Coast Guard
Vessel Identification System Development Needs to Be Reassessed Gao ID: GAO-02-477 May 24, 2002The September 11th attacks emphasized the need for sound government information management of potential risks to U.S. assets and citizens. One possible source of that risk is through the vessels that navigate our ports and waterways. Whereas most large commercial vessels and many large recreational vessels obtain federal documentation, most smaller vessels are registered only in the state where they are primarily used. Congress, in 1998, required the Secretary of Transportation to develop a system to share individual states' vessel information as well as information on federally documented vessels. Fourteen years after legislation required the Coast Guard to develop a vessel identification system (VIS), no such system exists. In 1995 the agency contracted to develop the Marine Information for Safety and Law Enforcement system, of which VIS was a subcomponent. The Coast Guard accepted the contractor-developed VIS in 1998 despite system performance problems, intending to resolve these problems as the system evolved. However, the Coast Guard later found that there was no viable way to correct these problems, and that the cost to populate the system with states' data would be high. Even though the Coast Guard spent $9 million to plan and develop VIS, it was never implemented. Recently, the Coast Guard initiated a new three-phase VIS development effort and developed a rudimentary system called VIS 2.0. The new system contains information on documented vessels and on state's data. However, the Coast Guard has yet to develop detailed plans for the full system development and cannot estimate when a system capable of uploading, integrating, and updating states' data may be developed. Even as the Coast Guard is initiating efforts to plan for the full system development, it does not intend to incorporate a rigorous acquisition process--including comprehensive analyses and management oversight.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-02-477, Coast Guard: Vessel Identification System Development Needs to Be Reassessed
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May 24, 2002:
The Honorable Frank LoBiondo, Chairman. The Honorable Corrine Brown,
Ranking Democratic Member: Subcommittee on Coast Guard and Maritime
Transportation Committee on Transportation and Infrastructure House of
Representatives:
The September 11, 2001, attacks on our nation emphasized the need for
sound government information management--especially as it pertains to
potential risks to U.S. assets and citizens. One possible source of
that risk is through the vessels that navigate our ports and waterways.
Whereas most large commercial vessels and many large recreational
vessels obtain federal documentation, most smaller vessels are
registered only in the state where they are primarily used. In 1988,
the Congress required the secretary of transportation to develop a
system to share individual states‘ vessel information as well as
information on federally documented vessels. A vessel identification
system would allow the Department of Transportation‘s Coast Guard and
local law enforcement officials to more effectively identify critical
information on vessels in our nation‘s ports and waterways--information
including the owner‘s name, vessel identification, and any prior law
enforcement activities associated with the vessel.
Concerned with the Coast Guard‘s lack of progress in developing its
Vessel Identification System (VIS), you asked us to assess efforts to
establish this system. Specifically, our objectives were to determine
(1) the Coast Guard‘s early efforts to acquire VIS, (2) the agency‘s
current plans for developing the system, and (3) whether Coast Guard
acquisition plans are adequate.
To address these objectives, we reviewed past and current VIS
acquisition documents, evaluated Coast Guard plans to acquire VIS by
comparing them to sound acquisition principles, and interviewed Coast
Guard officials, contractor staff, and state boating representatives.
We conducted our review at the U.S. Coast Guard Headquarters in
Washington, D.C., the Coast Guard‘s Operations Systems Center (OSC) in
Martinsburg, West Virginia, and the National Association of State
Boating Law Administrators annual conference in Anchorage, Alaska, from
October 2001 through March 2002, in accordance with generally accepted
government auditing standards. Appendix I contains further details on
our scope and methodology.
Results in Brief:
Fourteen years after legislation required the Coast Guard to develop a
vessel identification system, no such system exists, and future plans
for developing the system are uncertain. The Coast Guard‘s early
efforts to acquire VIS were unsuccessful. In the late 1980‘s and early
1990‘s, the Coast Guard undertook numerous activities to define
requirements for such a system. In 1995, the agency contracted to
develop the Marine Information for Safety and Law Enforcement (MISLE)
system, of which VIS was a subcomponent. The Coast Guard accepted the
contractor-developed VIS in 1998 despite system performance problems,
intending to resolve these problems as the system evolved. However, the
Coast Guard later found that there was no viable way to correct these
and other problems, and that the cost to populate the system with
states‘ data would be high. In retrospect, Coast Guard officials noted
two factors that complicated VIS implementation: (1) not all vessels
had unique identification numbers and (2) the system depended on the
voluntary participation of the states, and many states were unwilling
or unable to commit the funds needed to participate. Consequently, even
though the Coast Guard spent about $9 million in identified costs to
plan and develop VIS, it was never implemented.
