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Report to the Committee on Homeland Security and Governmental Affairs, 
U.S. Senate: 

United States Government Accountability Office: 
GAO: 

December 2008: 

Radio Communications: 

Congressional Action Needed to Ensure Agencies Collaborate to Develop a 
Joint Solution: 

GAO-09-133: 

GAO Highlights: 

Highlights of GAO-09-133, a report to the Committee on Homeland 
Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

The Integrated Wireless Network (IWN) was intended to be a 
collaborative effort among the Departments of Justice (DOJ), Homeland 
Security (DHS), and the Treasury to provide secure, seamless, 
interoperable, and reliable nationwide wireless communications in 
support of federal agents and officers engaged in law enforcement, 
protective services, homeland defense, and disaster response missions. 
GAO was asked to determine the extent to which the three departments 
are developing a joint radio communications solution. To address this 
objective, GAO reviewed and analyzed relevant documentation and 
interviewed department officials about the extent to which they are 
collaborating with the other departments on IWN or an alternative joint 
radio communications solution. 

What GAO Found: 

The Departments of Justice, Homeland Security, and the Treasury had 
originally intended IWN to be a joint radio communications solution to 
improve communication among law enforcement agencies; however, IWN is 
no longer being pursued as a joint development project. Instead of 
focusing on a joint solution, the departments have begun independently 
modernizing their own wireless communications systems. While the 
Departments of Justice and the Treasury (and later the Department of 
Homeland Security) collaborated on a pilot demonstration of IWN in the 
Seattle/Blaine area that continues to provide service to multiple 
agencies, the departments have determined that this specific system 
design cannot be implemented on a nationwide scale, and they have not 
acted collaboratively to identify an alternative approach for a jointly 
coordinated communications solution. In addition, the formal governance 
structure that was established among the three departments has been 
disbanded, and the contract for developing a new IWN design, awarded 
over a year and a half ago, is not being used jointly by the 
departments for this purpose. Currently, the Department of Justice is 
planning to implement a nationwide network for its component agencies, 
and the Department of Homeland Security and its components are pursuing 
numerous independent solutions. 

A primary reason why the collaboration on a joint communications 
solution has not been successful is that the departments did not 
effectively employ key cross-agency collaboration practices. 
Specifically, they could not agree on a common outcome or purpose to 
overcome their differences in missions, cultures, and established ways 
of doing business; they have not established a collaborative governance 
structure with a process for decision making and resolving disputes; 
and they have not developed a joint strategy for moving forward. While 
the Department of Homeland Security considers improving radio 
communications at the nation’s borders to be a major priority, the 
Department of Justice’s priorities are in other areas. Program 
officials from both departments acknowledged that these differing 
priorities led to an inability to resolve conflicts. As a result, they 
now have several initiatives aimed at high-level coordination, none of 
which are focused on developing a joint communications solution. While 
department officials have signed an updated memorandum of understanding 
related to coordinating their radio communications projects, they have 
not made any progress on reestablishing a joint governance structure 
and decision-making procedures to address the challenges of 
collaborating on a joint communications solution. 

In abandoning collaboration on a joint solution, the departments risk 
duplication of effort and inefficient use of resources as they continue 
to invest significant resources in independent solutions. Further, 
these efforts will not ensure the interoperability needed to serve day-
to-day law enforcement operations or a coordinated response to 
terrorist or other events. 

What GAO Recommends: 

GAO is not recommending executive action. However, Congress should 
consider, given the critical importance of improving radio 
communications among federal agencies, requiring that DOJ, DHS, and the 
Treasury employ key cross-agency collaboration practices to develop a 
joint radio communications solution. In written comments on a draft of 
this report, DOJ and DHS largely disagreed with GAO’s findings and 
conclusions. GAO continues to believe that adoption of key 
collaborative practices is critical. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-133]. For more 
information, contact Joel Willemssen at (202) 512-6253 or 
willemssenj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Matters for Congressional Consideration: 

Agency Comments and Our Evaluation: 

Appendix I: Briefing to Staff of the Senate Committee on Homeland 
Security and Governmental Affairs: 

Appendix II: Comments from the Department of Justice: 

