interdiction scenario designed to improve regional
cooperation and maritime security in the Mediterranean basin. Also, a
U.S. delegation participated in an Australia-hosted exercise in September
2010 that focused on an aircraft counterproliferation scenario and
associated customs and law enforcement authorities and challenges. A
regional PSI planning meeting was held in conjunction with the exercise.

Table 3: Number and Type of PSI Activities with U.S. Participation, Fiscal Years
2009-2011

    Activity type                                     FY 2009             FY 2010      FY 2011
    Multilateral meeting                                      2                0              1
    Exercise                                                  3                3              4
                   a
    Other activity                                            1                0              1
    Multilateral meeting and other activity                   2                0              1
    Exercise and other activity                               0                0              3
    Multilateral meeting and exercise                         0                1              0
    Total                                                     8                4             10
Source: GAO analysis of DOD and State data.

a
Other activities include, for example, workshops and training sessions.

Officials from DOD, State, DHS, and FBI stated that their outreach efforts,
including State’s diplomatic efforts, have contributed to an increased
number of countries supporting PSI since our 2008 report. For example,
the number of countries that became PSI countries by endorsing the
Statement of Interdiction Principles has increased from 93 to 98 since
2008 and DOD officials said that they have ongoing efforts with several
non-endorsing countries and believe that the number of endorsing
countries will continue to rise. The most recent endorsees are Antigua
and Barbuda, Colombia, the Republic of Korea (South Korea), St. Vincent
and the Grenadines, and Vanuatu. Further, the number of signed bilateral
shipboarding agreements between the United States and individual PSI




Page 12                                               GAO-12-441 Proliferation Security Initiative
countries increased between November 2008 and February 2012 from 9
to 11. 22 Bilateral shipboarding agreements put procedures into place and
identify points of contact to permit the timely inspection by either party of
vessels flying their flags suspected of transporting proliferation-related
cargo. State officials said these agreements are significant because they
have been signed by countries with some of the largest ship registries. 23

U.S. agencies, in cooperation with the 20 other OEG countries, also have
extended access to PSI activities to additional countries since our last
report. In 2008, we reported that U.S. agencies had not built relationships
with PSI countries that are not OEG countries by involving them in PSI
planning and activities. We recommended that U.S. agencies work in
conjunction with other leading PSI countries to increase cooperation,
coordination, and information exchange with PSI countries that were not
invited to multilateral OEG planning meetings. 24 In May 2009, the
countries of the OEG committed to consider ways to involve more
countries in future PSI planning meetings. According to U.S. officials, they
also agreed to increase the number of PSI activities, including regional
PSI planning meetings, that include PSI-endorsing countries beyond the
OEG countries and, in some cases, non-endorsing countries. In addition,
the 2011 U.S. interagency PSI report to Congress stated that activities
planned for fiscal years 2012 through 2014 are designed to increase
cooperation, coordination, and information exchange with the broad range
of PSI-endorsing countries beyond the countries that normally participate
in the OEG.

U.S. officials provided examples of expanded efforts to cooperate with
non-OEG countries. For example:



22
  In addition to the shipboarding agreements signed in 2010 with Antigua and Barbuda
and St. Vincent and the Grenadines, the United States also has agreements with The
Bahamas, Belize, Croatia, Cyprus, Liberia, Malta, Marshall Islands, Mongolia, and
Panama.
23
  A country’s ship registry includes vessels that sail bearing the flag of that country. Many
of the countries with the largest ship registries have open registries, meaning they engage
in the business practice allowing ships to be registered with their country and fly their flag
even when the ship owners are from another country. The ability to interdict a shipment
depends, in part, on the legal authorities of the country whose flag a ship is flying and
vulnerabilities in legal codes may be exploited by merchants shipping WMD or WMD-
related materials.
24
  GAO-09-43.




Page 13                                           GAO-12-441 Proliferation Security Initiative
                           •    Eight of the 17 participating delegations at a PSI activity hosted in
                                September 2010 by Australia represented countries not normally
                                invited to multilateral PSI planning meetings. The activity included an
                                aircraft counterproliferation scenario exercise and a regional PSI
                                planning meeting.

                           •    According to U.S. officials, the Republic of Korea endorsed PSI in
                                May 2009 as a result of its participation in PSI activities and became
                                one of the 21 leading PSI countries in November 2010. It organized a
                                PSI exercise and hosted a regional PSI workshop in 2010.

                           U.S. officials said they are also currently developing the Critical
                           Capabilities and Practices effort, a clearinghouse for PSI-related
                           information and tools, designed to make PSI lessons learned and best
                           practices available both to PSI activity participants and to endorsing
                           countries that were unable to participate in the activities. 25 The OEG
                           countries discussed and confirmed support for the development of the
                           Critical Capabilities and Practices effort. Officials said they have not set a
                           target date for the effort to begin making PSI-related information and tools
                           available.