Since that time, the Coast Guard has initiated a new three-phase VIS
development effort and, in fact, developed a rudimentary system--called
VIS 2.0--which is populated with information on documented vessels and
one state‘s data. However, the Coast Guard has not yet developed
detailed plans for the full system development and is unable to
estimate when a system capable of uploading, integrating, and updating
states‘ data may be developed.
Even as the Coast Guard is initiating efforts to plan for the full
system development, it does not intend to incorporate a rigorous
acquisition process-- including comprehensive analyses and management
oversight. Coast Guard officials stated that they intend to analyze VIS
costs, benefits, and risks and to evaluate acquisition options, but
they do not plan to follow the Coast Guard‘s acquisition policy---which
requires comprehensive analyses, justification, and oversight.
Officials noted that the acquisition policy does not apply to the
planned VIS development because it is not a major system acquisition, a
designation generally applied to projects over $50 million. However,
rigorous processes and oversight, such as those in the acquisition
policy, are especially critical on the future VIS acquisition because
the Coast Guard is still facing some of the risks that undermined the
early VIS acquisition, the system‘s criticality and requirements may be
evolving as a result of the recent terrorist attacks, and new
alternatives are now available.
Therefore, we are recommending that the Coast Guard reassess its
approach to developing VIS and that the agency perform mission needs
identification, alternatives analyses, and oversight activities. We are
also recommending that the Coast Guard evaluate alternative interim
solutions that could provide some vessel information until a full
system can be implemented. Coast Guard officials agreed to consider our
recommendations.
Background:
Vessel documentation---a national form of vessel registration--is one
of the oldest functions of government, dating back to the 11th Act of
the First Congress. Documentation provides evidence of nationality for
international travel and trade, allows for commerce between the states,
and admits vessels to certain restricted trades, such as coastwise
trade and the fisheries. [Footnote 1] The Coast Guard documents most
large commercial vessels and many large recreational vessels. [Footnote
2] This process involves obtaining key information about the owner and
vessel--including the owner‘s name and address, the manner in which the
owner took title to a vessel, and, in most cases, when and where a
vessel was built. The Coast Guard assigns an official number to all
documented vessels in order to track them, and maintains key
information about the vessel, including mortgages, bills of sale, and
other instruments affecting the vessel title. However, the Coast Guard
does not maintain such information on smaller commercial and
recreational vessels or on large recreational vessels that are
undocumented. Instead, individual states register these vessels under a
variety of numbering programs. [Footnote 3]
Public Law 100-710, as amended, commonly called the Ship Mortgage Act
of 1988, requires the secretary of transportation to establish a vessel
identification system to make information on both federally documented
vessels and state numbered and titled [Footnote 4] vessels available
for law enforcement and other purposes. The information was to include-
-among other items--the owner‘s name, a vessel identifier, the name of
the state in which the vessel is numbered or titled, information on any
liens associated with the vessel, and information to assist law
enforcement officials, such as the date a vessel was stolen or
abandoned. The law permits voluntary state participation in providing
this information.
Originally, the vessel identification system was expected to assist
state boating officials in identifying vessels within their borders,
aid law enforcement officials in identifying stolen vessels, help
mortgagers avoid remortgaging stolen vessels, and help insurers avoid
reinsuring stolen vessels. More recently, given today‘s heightened
state of homeland security, such a system has even more potential
usefulness. Coast Guard officials stated that the system could be used
to help ensure port and national security. For example, law enforcement
officials could use a vessel identification system to review all
vessels that have been lost or stolen and verify ownership and law
enforcement history. Currently, Coast Guard and local law enforcement
officials would have to access multiple sources to obtain this vessel
information--an ineffective and time-consuming process.
Within the Coast Guard, several organizations have had a role in past
and current efforts to develop a vessel identification system.
Specifically, the information and technology directorate--headed by the
chief information officer--is responsible for Coast Guard-wide
information technology (IT) strategy and oversight, including IT
investment management. This organization also oversees the Operations
Systems Center--a government-owned, contractor-operated facility--
which develops, fields, and maintains critical systems and data
networks. The acquisition directorate was responsible for the early VIS
acquisition, whereas the marine safety and environmental protection
directorate is responsible for current system efforts. Another office
within the operations directorate, the office of boating safety,
represents the boating public and coordinates with states on their
needs for VIS.