Appendix III: Comments from the Department of Homeland Security: 

Appendix IV: Comments from the Department of the Treasury: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Abbreviations: 

DHS: Department of Homeland Security: 

DOJ: Department of Justice: 

ECPC: Emergency Communications Preparedness Center: 

IWN: Integrated Wireless Network: 

NTIA: National Telecommunications and Information Administration: 

MOU: memorandum of understanding: 

OEC: Office of Emergency Communications: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

December 12, 2008: 

The Honorable Joseph Lieberman: 
Chairman: 
The Honorable Susan Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The tragic events of September 11, 2001, and Hurricane Katrina have 
highlighted the critical importance of having effective radio 
communications systems for law enforcement and public safety agencies 
including federal agencies with such responsibilities. In order to 
effectively respond to events such as natural disasters, criminal 
activities, and domestic terrorism, law enforcement and public safety 
agencies need reliable systems that enable communication with their 
counterparts in other disciplines and jurisdictions. Further, since the 
1990s, increasing demand for radio communications capabilities in both 
the private and public sectors has created a need to use radio 
communications capacity more efficiently. 

The Integrated Wireless Network (IWN) was intended to be a 
collaborative effort among the Departments of Justice (DOJ), Homeland 
Security (DHS), and the Treasury to provide secure, seamless, 
interoperable,[Footnote 1] and reliable nationwide wireless 
communications in support of federal agents and officers engaged in law 
enforcement, protective services, homeland defense, and disaster 
response missions. This initiative, begun in 2001, was originally 
estimated to cost approximately $5 billion. 

At your request, we determined the extent to which DOJ, DHS, and the 
Treasury are developing a joint radio communications solution to 
improve communications among federal agencies. To address this 
objective, 

* we reviewed and analyzed documentation from DOJ, DHS, and the 
Treasury to determine the status of IWN, 

* interviewed officials from each department about the extent to which 
they are collaborating with the other departments on IWN or on an 
alternative joint radio communications solution, 

* reviewed and analyzed documentation for independent radio 
communications projects at DOJ and DHS to identify actions the 
departments are taking to improve their radio communications systems, 

* reviewed and analyzed past and present agreements among the 
departments to determine the extent to which a governance structure is 
in place that enables effective collaboration, and: 

* compared collaboration activities performed by the departments to 
selected practices previously identified by GAO as helpful to 
sustaining collaboration among federal agencies.[Footnote 2] 

We performed our audit work in the Washington, D.C., metropolitan area 
at DOJ, the Federal Bureau of Investigation, the Drug Enforcement 
Administration, DHS, Immigration and Customs Enforcement, Customs and 
Border Protection, the Treasury, the National Institute of Standards 
and Technology, the National Telecommunications and Information 
Administration, and the Office of Management and Budget. We also 
conducted work at agency field offices in the Seattle, Washington, 
metropolitan area, which was the location of a key pilot demonstration 
for the IWN program. 

We conducted this performance audit from February to September 2008, in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

This report summarizes the information we provided to your staff during 
our September 25, 2008, briefing. The full briefing, including our 
objective, scope, and methodology, can be found in appendix I. 

In summary, our briefing made the following points: 

* DOJ, DHS, and the Treasury had originally intended IWN to be a joint 
radio communications solution to improve communication among law 
enforcement agencies; however, IWN is no longer being pursued as a 
joint development project. Instead of focusing on a joint solution, the 
departments have begun independently modernizing their own wireless 
communications systems. While DOJ and the Treasury (and later DHS) 
collaborated on a pilot demonstration of IWN in the Seattle/Blaine area 
that continues to provide service to multiple agencies, the departments 
have determined that this specific system design cannot be implemented 
on a nationwide scale, and they have not acted collaboratively to 
identify an alternative approach for a jointly coordinated 
communications solution. In addition, the formal governance structure 
that was established among the three departments has been disbanded, 
and the contract for developing a new IWN design, awarded over a year 
and a half ago, is not being used jointly by the departments for this 
purpose. Currently, DOJ is planning to implement a nationwide network 
for its component agencies, and DHS and its components are pursuing 
numerous independent solutions. 