U.S. Agencies Have Not     While U.S. agencies have undertaken a range of PSI efforts since 2008,
Established a Framework    they have not established a framework to measure PSI activities’ results
to Measure PSI’s Results   and, therefore, it is unclear to what extent these activities have enhanced
                           and expanded capacity to prevent the flow of WMD, their delivery
                           systems, and related materials on the ground, in the air, and at sea, to
                           and from states and nonstate actors of proliferation concern. The 9/11 Act
                           recommended that DOD and State establish indicators to measure results
                           of their PSI activities. It is the responsibility of the implementing agencies
                           to measure the results of PSI activities. Linking the activities to the
                           initiative’s overall objective could help the agencies better organize and
                           prioritize future activities. In 2008, we reported that agencies had not
                           established PSI performance indicators. We also recommended that law
                           enforcement agencies, such as DHS and FBI, which we found to have
                           become increasingly involved in PSI activities, establish PSI performance
                           indicators and they concurred.



                           25
                             Officials report that the Critical Capabilities and Practices effort will include
                           documentation of past activities and notice of future activities.




                           Page 14                                              GAO-12-441 Proliferation Security Initiative
The four agencies we reviewed have not established formal performance
indicators that can be used to systematically measure progress toward
the stated PSI objective. DOD officials said they have general
counterproliferation goals but have not developed PSI indicators. 26 FBI
officials said that they have performance measures applying to activities
of their Weapons of Mass Destruction Directorate, and that their PSI-
specific goal is the commitment to participate in PSI activities as
appropriate, including at least one PSI exercise per year. Although FBI
officials consider this to be a performance indicator, participation alone
does not provide information to measure the results of PSI activities.
State has identified as its PSI indicator “An Effective Global Network
Countering WMD Proliferation-Related Trafficking.” 27 However, the
measures used to track the indicator’s progress change from year to year,
making it difficult for State to assess systematically the results of its PSI
activities. For example, although State did not meet its fiscal year 2009
target to have 100 PSI-endorsing countries, it did not set targets for the
number of PSI endorsees for fiscal years 2010 or 2011. We reported in
2008 that CBP developed a PSI Implementation Plan with expected goals
and targets, but that it had not been updated since June 2006. 28 As of
February 2012, CBP officials stated that many of the goals are outdated
and that the plan has not been updated because they wanted to wait and
align their plan with the interagency PSI policy documents that were
completed in 2010 and 2011. The officials acknowledged that
performance measurement is important and said they are working to
include indicators in their updated plan.

In addition, although some agencies have made efforts to assess
individual PSI activities, the four agencies we reviewed have not
performed a systematic evaluation of the results of PSI activities. Some
officials draft summary reports following individual activities to identify
issues to address in planning for future activities. For example, FBI



26
  Officials from DOD's U.S. Southern Command (USSOUTHCOM) reported that they
anticipate working with the U.S. Strategic Command Center for Combating Weapons of
Mass Destruction to develop performance indicators and evaluation criteria.
27
 State's indicator is part of the annual Bureau Strategic and Resource Plan for the
Bureau of International Security and Nonproliferation.
28
  CBP officials said they believe their Implementation Plan contained indicators. In our
2008 report, however, we found that although the plan contained expected goals and
targets, they were not performance indicators.




Page 15                                          GAO-12-441 Proliferation Security Initiative
                               officials said they conducted a formal evaluation of the two workshops
                               they sponsored in 2009. 29 The report from the September 2009 workshop
                               in Australia included some reporting of feedback from a written survey
                               conducted at the end of the activity. Similarly, a CBP official provided
                               examples of post-activity reports that include recommendations for future
                               PSI efforts. However, these reports do not represent a systematic
                               evaluation that links the activity results to the PSI objective. The officials
                               with whom we met said they consider past activities when planning for the
                               future, but they have no systematic evaluation of the activity results or
                               impact to aid their planning. Further, the annual PSI reports to Congress
                               do not generally document results of U.S. agencies’ activities beyond the
                               names of the participating countries.

Agency Officials Cited         State and DOD officials cited a number of challenges to developing
Challenges to Developing PSI   indicators to measure the impact or results of the U.S. government’s PSI
Performance Measures           activities. According to the officials, results that can be quantified can also
                               be misleading. For example, the officials stated the following:

                               •    Tracking the overall number of new countries endorsing PSI ignores
                                    the fact that U.S. agencies have strategic reasons for focusing efforts
                                    on a certain country or subset of countries, even if a larger number of
                                    other countries might be persuaded more quickly to endorse.