There are clear guidelines and best practices for managing system
development efforts such as the vessel identification system. Federal
regulations and requirements, including the Clinger-Cohen Act of 1996
and Office of Management and Budget guidance, establish a comprehensive
approach for executive agencies to acquire and manage their information
resources. [Footnote 5] This approach includes (1) focusing information
resource planning on supporting strategic missions; (2) economically
justifying proposed projects on the basis of reliable analysis of
expected life-cycle costs, benefits, and risks; and (3) using these
measures throughout the life cycle as the basis for decisions on
selecting, controlling, and evaluating projects. Additionally, our IT
investment management framework, which is based on industry best
practices, establishes a systematic process for investment planning
management--including selection, control, and evaluation of investment
options to maximize the value of the investments and to minimize their
risks. [Footnote 6]
To implement federal requirements and guidance, the Coast Guard has
established an overarching investment management framework for
selecting, controlling, and evaluating its portfolio of IT investments.
Within this framework the Coast Guard established investment and
acquisition review boards to oversee investment management processes.
Also, underlying agency policies, including the Coast Guard systems
acquisition policy, are intended to support this investment framework.
We recently evaluated Coast Guard information technology management,
and reported that while the agency had many important IT management
policies in place, it did not consistently implement these policies.
[Footnote 7] That is, Coast Guard practices are not always in
compliance with its policies. For example, in the area of software
acquisition, we found that the agency had policies in place for
planning and managing software acquisitions and that the agency
generally followed these policies on the projects we reviewed. However,
in the area of investment management, we found that although the Coast
Guard had an investment management framework and policies in place, and
implemented these policies for major acquisitions exceeding $50
million, it did not adequately oversee the costs, schedules, and risks
of nonmajor acquisitions or operational system projects. We made 17
recommendations to improve the Coast Guard‘s IT management practices
and the agency is working to address these recommendations.
Coast Guard‘s Early Efforts to Acquire VIS Were Unsuccessful:
Soon after the Ship Mortgage Act was enacted, the Coast Guard initiated
a series of planning activities to prepare to fulfill the law. Early in
1989, it established a task force to examine options for satisfying the
law, and subsequently decided to acquire VIS. The Coast Guard also
contracted with the General Services Administration‘s Federal Systems
Integration and Management Center (FEDSIM) to assist in defining the
functionality of the system, developing requirements, analyzing
alternatives, and acquiring the system. As part of their work to define
requirements, the Coast Guard and FEDSIM visited 25 states and the
District of Columbia and met with developers and operators of
nationwide networks, including the motor vehicle administrator‘s
network. Later, in 1992, the Coast Guard and another contractor
surveyed states and developed marketing strategies to demonstrate the
benefits of VIS to states in order to attract their participation.
As the plans for a VIS acquisition evolved, the Coast Guard became
concerned that it had planned too many separate systems and that it
needed to undertake a more integrated approach to developing these
systems. Thus, in the early 1990s, the Coast Guard delayed plans to
acquire VIS in order to integrate the requirements for multiple systems
into a single systems development effort.
In 1995, the Coast Guard awarded a contract to Computer Sciences
Corporation (CSC) to develop systems software, which evolved into the
MISLE system. Under the original MISLE program baseline, VIS was
expected to be the first contract deliverable in December 1997. VIS was
to be a centralized information system capable of uploading state
registered and federally documented vessel information and any changes
to this information. It was to respond to queries for information on
vessels and owners by the Coast Guard and federal and state boating and
law enforcement officials, and--with some limitations--marine bankers
and insurers. The Coast Guard was unable to provide a cost estimate
solely for the VIS development, but the cost of VIS combined with
another component that was to automate the Coast Guard‘s vessel
documentation process, was estimated to be between $12 million and $15
million.
CSC developed and tested VIS and then delivered it to the Coast Guard
in early 1998. The Coast Guard conducted two rounds of operational
testing with state and system users. At the conclusion of the second
round of testing, the Coast Guard reported that users highly rated both
system functionality and their overall satisfaction. In December 1998,
the Coast Guard determined that VIS was operationally effective and
suitable and formally approved the system for full production and
deployment. However, there were still several unresolved problems that
had been encountered during operational testing. Specifically, a high-
priority problem involved the processing of duplicate vessel entries,
while other lower priority problems involved system performance. Coast
Guard officials determined that these items were either the
responsibility of the states or would be resolved through enhancements
to the system as it evolved. Over the next year, the agency and CSC
worked to address the unresolved testing problems and to input one
state‘s vessel data into VIS.