* A primary reason why the collaboration on a joint communications 
solution has not been successful is that the departments did not 
effectively employ key cross-agency collaboration practices. 
Specifically, they could not agree on a common outcome or purpose that 
overcame their differences in missions, cultures, and established ways 
of doing business; they did not establish an effective collaborative 
governance structure with a process for decision making and resolving 
disputes; and they have not developed a joint strategy for moving 
forward. While DHS considers improving radio communications at the 
nation's borders to be a major priority, DOJ's priorities are in other 
areas. Program officials from both departments acknowledged that these 
differing priorities led to an inability to resolve conflicts. As a 
result, while the departments now have several initiatives aimed at 
high-level coordination, none are focused on developing a joint 
communications solution. While department officials have signed an 
updated memorandum of understanding related to coordinating their radio 
communications projects, they have not made any progress in 
reestablishing a joint governance structure and decision-making 
procedures to address the challenges of collaborating on a joint 
communications solution. 

* In abandoning collaboration on a joint solution, the departments risk 
duplication of effort and inefficiency as they continue to invest 
significant resources in independent solutions. Further, these efforts 
will not ensure the interoperability needed to serve day-to-day law 
enforcement operations or a coordinated response to terrorist or other 
events. While collaboration on a joint solution is critical for 
success, this joint solution need not be based necessarily on a single, 
nationwide network, such as an extension of the original IWN design. It 
could also consist of a mutually agreed-upon strategy for developing 
separate but interoperable networks and systems that incorporate 
lessons learned from past efforts. 

Matters for Congressional Consideration: 

Congress should consider requiring the Departments of Justice, Homeland 
Security, and Treasury to collaborate on the development and 
implementation of a joint radio communications solution. Specifically, 
Congress should consider requiring the departments to: 

* establish an effective governance structure that includes a formal 
process for making decisions and resolving disputes, 

* define and articulate a common outcome for this joint effort, and: 

* develop a joint strategy for improving radio communications. 

Congress should also consider specifying deadlines for completing each 
of these requirements. 

Agency Comments and Our Evaluation: 

We obtained written comments on a draft of this report from DOJ, DHS, 
and the Treasury, which are reprinted in appendixes II, III, and IV 
respectively. 

In comments from DOJ, the Assistant Attorney General for Administration 
largely disagreed with our findings and conclusions. DOJ stated that we 
had not recognized that circumstances had changed since the inception 
of our review and that departmental leaders had agreed on a common 
approach that would address concerns we have raised. However, we 
believe that our review accurately characterizes the evolution of 
circumstances throughout the development of IWN as well as the current 
status of the program. For example, we noted in our briefing slides 
that the departments had collaborated productively on the Seattle/ 
Blaine pilot program, which served as a working demonstration and test 
of the IWN design. We also acknowledged in the slides that the 
departments had recently established a memorandum of understanding 
(MOU) regarding development of interoperable communications systems in 
the future. While that step is important, an effective governance 
structure still needs to be implemented before decisions can be made 
and procedures established for overcoming the differing missions, 
priorities, funding structures, and capabilities among the departments. 

DOJ also commented that the current business environment is not 
conducive to a single mobile-radio solution, and that such an approach 
is no longer feasible or cost-effective. In the slides we pointed out 
that a single, common project or system is not necessarily the best 
solution, and our conclusions do not advocate such a system as the best 
solution. We concluded that successful collaboration on a joint 
solution--whether that solution is IWN or an alternative approach--is 
necessary to promote efficient use of resources, reduce duplicative 
efforts, and encourage interoperability. Although a joint solution 
could be based on a single, nationwide network, such as an extension of 
the original IWN design, it could also be, for example, a mutually 
agreed-upon strategy for developing separate but interoperable networks 
and systems. 

DOJ stated that it planned to continue pursuing eventual integration 
and interoperability with DHS and other entities using common standards 
and guidelines rather than through a single, central solution. We agree 
that the implementation of common standards and guidelines are 
important and can help facilitate a joint project such as this. The 
Seattle/Blaine pilot project, for example, was based on the Project 25 
set of standards. However, agreement has not yet been reached on the 
standards and guidelines that are to shape future collaboration among 
the departments on a joint approach to radio communications. As 
reflected in the briefing slides, we believe that success hinges on a 
means to overcome differences in missions and cultures, a collaborative 
governance structure through which decisions are made and disputes 
resolved, and a joint strategy to align activities and resources to 
achieve a joint solution. 