                               •    Tracking the number of interdictions does not necessarily link PSI
                                    activities to the initiative’s objective. According to the officials, the
                                    initiative’s activities are focused on building capacity to perform
                                    interdiction, but actual interdictions are not performed as part of PSI. 30
                                    They emphasized that they cannot credit successful interdictions to
                                    PSI activities, in part because there are many efforts in addition to PSI
                                    that are focused on counterproliferation. Also, a change in the number
                                    of interdictions over the previous year could be attributed to a range of
                                    positive and negative factors, including better capacity to interdict,
                                    increased transfers of illicit material, or failure to deter transfers.




                               29
                                 FBI officials could not locate documentation of the evaluation report from the FBI-
                               sponsored July 2009 workshop in Budapest, Hungary.
                               30
                                 Officials stated that although PSI complements and supports interdiction efforts, the act
                               of performing interdictions is beyond the scope of PSI.




                               Page 16                                          GAO-12-441 Proliferation Security Initiative
                              •    Tracking measures of U.S. efforts, such as the number of activities
                                   hosted by the United States, ignores the fact that PSI is a
                                   multinational effort.

                              Further, State officials said some of the results of PSI activities are
                              difficult to quantify. For example, although the officials said tools and
                              expertise provided to participants at activities are used by participants to
                              enhance their ability to interdict illicit cargo, the extent of the improvement
                              is often difficult to measure and track.

Performance Measurement       Despite the challenges U.S. agencies face in developing performance
Possible Despite Challenges   indicators, it is possible for agencies to measure performance. One
                              possible approach agencies could consider is to develop a framework
                              that links PSI activities to the initiative’s objective. GAO has previously
                              identified such frameworks, called logic models, that agencies could
                              adopt even if they face performance measurement challenges similar to
                              some of the ones identified by PSI implementing agencies. 31 Specifically,
                              GAO reported that using a logic model could allow the agencies to
                              consider indirect outcomes and unquantifiable benefits when linking
                              activities and outputs to the overall objective. By specifying the program’s
                              theory of what is expected, a logic model can help evaluators define
                              measures of the program’s progress toward its ultimate goals. In
                              particular, GAO found that logic models were used or could be used to
                              measure results in programs with challenges similar to some of PSI’s,
                              including, for example, difficulty in observing changes in behavior
                              occurring after activity completion and difficulty in attributing outcomes to
                              activities because of external factors’ influence on the outcomes. Figure 1
                              provides generic guidance on how a logic model framework could be
                              used to link agencies’ program inputs and outputs to outcomes or impact.
                              A logic model can help identify pertinent variables and how, when, and in
                              whom they should be measured, as well as other factors that might affect
                              program results.



                              31
                                A logic model is an evaluation tool used to describe a program’s—or initiative’s, in the
                              case of PSI—components and desired results and explain the strategy—or logic—by
                              which the program is expected to achieve its goals. See GAO, Program Evaluation:
                              Strategies for Assessing How Information Dissemination Contributes to Agency Goals,
                              GAO-02-923 (Washington, D.C.: Sept. 30, 2002). For another example of how a logic
                              model could be applied to a specific program or set of activities, see appendix IV in GAO,
                              Security Assistance: State and DOD Need to Assess How the Foreign Military Financing
                              Program for Egypt Achieves U.S. Foreign Policy and Security Goals, GAO-06-437
                              (Washington, D.C.: Apr. 11, 2006).




                              Page 17                                          GAO-12-441 Proliferation Security Initiative
Figure 1: Sample Logic Model




                               A logic model can be used by agencies to guide their efforts to link
                               activities to high-level objectives or impact, and agency officials could
                               adapt the general framework to the individual program they plan to
                               evaluate. For PSI, a logic model could link inputs and activities to
                               outcomes while also documenting the challenges in measuring results.
                               For example, officials could track quantitative inputs, such as the amount
                               of money spent on a training activity about overcoming gaps in legal
                               authority to interdict illicit shipments. They could link that input to
                               measurable outputs, such as the number of participants trained. To link
                               the outputs to short term results, they could make efforts to elicit feedback
                               from participants to measure changes in participants’ knowledge of ways
                               to strengthen legal authorities. Agencies may be able to identify medium
                               and long-term results, such as participants who successfully implement
                               new national policies that strengthen their authority to perform
                               interdictions. Together with the linkage of quantifiable measures,
                               agencies could include narrative explanation of unquantifiable results that
                               they believe contribute to the initiative’s objective. They could also



                               Page 18                                  GAO-12-441 Proliferation Security Initiative
              describe external factors that make it difficult to demonstrate or quantify
              the extent of the causal link between activities and results, such as the
              existence of other programs or initiatives that may also result in improved
              legal capacity to perform interdictions. Over time, the use of such a
              framework can help determine whether the results of the initiative’s
              activities match the expected outcomes.