As these VIS activities were proceeding, the MISLE contract was
experiencing escalating costs and schedule delays. Therefore, the Coast
Guard decided to partially terminate its contract with CSC in October
1999. [Footnote 8] Shortly thereafter, the Coast Guard had OSC
[Footnote 9] evaluate VIS.
In January 2000, OSC recommended that VIS be shut down because of
performance problems and the high cost to populate and maintain the
system. Specifically, the evaluation cited the following issues:
System performance problems : VIS was unable to effectively upload
states‘ data, deal with data reliability issues, and handle complicated
requests for information from states and other users. Specifically, OSC
noted that it took over 14 hours to load one state‘s data into VIS and
that this was unacceptably slow. OSC also reported on VIS problems in
handling different vessels with duplicate identification numbers and
single vessels that had multiple identification numbers--a situation
that could occur when a vessel was relocated from one state to another.
In addition, OSC noted that complicated queries either took too long to
process or were not processed at all. The center reported that solving
these issues would involve significant changes to VIS software and
hardware.
Cost to populate VIS : The only method available to pull state data
into VIS was through customized load routines---that is, through
computer programs for uploading data that were tailored to each state‘s
vessel registration system. OSC noted that the cost of developing a
custom routine to load one state‘s data into VIS was approximately
$50,000, and estimated that it would cost the Coast Guard an additional
$2.45 million to develop interfaces for all states to be able to use
VIS as it was intended. In addition, OSC reported that all the
interfaces would have to be maintained and updated when each state
updated its system.
Cost to maintain VIS : Although VIS application tools were state of the
art in 1995, they were outdated in 2000. OSC noted that finding staff
experienced with these tools would be difficult. Therefore, OSC
reported that operations and maintenance costs for VIS would be
significant and suggested replacing these tools with updated ones.
In addition, Coast Guard officials cited two key factors that hindered
the implementation of VIS:
Lack of unique hull identification numbers : Coast Guard officials told
us that in developing VIS, the contractor had assumed that vessels
would have unique hull identification numbers (HINs), but in fact, many
do not. Because manufacturers were not required to provide unique HINs
before 1972, many vessels do not have these numbers, while others do
not have unique HINs-- that is, multiple vessels share an identical
HIN. Thus, the Coast Guard encountered major data integrity problems
when entering vessels into VIS.
Voluntary nature of state participation : The MISLE project manager
stated that the Coast Guard could not force the states to contribute
their vessel data, and that a lack of participation by states would
undermine the usefulness of the system. Other Coast Guard officials
stated that many states were unwilling or unable to commit the funds
necessary to participate in VIS.
Given these problems, key stakeholders agreed that there was no viable
way to correct VIS‘s deficiencies, and the MISLE project manager
decided not to provide any additional MISLE project funds to the
project. As a result, the original VIS development effort was never
implemented, even though the Coast Guard reportedly spent about $9
million [Footnote 10]0 to plan, acquire, and attempt to implement the
system.
oast Guard Initiated a New VIS Development Effort, but Future Plans Are
Uncertain:
After its initial unsuccessful effort, the Coast Guard initiated a new
attempt to develop a vessel identification system. In its January 2000
evaluation report, OSC recommended a three-phased approach to
developing a new vessel identification system. The three phases were
having OSC (1) add to the limited amount of information on federally
documented vessels that was available on-line and provide a password
security feature, (2) develop a generic state vessel registration
system that could be integrated into a proposed new VIS system and
distribute it to states and territories, and (3) develop the new VIS
system that would integrate information from the states and federally
documented vessels. The Coast Guard agreed to these recommendations and
implemented phases 1 and 2 at a reported cost of about $220,000.
However, it has not yet committed to the full development effort
proposed in phase 3 because the agency is working to validate states‘
requirements for the system. The Coast Guard‘s plans for this
development are uncertain.
Phase 1 Has Been Completed and Enhanced:
In October 2000, OSC implemented phase 1 of a new VIS development
effort in a system called VIS 1.0, at a cost of $135,700. To develop
VIS 1.0, OSC modified a copy of the Coast Guard‘s Port State
Information Exchange--an existing Web- based database that contains
some on-line information on federally documented vessels--to include
seven additional data fields that the states had requested, including
information such as the vessel owner‘s name and address. It also added
a password security feature to protect privacy information.