DOJ also stated that where the report seemed to suggest that DOJ and 
other agencies had not collaborated, that in fact the departments had 
worked together and collaborated extensively. However, as described in 
the briefing, we disagree with this statement. While DOJ has 
collaborated with other agencies on the Seattle/Blaine pilot project, 
the agencies determined that that specific system design could not be 
implemented on a nationwide scale, and they have not acted 
collaboratively to identify an alternative approach for a jointly 
coordinated communication solution. As discussed in the briefing, while 
the departments recently established an MOU regarding development of 
interoperable communications systems in the future, no progress had 
been made in re-establishing the joint governance structure outlined in 
the agreement, and the departments have been actively working to 
develop independent communications systems. In effectively abandoning 
collaboration on a joint solution, the departments risk duplication of 
effort and inefficient use of resources as they continue to invest 
significant resources in independent solutions. Further, these 
stovepipe efforts will not ensure the interoperability needed to serve 
day-to-day law enforcement operations or a coordinated response to 
terrorist or other events. As stated above, the adoption of key 
collaboration practices will be critical to a successful outcome. 

Finally, the department stated that it understood GAO's concern that 
the departments risk duplication of effort and that it had made great 
progress in minimizing duplication/overlap, as evidenced by the 
Seattle/Blaine pilot project. However, as discussed above, the pilot 
project has not been chosen as a basis for a jointly coordinated, 
nationwide communications solution, nor has any other specific strategy 
been adopted that would provide assurance that duplication will be 
minimized in the future. DOJ also agreed that agencies must begin 
meeting quarterly to improve communications and that they must better 
document their overall, collective strategy beyond the MOU. Until a 
joint strategy to align activities and resources is adopted, we believe 
the potential for duplication and overlap remains. 

In comments from DHS, the Director of the Departmental Audit Liaison 
Office discussed the development of the IWN program and noted that 
issues had been identified with joint governance, the management of 
priorities and requirements across multiple departments, and addressing 
user requirements within schedule constraints. In this regard, DHS 
stated that our report was focused on mandating that the three agencies 
have one radio communications solution and that it implied that any 
other option would result in a stovepipe of non-interoperable 
communications systems. We disagree. As discussed above, in the slides 
we pointed out that a single, common project or system is not 
necessarily the best solution, and we do not advocate such a system as 
the best solution. We concluded that successful collaboration on a 
joint solution--whether that solution is IWN or an alternative 
approach--is necessary to promote efficient use of resources, reduce 
duplicative efforts, and encourage interoperability. Although a joint 
solution could be based on a single, nationwide network, such as an 
extension of the original IWN design, it could also be, for example, a 
mutually agreed-upon strategy for developing separate but interoperable 
networks and systems. 

Regarding the breakdown of the original collaborative structure for the 
IWN program, DHS commented that DHS and DOJ are employing different 
radio designs funded by Congress that are commensurate with spectrum 
needs in their environments and that the two departments have different 
regional priorities, such that a common system will not work on a 
national level. In the briefing, we recognized that the two departments 
had different priorities and that those differences led to an inability 
to resolve conflicts on the original IWN program. However, as discussed 
above, in effectively abandoning collaboration on a joint solution, the 
departments risk duplication of effort and inefficient use of resources 
as they continue to invest significant resources in independent 
solutions. Given their differences, adoption of key collaboration 
practices will be critical to ensuring that separate projects in the 
two departments are successfully coordinated in the future so that 
radio communications are improved among federal agencies, costs 
reduced, and duplication eliminated wherever possible. 

DHS also commented that we had not discussed the departments' concerns 
about the projected expense of expanding the Seattle/Blaine pilot 
project to a national level. While we did not discuss specific cost 
projections for this option, which is no longer being considered, we 
recognize that any investment in coordinated future communications 
between the departments will be substantial. Accordingly, it will be 
critical to ensure a properly coordinated approach so that duplication 
and overlap is avoided. 