              Federal agencies are increasingly expected to focus on achieving results
              and to demonstrate, in annual performance reports, how their activities
              help achieve agency or governmentwide goals. Because U.S. agencies
              have not developed indicators that can be used to measure
              systematically the results of their PSI activities, it is difficult for Congress
              and the public to know whether PSI activities hosted or participated in by
              the agencies are achieving their stated objective. As GAO has previously
              reported, in programs that inform and persuade others to act to achieve a
              desired outcome, it would seem all the more important to assure decision
              makers that this strategy is credible and likely to succeed. 32


              PSI has the potential to increase global capacity to recognize and
Conclusions   interdict the flow of WMD, their delivery systems, and related materials on
              the ground, air, or sea, to and from states and nonstate actors of
              proliferation concern. The previous and current administrations have
              committed to implementing PSI and President Obama has called for it to
              be turned into a durable international institution. Given this commitment, it
              is important that agencies ensure that PSI is fully implemented according
              to legislative recommendations and requirements. Since our 2008 report,
              U.S. agencies have developed interagency PSI policies and procedures
              that satisfy a recommendation of the 9/11 Act. They have also submitted
              annual reports covering fiscal years 2008 through 2010 documenting their
              PSI activities, but these reports have not included the associated funding
              information for all PSI implementing agencies, as required by law. While
              all agencies we spoke with except DOD stated that they fund their PSI
              activities from their general funds, rather than request an annual PSI
              budget, it does not eliminate the requirement that they provide
              expenditure information for their PSI activities under the 9/11 Act. Without
              reports that include the required information for all agencies’ PSI
              activities, Congress will not know how much the U.S. government is



              32
               GAO-02-923.




              Page 19                                    GAO-12-441 Proliferation Security Initiative
                      spending on PSI and how such funds are being allocated. Also, while
                      U.S. agencies have provided years of documentation of a range of
                      activities they have performed or plan to perform under PSI, they have
                      been unable to demonstrate if or how these activities are linked to the PSI
                      objective. Without performance indicators that can be used to
                      systematically measure progress toward the stated PSI objective and a
                      framework for measuring the results of PSI activities, Congress and the
                      public do not have a sufficient basis to judge whether PSI activities are
                      successful.


                      To ensure that Congress has information to assess U.S. participation in
Recommendations for   PSI, we recommend that the Secretaries of Defense and State take the
Executive Action      following two actions:

                      1. Include in the annual PSI report to Congress the required expenditure
                         information for all U.S. agencies participating in PSI activities; and

                      2. Develop a framework for measuring PSI activities’ results, including
                         performance measures where possible that help link the results to
                         PSI’s objective.


                      We provided a draft of this report to DOD, State, FBI, and DHS. DOD and
Agency Comments       State provided written comments on a draft of this report, which are
and Our Evaluation    reprinted in appendixes IV and V along with our responses to specific
                      points. FBI and DHS, along with DOD and State provided technical
                      comments that we have incorporated into this report, as appropriate.

                      In commenting on the draft report, DOD partially concurred with both of
                      our recommendations. Consistent with our recommendation, DOD agreed
                      that the annual PSI report should include expenditure information for all
                      U.S. agencies. DOD stated that the reports have included information on
                      expenditures by DOD and other agencies that are unique to PSI, while
                      excluding items that are accounted for in agency general operating
                      budgets. However, we found that some expenditure amounts not reported
                      in the annual reports were unique to PSI and, therefore, should have
                      been included. In a 2009 e-mail to CBP, a DOD official stated that travel
                      expenses could be included in its submission to the annual report, as long
                      as they were specifically for a PSI event. However, after CBP submitted
                      such expenditures to DOD, they were excluded from the 2010 annual
                      report even though they were for PSI-specific travel. DOD also partially
                      concurred with our recommendation to develop a results framework. The


                      Page 20                                 GAO-12-441 Proliferation Security Initiative
department cited challenges in establishing objective and quantifiable
measures of success but committed to make an effort to implement the
recommendation by using the Critical Capabilities and Practices (CCP)
concept as a results framework and to identify meaningful performance
measures, where appropriate.

State partially concurred with the recommendation to provide expenditure
information for all U.S. agencies participating in PSI activities. The
department explained that it is difficult to define some expenditures as
unique to PSI, for example, because travel in support of PSI events often
coincides with travel in support of other department operational activities.
However, the department said it would closely examine travel-related and
other expenses unique to PSI in order to include them in future reports to
Congress. State did not concur with our recommendation that it should
develop a results framework. State said it had some indicators, such as
the numbers of PSI-endorsing countries, for use in measuring PSI
progress, but cautioned that PSI does not lend itself to collective data that
would provide reasonable approximation of results. Nonetheless, State
cited the CCP effort as one tool it intends to use, in coordination with
other participating U.S. agencies, “which could contribute to an effective
future analysis of the outcomes of coordinated PSI activity,” which is
consistent with our recommendation. Although we made a written request
for documentation of State’s PSI performance indicators in July 2011,
State did not provide documentation of its PSI indicator and targets until
March 2012, after it provided its response to our draft report. We have
revised our report findings to include this documentation and our
assessment. Upon reviewing the documentation provided, we found that
the metrics State identified were not consistently listed as annual metrics
in the strategic plan to which they refer. For example, neither the number
of endorsing states nor the conclusion of shipboarding agreements were
listed as metrics for fiscal years 2010 or 2011. In addition, State set no
numeric targets for its participation in PSI activities for fiscal years 2010
or 2011. Without an overall results framework including, where possible,
consistent indicators and targets that can be tracked over time, State
cannot systematically evaluate its PSI activities.