In October 2001, to enhance the system, OSC issued a subsequent
release, VIS 2.0, at a cost of $58,100. In VIS 2.0, OSC added a one-
time load of boating registration data from one state (Georgia),
expanded the database to include an additional 67 data fields, and
enhanced the system‘s reporting capabilities. Officials noted that the
primary reason for these additions was to demonstrate to the states
what VIS could do before building the entire system in phase 3.
Phase 2 Was Developed and Distributed Without a Key Envisioned
Capability:
To address past problems in uploading and integrating states data, OSC
proposed developing phase 2, a generic boating-registration data-entry
system for states to use. The Coast Guard planned to distribute this
system to states and encourage them to use it. In developing a cost
estimate for this effort, OSC included an estimate for an export
routine that would enable states to export their data so that it could
be loaded into a future VIS system. However, the Coast Guard removed
the envisioned export routine from this development effort because it
had not yet defined a format for the future VIS system.
A contractor [Footnote 11]1 developed a generic boating registration
system, called the National Boating Registration (NABR), at a cost of
$25,000. Although the Coast Guard distributed NABR to the states in
July 2001, in the months since its distribution, NABR has not been
heavily used. In fact, the Coast Guard is aware of only one state that
is planning to use a modified version of NABR. Instead, Coast Guard
officials indicated that most states are using their own registration
systems. Coast Guard officials are hopeful that territories that do not
currently have a registration system will be able to use NABR.
Coast Guard‘s Plans for Full VIS Development Are Not Yet Defined:
The Coast Guard‘s current plans for the future of VIS are uncertain.
The Coast Guard halted further work on VIS after phase 2 was completed,
stating that it needed to review and update VIS requirements before
deciding to fund phase 3. Coast Guard officials told us that they
recently met with states to validate VIS requirements and plan to send
these requirements to OSC by the end of May 2002. OSC will then develop
a cost estimate for the system development effort. Coast Guard
officials were unable to provide schedule estimates for when they would
make decisions regarding any future VIS development.
Coast Guard Does Not Plan to Follow a Rigorous Acquisition Process on
Future VIS Effort:
To effectively develop systems, federal requirements, Coast Guard
policies, and sound system acquisition principles call for key
assessments and oversight at the inception of a system acquisition
effort. Specifically, our investment management framework calls for
evaluating completed projects and identifying lessons learned to
incorporate in future development efforts. Additionally, Coast Guard
system acquisition policy--as well as sound system life-cycle
management principles-- calls for identifying mission needs and
operational requirements; exploring suitable, feasible, and affordable
alternatives for meeting those needs through trade-off analyses and
feasibility studies; assessing the costs, benefits, and risks of the
proposed alternatives; and developing an acquisition plan. Coast Guard
policies also call for oversight and approval of these key assessments
by an acquisition board throughout this early planning process. After
an acquisition proposal has been justified and approved, program
management focuses on developing a detailed system design and project
plans, including cost estimates and schedule milestones.
In commenting on a draft of this report, Coast Guard officials noted
that the agency recently revised its systems acquisition policy so that
it now targets only major acquisitions--generally, those expected to
cost over $50 million. An acquisition official stated that the agency
is working to develop policies to guide smaller acquisitions, including
VIS, but does not yet have these policies in place. Further, the Coast
Guard could not estimate a time frame for doing so.
Although Coast Guard officials plan to perform important analyses to
support future VIS efforts, they do not plan to follow all elements of
a rigorous process-- including comprehensive assessments,
justification, and senior management oversight. Coast Guard officials
recently met with states‘ representatives to validate VIS requirements
and reported that they plan to have OSC assess these requirements to
identify cost, schedule, and technical issues and risks. Further, Coast
Guard officials stated that they plan to review this analysis, along
with lessons learned from prior VIS efforts, to evaluate alternative
strategies for developing VIS. However, the Coast Guard has not
formally assessed and developed plans to address lessons learned from
its prior VIS efforts or reassessed its mission needs. Also, without a
structured policy and oversight, it is not clear that the Coast Guard
will fully explore alternative concepts for satisfying system needs
through trade-off analyses and feasibility studies. Further, Coast
Guard officials stated that the acquisition board will not oversee
planned VIS activities.
The reason that the Coast Guard does not plan to perform these system
acquisition activities or obtain acquisition oversight on its new VIS
effort is that it does not believe that these activities are required.