Regarding current collaboration with DOJ and Treasury, DHS noted that a 
memorandum of understanding had been signed in January 2008 and 
described how decisions are to be made under this agreement. DHS went 
on to describe internal priorities, such as the need for radio system 
upgrades in Customs and Border Protection, and stated that any cross- 
departmental efforts should not result in delays to these priorities. 
We do not dispute the urgency for upgrading radio systems that DHS 
cites. However, given that all three departments have differing 
priorities, as discussed in the slides, it remains critical that key 
collaboration practices are adopted to ensure successful coordination 
across departments. 

Finally, DHS briefly outlined its vision for a "tiered" strategy for 
achieving effective radio communications in a timely and cost-effective 
manner. DHS stated that the first goal of the partnership will be to 
define an outcome and an associated joint strategy. We agree that these 
elements--along with an effective governance structure that includes a 
formal process for making decisions and resolving disputes--are key 
elements for successful collaboration and implementation of a joint 
radio communications solution. 

In comments from the Treasury, the Chief Information Officer stated 
that the department continued to be highly supportive of the overall 
goals of the IWN program and looked forward to continuing to work with 
DOJ and DHS to advance law enforcement and emergency services 
communications. 

We are sending copies of this report to interested congressional 
committees and the Attorney General, the Secretary of Homeland 
Security, and Secretary of the Treasury. The report also is available 
at no charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-6253 or at willemssenj@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 to this report 
are listed in appendix V. 

Signed by: 

Joel C. Willemssen: 
Managing Director, Information Technology: 

[End of section] 

Appendix I: Briefing to Staff of the Senate Committee on Homeland 
Security and Governmental Affairs: 

Radio Communications: Congressional Action Needed to Ensure Agencies 
Collaborate to Develop a Joint Solution: 

Briefing for the Staff of the Senate Committee on Homeland Security and 
Governmental Affairs: 

September 25, 2008: 

Outline of Briefing: 

Introduction: 

Objective, Scope, and Methodology: 

Results in Brief: 

Background: 

DOJ, DHS, and Treasury Are No Longer Pursuing a Joint Solution: 

Conclusions: 

Matters for Congressional Consideration: 

Agency Comments and Our Evaluation: 

[End of section] 

Introduction: 

The tragic events of 9/11 and Hurricane Katrina have highlighted the 
critical importance of having effective radio communications systems 
for law enforcement and public safety agencies including federal 
agencies with such responsibilities. In order to effectively respond to 
events such as natural disasters, criminal activities, and domestic 
terrorism, law enforcement and public safety agencies need reliable 
systems that enable communication with their counterparts in other 
disciplines and jurisdictions. Further, since the 1990s, increasing 
demand for radio communications capabilities in both the private and 
public sectors has created a need to use radio communications capacity 
more efficiently. 

The Integrated Wireless Network (IWN) was intended to be a 
collaborative effort among the Departments of Justice (DOJ), Homeland 
Security (DHS), and the Treasury to provide secure, seamless, 
interoperable,[Footnote 3] and reliable nationwide wireless 
communications in support of federal agents and officers engaged in law 
enforcement, protective services, homeland defense, and disaster 
response missions. This initiative, begun in 2001, was originally 
estimated to cost approximately $5 billion. 

[End of Introduction] 

Objective, Scope, and Methodology: 

As agreed, our objective for this review was to determine the extent to 
which DOJ, DHS, and Treasury are developing a joint radio 
communications solution to improve communication among federal 
agencies. To address our objective, we: 

* reviewed and analyzed documentation from DOJ, DHS, and Treasury to 
determine the status of IWN, 

* interviewed officials from each department about the extent to which 
they are collaborating with the other departments on IWN or an 
alternative joint radio communications solution, 

* reviewed and analyzed documentation for independent radio 
communications projects at DOJ and DHS to identify actions the 
departments are taking to improve their radio communications systems, 

* reviewed and analyzed past and present agreements among the 
departments to determine the extent to which a governance structure is 
in place that enables effective collaboration, and; 