We are sending copies of this report to the appropriate congressional
committees, the Secretary of Defense, the Secretary of State, the
Secretary of Homeland Security, the Attorney General, and other
interested parties. In addition, this report is available at no charge on the
GAO website at http://www.gao.gov.



Page 21                                   GAO-12-441 Proliferation Security Initiative
If you or your staff members have any questions about this report, please
contact me at (202) 512-9601 or melitot@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors are listed in appendix VI.




Thomas Melito
Director, International Affairs and Trade




Page 22                                     GAO-12-441 Proliferation Security Initiative
List of Committees

The Honorable Carl Levin
Chairman
The Honorable John McCain
Ranking Member
Committee on Armed Services
United States Senate

The Honorable John Kerry
Chairman
The Honorable Richard G. Lugar
Ranking Member
Committee on Foreign Relations
United States Senate

The Honorable Howard P. McKeon
Chairman
The Honorable Adam Smith
Ranking Member
Committee on Armed Services
House of Representatives

The Honorable Ileana Ros-Lehtinen
Chairman
The Honorable Howard L. Berman
Ranking Member
Committee on Foreign Affairs
House of Representatives




Page 23                             GAO-12-441 Proliferation Security Initiative
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             To assess the progress agencies have made since 2008 in establishing
             recommended Proliferation Security Initiative (PSI) policies and
             procedures, and issuing required annual reports, we reviewed the
             findings and recommendations in GAO’s 2006 and 2008 reports on PSI
             and the Implementing Recommendations of the 9/11 Commission Act of
             2007 (the 9/11 Act). 1 We requested and reviewed documentation of
             policies and procedures developed since 2008. Because the National
             Security Staff is the custodian of the interagency policy documents, we
             discussed the contents of those documents with National Security Staff
             officials and reviewed the documents to confirm that they contained PSI
             policies and procedures. We also reviewed PSI annual reports submitted
             to Congress by the Departments of State (State) and Defense (DOD) and
             analyzed them for compliance with the requirements in the 9/11 Act. We
             reported expenditure data as they appeared in the annual reports to
             Congress and discussed the reliability of the data with agency officials.
             We determined the data were sufficiently reliable for the purposes of our
             report. Further, we interviewed relevant agency officials to better
             understand the extent to which they implemented the requirements and
             recommendations in the 9/11 Act and any compliance challenges they
             faced.

             To assess the extent to which PSI activities have enhanced and
             expanded U.S. efforts to prevent the flow of weapons of mass destruction
             (WMD) materials, we reviewed and analyzed documents from DOD,
             State, the Department of Homeland Security (DHS), and the Department
             of Justice (DOJ). We analyzed the information on each PSI activity in the
             annual reports covering fiscal years 2009 and 2010. We reported the
             number of PSI activities with U.S. participation based on agency
             documents. Because the agencies have not yet submitted the annual
             report for PSI activities in fiscal year 2011, we analyzed information on
             fiscal year 2011 activities provided by agency officials. We also
             interviewed relevant agency officials and solicited responses from seven
             DOD combatant commands to a list of questions about the PSI. In
             particular, we requested and analyzed documentation of actions relevant
             agencies have taken, if any, to develop indicators of PSI’s success. In
             addition, we compared our findings with those of the 2008 GAO PSI
             review and reviewed GAO reports assessing agencies’ evaluation
             frameworks and performance measurement.



             1
              Pub. L. 110-53, sec. 1821.




             Page 24                                GAO-12-441 Proliferation Security Initiative
Appendix I: Scope and Methodology




For both objectives, we focused on DOD and State because the
applicable recommendations and requirements in the mandate were
addressed to them. In addition, we assessed DHS and DOJ progress
because GAO made recommendations to those agencies in 2008 to
develop policies, procedures, and performance indicators because of the
increased involvement of law enforcement agencies in U.S. PSI efforts.