Coast Guard marine safety officials stated that because VIS will not
meet the dollar threshold for a major system acquisition, Coast Guard
policies requiring these analyses, justification, and oversight do not
apply to planned VIS efforts.
However, comprehensive analyses and oversight are especially critical
for a new VIS effort because of the difficulty the agency has had to
date in developing the system, and since so much has changed since the
system was first justified and approved in the mid-1990s. The Coast
Guard is still facing some of the risks that undermined past efforts to
acquire VIS, and there is no evidence that these risks have been
addressed. In addition, the system‘s criticality and mission needs may
have evolved, and new alternatives are now available.
Key risks that undermined past efforts to acquire the system are likely
to hinder any new efforts. Specifically, Coast Guard officials stated
that problems with duplicative or nonexistent HINs are still a concern
and that any new system development effort will need to be able to
handle a variety of situations involving vessel identifiers, including
vessels (1) without HINs, (2) with duplicative HINs, and (3) with
invalid HINs.
Further, Coast Guard officials noted that a lack of state participation
would undermine any new effort. Because state participation is
voluntary, there is no guarantee that states will choose to provide
their vessel data and any updates to that data to a new VIS system. In
fact, several states‘ representatives have reported that they are
unable to commit to future VIS efforts because of the cost of
converting their data to the Coast Guard‘s format and updating the data
as they change. State boating representatives we contacted acknowledged
VIS benefits-- including assisting in recovering stolen vessels,
decreasing fraud associated with stolen vessels, and deterring vessel
theft--but just as many expressed concerns with the technical
complexity and/or the cost of converting their data to the Coast
Guard‘s format. Unless these risks are assessed and managed, they may
undermine any future system development efforts.
While the Coast Guard is still facing these former risks, it is also
encountering evolving needs and new alternatives for VIS. Regarding
mission needs, recent national security issues and consumer safety
hazards [Footnote 12]2 have reemphasized the need for states‘ vessel
data within the Coast Guard. According to a Coast Guard official,
although the Coast Guard has not viewed recreational vessels as a
national security risk in the past, it is now doing so in light of the
recent terrorist attacks. Unless these potential mission needs are
identified and their requirements factored into VIS‘s design and
development, the Coast Guard risks developing a system that does not
capture all the critical information or functions needed to support its
evolving missions.
In addition to evolving needs for information on state-registered
vessels, there are new and promising alternatives for meeting these
needs. Specifically, several private companies obtain and integrate
information on state-registered vessels for marketing purposes.
Although it is not clear whether these companies can meet all user
needs for up-to-date vessel data, their information is more integrated
and up to date than the Coast Guard‘s. For example, one company
maintains a database containing limited vessel data from 46 states and
updates some states‘ data every 6 weeks, while another maintains
limited vessel information from 44 states and has suggested that it
would update the data quarterly. Coast Guard officials are aware of
these options and have stated that they are too expensive and not
timely enough to meet law enforcement needs. However, the agency has
not performed any analysis of the costs, benefits, and risks of these
alternatives.
Also, new technologies, such as the extensible markup language (XML),
have the potential to resolve some of the past problems the Coast Guard
has had in integrating state data. XML is a flexible, nonproprietary
set of standards designed to facilitate the exchange of information
among disparate computer systems using the Internet‘s protocols.
Although implementation challenges still exist, this technology holds
promise as a way to effectively integrate data from diverse systems.
[Footnote 13]3 Unless these and other potential alternatives are
evaluated, the Coast Guard may miss key opportunities to develop VIS
more effectively.
By not incorporating a rigorous system acquisition process, the Coast
Guard risks developing a system that does not address past problems,
fulfill its mission needs, or effectively use new technologies and
commercial products. Without such processes and a commensurate level of
management oversight, the Coast Guard is unlikely to successfully
develop and effectively implement a vessel identification system.
Conclusions:
The Coast Guard has little to show for the 14 years it has spent trying
to develop a vessel identification system to aid state and federal law
enforcement activities. Past efforts to develop the system were
unsuccessful. The agency is now considering another attempt at
developing VIS, but is not straying far from its past, unsuccessful
efforts.
By planning to develop VIS as if it were a low-risk project, instead of
a system acquisition effort that warrants a thorough system acquisition
approach to analyses, justification, and oversight, the Coast Guard
runs the risk that VIS will continue as it has for the past 14 years.