Page 25                               GAO-12-441 Proliferation Security Initiative
Appendix II: Full Text of the Statement of
                              Appendix II: Full Text of the Statement of
                              Interdiction Principles



Interdiction Principles

                              The PSI is a response to the growing challenges posed by the
                              proliferation of WMD, their delivery systems, and related materials
                              worldwide. The PSI builds on efforts by the international community to
                              prevent proliferation of such items, including existing treaties and
                              regimes. It is consistent with, and a step in the implementation of the UN
                              Security Council Presidential Statement of January 1992, which states
                              that the proliferation of all WMD constitutes a threat to international peace
                              and security, and underlines the need for member states of the UN to
                              prevent proliferation. The PSI is also consistent with recent statements of
                              the G8 and the European Union, establishing that more coherent and
                              concerted efforts are needed to prevent the proliferation of WMD, their
                              delivery systems, and related materials. PSI participants are deeply
                              concerned about this threat and of the danger that these items could fall
                              into the hands of terrorists and are committed to working together to stop
                              the flow of these items to and from states and nonstate actors of
                              proliferation concern.

                              The PSI seeks to involve, in some capacity, all states that have a stake in
                              nonproliferation and the ability and willingness to take steps to stop the
                              flow of such items at sea, in the air, or on land. The PSI also seeks
                              cooperation from any state whose vessels, flags, ports, territorial waters,
                              airspace, or land might be used for proliferation purposes by states and
                              nonstate actors of proliferation concern. The increasingly aggressive
                              efforts by proliferators to stand outside or to circumvent existing
                              nonproliferation norms, and to profit from such trade, requires new and
                              stronger actions by the international community. We look forward to
                              working with all concerned states on measures they are able and willing
                              to take in support of the PSI, as outlined in the following set of
                              “Interdiction Principles.”


Interdiction Principles for   PSI participants are committed to the following interdiction principles to
the Proliferation Security    establish a more coordinated and effective basis through which to impede
Initiative                    and stop shipments of WMD, delivery systems, and related materials
                              flowing to and from states and nonstate actors of proliferation concern,
                              consistent with national legal authorities and relevant international law
                              and frameworks, including the UN Security Council. They call on all states
                              concerned with this threat to international peace and security to join in
                              similarly committing to:

                              1. Undertake effective measures, either alone or in concert with other
                                 states, for interdicting the transfer or transport of WMD, their delivery
                                 systems, and related materials to and from states and nonstate actors


                              Page 26                                      GAO-12-441 Proliferation Security Initiative
Appendix II: Full Text of the Statement of
Interdiction Principles




    of proliferation concern. “States or nonstate actors of proliferation
    concern” generally refers to those countries or entities that the PSI
    participants involved establish should be subject to interdiction
    activities because they are engaged in proliferation through: (1) efforts
    to develop or acquire chemical, biological, or nuclear weapons and
    associated delivery systems; or (2) transfers (either selling, receiving,
    or facilitating) of WMD, their delivery systems, or related materials.

2. Adopt streamlined procedures for rapid exchange of relevant
   information concerning suspected proliferation activity, protecting the
   confidential character of classified information provided by other
   states as part of this initiative, dedicate appropriate resources and
   efforts to interdiction operations and capabilities, and maximize
   coordination among participants in interdiction efforts.

3. Review and work to strengthen their relevant national legal authorities
   where necessary to accomplish these objectives, and work to
   strengthen when necessary relevant international law and frameworks
   in appropriate ways to support these commitments.

4. Take specific actions in support of interdiction efforts regarding
   cargoes of WMD, their delivery systems, or related materials, to the
   extent their national legal authorities permit and consistent with their
   obligations under international law and frameworks, to include:

    a. Not to transport or assist in the transport of any such cargoes to or
       from states or nonstate actors of proliferation concern and not to
       allow any persons subject to their jurisdiction to do so.

    b. At their own initiative, or at the request and good cause shown by
       another state, to take action to board and search any vessel flying
       their flag in their internal waters or territorial seas, or areas beyond
       the territorial seas of any other state, that is reasonably suspected
       of transporting such cargoes to or from states or nonstate actors
       of proliferation concern, and to seize such cargoes that are
       identified.

    c. To seriously consider providing consent under the appropriate
       circumstances to the boarding and searching of its own flag
       vessels by other states, and to the seizure of such WMD-related
       cargoes in such vessels that may be identified by such states.

    d. To take appropriate actions to (1) stop and/or search in their
       internal waters, territorial seas, or contiguous zones (when


Page 27                                      GAO-12-441 Proliferation Security Initiative
Appendix II: Full Text of the Statement of
Interdiction Principles




          declared) vessels that are reasonably suspected of carrying such
          cargoes to or from states or nonstate actors of proliferation
          concern and to seize such cargoes that are identified and (2) to
          enforce conditions on vessels entering or leaving their ports,
          internal waters, or territorial seas that are reasonably suspected of
          carrying such cargoes, such as requiring that such vessels be
          subject to boarding, search, and seizure of such cargoes prior to
          entry.

    e. At their own initiative or upon the request and good cause shown
       by another state, to (a) require aircraft that are reasonably
       suspected of carrying such cargoes to or from states or nonstate
       actors of proliferation concern and that are transiting their airspace
       to land for inspection and seize any such cargoes that are
       identified and/or (b) deny aircraft reasonably suspected of carrying
       such cargoes transit rights through their airspace in advance of
       such flights.

    f.    If their ports, airfields, or other facilities are used as transshipment
          points for shipment of such cargoes to or from states or nonstate
          actors of proliferation concern, to inspect vessels, aircraft, or other
          modes of transport reasonably suspected of carrying such
          cargoes, and to seize such cargoes that are identified.