That is, funds will be spent and products will be developed and
delivered, yet users‘ needs for this system will continue to be
unfulfilled.
Given the continuing risks, changing needs, and new alternatives, it is
imperative that this system be approached anew with an understanding of
what went wrong in prior efforts, with sound system acquisition
processes in place, and with adequate program management and oversight.
Recommendations:
In order to mitigate the risk that the Coast Guard will continue to
spend funds on VIS but not fulfill the requirements of the 1988 law, we
recommend that the secretary of transportation direct the Coast Guard
commandant to ensure that the following actions occur to reassess VIS:
determine if the problems with nonunique HINs and a lack of state
participation are still pertinent;
if so, identify what can be done to mitigate these risks; and:
brief relevant congressional committees and subcommittees on critical
VIS risks and options for addressing these risks within 3 months of the
date of this report.
If the Coast Guard decides to move forward in developing a VIS, we
recommend that it do so in compliance with a rigorous system
acquisition approach. Specifically,
reassess mission needs in light of evolving homeland security
initiatives and define and validate user requirements to support these
mission needs;
identify alternatives for fulfilling these needs, including the use of
commercial vendors and new technologies;
perform feasibility studies as well as cost, benefit, and risk analyses
of these alternatives;
select a system design;
develop an acquisition plan that incorporates cost and schedule
milestones; and:
obtain oversight from the Coast Guard acquisition board throughout the
VIS acquisition process to help ensure that it is effectively managed.
Additionally, we recommend that the Coast Guard evaluate the use of
commercial products that could provide vessel information as an
immediate, interim solution until a system that fully meets the
requirements of the Ship Mortgage Act can be developed.
Agency Comments and Our Evaluation:
In providing oral comments on a draft of this report, representatives
of the Department of Transportation and the Coast Guard, including a
representative of the Office of the Secretary of Transportation and the
chief of the Office of Information Resources, agreed to consider our
recommendations. Coast Guard officials reported that the agency would
not expend any further funds on developing VIS until it develops a
viable plan to address the technical and financial barriers to a
successful VIS implementation. Further, officials stated that they
intend to apply sound acquisition principles in developing VIS, but do
not need to follow all the requirements for major acquisitions. Coast
Guard officials also offered specific technical corrections, which we
have incorporated as appropriate.
We believe that rigorous processes and oversight, such as those in the
Coast Guard‘s systems acquisition policy, are especially critical on
the future VIS acquisition because the Coast Guard is still facing some
of the risks that undermined the early VIS acquisition, the system‘s
criticality and requirements may be evolving as a result of the recent
terrorist attacks, and new alternatives are now available.
We are sending copies of this report to the secretary of
transportation, the Coast Guard commandant, the director of the Office
of Management and Budget, and other interested parties. Copies will
also be made available to others upon request.
Should you or your staff have any questions concerning this report,
please contact me at (202) 512-6240 or by e-mail at koontzl@gao.gov .
Sophia Harrison, Franklin Jackson, Colleen Phillips, Cynthia Scott, and
Glenda Wright were major contributors to this report.
Linda D. Koontz:
Signed by Linda D. Koontz.
Director, Information Management Issues:
Appendix 1. Scope and Methodology:
To determine the Coast Guard‘s early efforts to acquire VIS, we
reviewed Public Law 100-710, which required the establishment of a
vessel identification system and identified the specific information
that the system was to include. We reviewed documents that outlined the
Coast Guard‘s early efforts to define and develop functional
requirements. We also evaluated the Coast Guard‘s Marine Information
for Safety and Law Enforcement (MISLE) system project plans,
operational requirements document, and acquisition project baselines to
determine the Coast Guard‘s plans for developing a system that would
meet the requirements of Public Law 100-710.
In addition, we reviewed the specific contract task orders for VIS
development, data conversion, and operation and maintenance efforts.
Further, we reviewed and evaluated VIS formal qualification testing and
operational test and evaluation reports, including system problem
reports outstanding at the end of each of these phases of testing.
Although we reviewed the Operations Systems Center‘s (OSC) assessment
of the Coast Guard‘s first VIS effort, we were not able to validate
this assessment because OSC did not provide supporting documentation to
the Coast Guard at the time it completed its evaluation and did not
maintain such documentation after that time.
We also interviewed the MISLE project manager and representatives from
the offices of information resources and boating safety to determine
their assessment of VIS and to provide details on its acceptance.