Page 28                                      GAO-12-441 Proliferation Security Initiative
Appendix III: Proliferation Security Initiative
                                     Appendix III: Proliferation Security Initiative
                                     Activities from Fiscal Year 2009 to December
                                     2011


Activities from Fiscal Year 2009 to December
2011

Month              Year   Type of activity     Event                       Description                      Location
Fiscal year 2012
November           2011   meeting              OEG                         Operational Experts Group        Germany
                                                                           (OEG) meeting
November           2011   exercise             Vigilant Shield             PSI portion of tabletop          Norfolk, VA
                                                                           exercise
Fiscal year 2011
September          2011   other                Bilateral activity          Bilateral activity with          Colombia
                                                                           Colombia
August             2011   exercise             Panamax                     PSI portion of live maritime     Panama
                                                                           exercise and tabletop
                                                                           exercise
June               2011   meeting and other Regional OEG                   Regional OEG meeting and         Honolulu, HI
                                                                           Critical Capabilities and
                                                                           Practices workshop
May                2011   exercise             Phoenix Express             PSI portion of live maritime     Mediterranean Sea
                                                                           exercise
April              2011   exercise             Austere Challenge           PSI portion of live maritime     Germany
                                                                           exercise
April              2011   exercise             Saharan Express             PSI portion of live maritime     Cape Verde/Senegal
                                                                           exercise
April              2011   exercise and other Bilateral activity            PSI tabletop exercise and        St. Vincent and the
                                                                           workshop with St. Vincent        Grenadines
                                                                           and the Grenadines
February           2011   exercise and other Bilateral activity            PSI tabletop exercise and        Mongolia
                                                                           workshop with Mongolia
November           2010   meeting              OEG                         OEG meeting                      Japan
October            2010   exercise and other Eastern Endeavor              PSI portion of live maritime     Republic of Korea
                                                                           exercise and tabletop
                                                                           exercise; PSI workshop
Fiscal year 2010
September          2010   meeting and          Regional OEG / Pacific      Regional OEG meeting and         Australia
                          exercise             Protector                   PSI portion of port exercise
May/June           2010   exercise             Phoenix Express             PSI portion of live maritime     Mediterranean Sea
                                                                           exercise
January            2010   exercise             Leading Edge                PSI portion of live maritime     United Arab Emirates
                                                                           exercise, port exercise, and
                                                                           tabletop exercise
October            2009   exercise             Deep Sabre                  PSI portion of live maritime     Singapore
                                                                           exercise, port exercise, and
                                                                           tabletop exercise




                                     Page 29                                              GAO-12-441 Proliferation Security Initiative
                                     Appendix III: Proliferation Security Initiative
                                     Activities from Fiscal Year 2009 to December
                                     2011




Month              Year   Type of activity      Event                               Description                     Location
Fiscal year 2009
September          2009   exercise              Panamax                             PSI portion of live maritime    Panama
                                                                                    exercise and tabletop
                                                                                    exercise
September          2009   meeting and other Regional OEG and                        Regional OEG meeting and    Australia
                                            counterproliferation                    3-day workshop organized by
                                            workshop                                FBI and Australia for PSI
                                                                                    endorsing countries in Asia
                                                                                    Pacific region
July               2009   other                 Bilateral workshop                  2-day workshop with Republic Republic of Korea
                                                                                    of Korea
July               2009   meeting and           Regional OEG and                    Regional OEG meeting and     Hungary
                          other                 counterproliferation                3-day workshop organized by
                                                workshop                            FBI and Hungary for PSI
                                                                                    endorsing countries in the
                                                                                    Middle East and North Africa
                                                                                    region
June               2009   meeting               Regional OEG                        Regional OEG meeting            Poland
May                2009   meeting               OEG                                 OEG meeting                     Miami, FL
April              2009   exercise              Bilateral exercise                  Bilateral tabletop exercise     Israel
                                                                                    with Israel
April/May          2009   exercise              Phoenix Express                     PSI portion of live maritime    Mediterranean Sea
                                                                                    exercise
                                     Source- GAO analysis based on DOD and State data.




                                     Page 30                                                      GAO-12-441 Proliferation Security Initiative
Appendix IV: Comments from the
                            Appendix IV: Comments from the Department
                            of State



Department of State


Note: GAO comments
supplementing those in
the report text appear at
the end of this
appendix.




                            Page 31                                     GAO-12-441 Proliferation Security Initiative
                 Appendix IV: Comments from the Department
                 of State




See comment 1.