To determine the Coast Guard‘s current plans for developing VIS, we
reviewed the current VIS statements of work, project plans, testing
efforts and results, and implementation and usage statistics by state
representatives. We interviewed project sponsor representatives and
contractor staff to determine how these efforts had been planned,
developed, and tested. Regarding the Coast Guard‘s future VIS plans, we
interviewed the MISLE project sponsor representatives as well as
representatives from the office of boating safety. In addition, we
interviewed the MISLE project manager and reviewed and evaluated future
VIS planning documents. We also contacted state boating law officials
representing 20 states and territories to identify their efforts to
participate in prior VIS efforts and to determine their perceptions of
VIS‘s benefits and challenges.
To assess whether the Coast Guard‘s VIS acquisition practices are
adequate, we compared documentation supporting the current VIS
development effort to the analyses and justification required under
sound system acquisition processes, including federal regulations and
the Coast Guard‘s own system acquisition policies. We also interviewed
Coast Guard officials to discuss their plans for analyzing and
justifying new VIS efforts.
(310332):
FOOTNOTES
[1] ’Coastwise trade“ involves the transportation of merchandise or
passengers between points in the United States or in the exclusive
economic zone--an area extending 200 miles out from the U.S. shoreline.
’Fisheries“ involves the processing, storing, transporting (except in
foreign commerce), planting, cultivating, catching, taking, or
harvesting of fish, shellfish, marine animals, pearls, shells, or
marine vegetation in the navigable waters of the United States or in
the exclusive economic zone.
[2] Rules governing the documentation of vessels vary, depending on the
vessel‘s volume and whether it is used for commercial or recreational
purposes. The Coast Guard only documents vessels with volumes of 5 net
tons or more--generally those measuring over 25 feet. Given vessels of
these volumes, federal law requires commercial vessels engaged in
coastwise trade and the fisheries to obtain federal documentation. In
addition, the owners of commercial vessels engaged in foreign trade
often choose to obtain federal documentation in order to obtain the
protection of the U.S. government. While not required, the Coast Guard
also documents recreational vessels of 5 net tons or more. Because only
documented vessels are eligible for preferred loans, most mortgage
lenders require federal documentation in order to protect themselves.
[3] Federal law requires any undocumented vessel equipped with
propelling machinery to be numbered in the state in which it is
primarily operated. In addition, some states require all undocumented
vessels to be numbered, even if they are not propelled by machinery.
[4] In addition to numbering vessels, some states also issue titles,
which are records of ownership.
[5] Clinger-Cohen Act of 1996, Public Law 104-106, and Office of
Management and Budget Circular A-130 (November 30, 2000).
[6] U.S. General Accounting Office, Information Technology Investment
Management: A Framework for Assessing and Improving Process Maturity,
Exposure Draft, GAO/AIMD-10.1.23, version 1 (Washington, D.C.: May
2000).
[7] U.S. General Accounting Office, Information Technology Management:
Coast Guard Practices Can Be Improved, GAO-01-190 (Washington, D.C.:
Dec. 12, 2000).
[8] We discuss the Coast Guard‘s MISLE program in our report, U.S.
General Accounting Office, Coast Guard: Update on Marine Information
for Safety and Law Enforcement, GAO-02-11 (Washington, D.C.: Oct. 17,
2001).
[9] OSC‘s primary contractor has changed over the years. From 1996
until August 2001, OSC‘s primary contractor was Fuentez Systems
Concepts, Incorporated. On July 6, 2001, OSC awarded its primary
operations contract to QSS Group, Inc.; major subcontractors include
Fuentez Systems Concepts, Incorporated and Litton TRC.
[10] 0This figure includes costs associated with early planning efforts
from 1987 to 1990 and CSC contract costs attributed to VIS. It does not
include costs of planning efforts between 1991 and 1994 because the
Coast Guard was not able to identify these. Also, the costs for the
years from 1995 to 1999 do not include any funds associated with Coast
Guard personnel or management because the agency was not required to
track government costs associated with a particular subcomponent.
[11] 1Coast Guard officials reported that Fuentez Systems Concepts,
Incorporated developed the NABR system independent of its OSC support
contract.
[12] 2Recent carbon monoxide deaths associated with certain houseboats
highlighted the need for more effectively identifying vessel owners to
alert them to hazards and to issue recall notices.
[13] 3U.S. General Accounting Office, Electronic Government: Challenges
to Effective Adoption of the Extensible Markup Language, GAO-02-327
(Washington, D.C.: Apr. 5, 2002).