                 Page 32                                     GAO-12-441 Proliferation Security Initiative
                 Appendix IV: Comments from the Department
                 of State




See comment 2.




See comment 3.




                 Page 33                                     GAO-12-441 Proliferation Security Initiative
                 Appendix IV: Comments from the Department
                 of State




See comment 4.




See comment 5.




                 Page 34                                     GAO-12-441 Proliferation Security Initiative
               Appendix IV: Comments from the Department
               of State




               The following are GAO’s comments on the Department of State’s letter,
               dated March 9, 2012.


               1. Our recommendation focuses on developing a framework that links
GAO Comments      PSI activities to the initiative’s objective, and not just on indicators,
                  which alone do not link the activities to the desired outcomes.
                  Although we made a written request for documentation of State’s PSI
                  performance indicators in July 2011, State did not provide
                  documentation of its PSI indicator and targets until March 2012, after
                  it provided its response to our draft report. We have revised our report
                  findings to include this documentation and our assessment. Upon
                  reviewing the documentation provided, we found that the metrics
                  State identified were not consistently listed in its bureau strategic plan
                  as annual metrics. For example, neither the number of endorsing
                  states nor the conclusion of shipboarding agreements were listed as
                  metrics for fiscal years 2010 and 2011. In addition, State set no
                  numeric targets for its participation in PSI activities for fiscal years
                  2010 and 2011. Without an overall results framework including, where
                  possible, consistent indicators and targets that can be tracked over
                  time, State cannot systematically evaluate its PSI activities.

               2. State’s decision to consider including PSI-specific expenditures in
                  future reports to Congress is consistent with our recommendation.

               3. If the Critical Capabilities and Practices (CCP) concept is developed
                  as a framework that links PSI activities to outcomes and the objective
                  of PSI, it will be consistent with our recommendation. (See also
                  comment 1.)

               4. Based on State’s response, we have revised the report to reflect
                  State’s justification for not breaking out PSI expenditures. However,
                  State’s decision not to track PSI expenditures is inconsistent with the
                  requirement to report such information annually.

               5. The description of OEG meetings as planning meetings is consistent
                  with our 2008 report on PSI. State concurred with this decision. In
                  addition, we believe that the activities currently listed by State are
                  consistent with PSI planning. We have added a footnote in the
                  background more fully explaining OEG meetings.




               Page 35                                     GAO-12-441 Proliferation Security Initiative
Appendix V: Comments from the Department
                         Appendix V: Comments from the Department
                         of Defense



of Defense

Note: GAO comments
supplementing those in
the report text appear
at the end of this
appendix.




                         Page 36                                    GAO-12-441 Proliferation Security Initiative
                 Appendix V: Comments from the Department
                 of Defense




See comment 1.




See comment 2.




                 Page 37                                    GAO-12-441 Proliferation Security Initiative
                 Appendix V: Comments from the Department
                 of Defense




                 The following are GAO’s comments on the Department of Defense’s
                 letter, dated March 9, 2012.


                 1. The 9/11 Act requires that DOD, in conjunction with State, report to
GAO’s Comments      Congress annually on the amount expended for the prior year’s PSI
                    activities. Because DOD is the only agency we spoke with that makes
                    a specific budget request for PSI-related activities, its decision not to
                    report expenditure amounts accounted for in agency general
                    operating budgets limits Congress’ knowledge of the amount the U.S.
                    government is spending on PSI and how those funds are being
                    allocated. In addition, we found that some expenditure amounts not
                    included in the annual reports were unique to PSI and, therefore,
                    should have been included. In a 2009 email to CBP, a DOD official
                    stated that travel expenses could be included in its submission to the
                    annual report, as long as they were specifically for a PSI event.
                    However, after CBP submitted such expenditures to DOD, they were
                    excluded from the 2010 annual report even though they were for PSI-
                    specific travel.

                 2. DOD’s willingness to work with interagency partners toward
                    developing and using a framework to assess PSI activities and toward
                    identifying meaningful performance measures is consistent with our
                    recommendation. If the CCP is developed as a framework that links
                    PSI activities to outcomes and the objective of PSI, it will be
                    consistent with our recommendation.




                 Page 38                                    GAO-12-441 Proliferation Security Initiative
Appendix VI: GAO Contact and Staff
                  Appendix VI: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Thomas Melito, (202) 512-9601, or melitot@gao.gov
GAO Contact
                  In addition to the contact named above, Godwin Agbara (Assistant
Staff             Director), Jeffrey Baldwin-Bott, Lynn Cothern, and Mattias Fenton made
Acknowledgments   key contributions to this report. Martin de Alteriis, Mark Dowling, and Mary
                  Moutsos also provided technical assistance.




(320847)
                  Page 39                                  GAO-12-441 Proliferation Security Initiative
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