* compared collaboration activities performed by the departments to 
selected practices previously identified by GAO as helpful to 
sustaining collaboration among federal agencies.[Footnote 4] 

We performed our audit work in the Washington, D.C., metropolitan area 
at DOJ, the Federal Bureau of Investigation, the Drug Enforcement 
Administration, DHS, Immigration and Customs Enforcement, Customs and 
Border Protection, Treasury, the National Institute of Standards and 
Technology, and the National Telecommunications and Information 
Administration. We also conducted work at these agencies’ field offices 
in the Seattle, Washington, metropolitan area, which was the location 
of the key pilot demonstration for the IWN program. 

We conducted this performance audit from February 2008 to September 
2008, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives, 
and we believe that the evidence obtained provides a reasonable basis 
for our findings and conclusions based on our audit objectives. 

[End of Objective, Scope, and Methodology] 

Results In Brief: 

While DOJ, DHS, and Treasury had originally intended IWN to be a joint 
radio communications solution to improve communication among law 
enforcement agencies, IWN is no longer being pursued as a joint 
development project. Instead of focusing on a joint solution, the 
departments have begun independently modernizing their own wireless 
communications systems. While DOJ and Treasury (and later DHS) 
collaborated on a pilot demonstration of IWN in the Seattle/Blaine area 
that continues to provide service to multiple agencies, the departments 
have determined that this specific system design cannot be implemented 
on a nationwide scale, and they have not acted collaboratively to 
identify an alternative approach for a jointly coordinated 
communications solution. In addition, the formal governance structure 
that was established among the three departments has been disbanded, 
and the contract for developing a new IWN design, awarded over a year 
and a half ago, is not being used jointly by the departments for this 
purpose. Currently, DOJ is planning to implement a nationwide network 
for its component agencies, and DHS and its components are pursuing 
numerous independent solutions. 

A primary reason why the collaboration on a joint communications 
solution has not been successful is that the departments did not 
effectively employ key cross-agency collaboration practices. 
Specifically, they could not agree on a common outcome or purpose to 
overcome their differences in missions, cultures, and established ways 
of doing business; they have not established a collaborative governance 
structure with a process for decision making and resolving disputes; 
and they have not developed a joint strategy for moving forward. While 
DHS considers improving radio communications at the nation’s borders to 
be a major priority, DOJ’s priorities are in other areas. Program 
officials from both departments acknowledged that differing priorities 
led to an inability to resolve conflicts. As a result, they now have 
several initiatives aimed at high-level coordination, none of which are 
focused on developing a joint communications solution. Department 
officials have indicated that they have not made any progress on re-
establishing a joint governance structure and decision-making 
procedures for a joint communications solution. 

In abandoning collaboration on a joint solution, the departments risk 
duplication of effort and inefficient use of resources as they continue 
to invest significant resources in independent solutions. Further, 
these stovepipe efforts will not ensure the interoperability needed to 
serve day-to-day law enforcement operations or a coordinated response 
to terrorist or other events. 

Given the importance of collaborating effectively toward improving 
radio communications among federal agencies, reducing costs, and 
eliminating duplication where possible and the departments’ failure to 
develop a joint radio communications solution through their own 
initiative, Congress should consider requiring that the Departments of 
Justice, Homeland Security, and Treasury employ key cross-agency 
collaboration practices discussed in this report to develop a joint 
radio communications solution. 

We received comments via e-mail from DOJ and DHS on a draft of these 
briefing slides. Treasury officials stated that they had no comments on 
the draft briefing slides. 

In their comments, officials from DOJ’s Office of the Chief Information 
Officer disagreed with our findings and conclusions in several areas. 
First, the department officials stated that our analysis was flawed and 
unrealistic in focusing on a single, common project as the best 
solution for supporting missions, improving interoperability, and 
achieving cost efficiencies. We disagree that our conclusions advocate 
a single system as the best solution and clarified our position in the 
briefing that a joint approach could mean a single system or it could 
be a mutually agreed-upon strategy for developing separate but 
interoperable networks. 

Second, DOJ officials stated that we misrepresented their efforts to 
work with other agencies, including DHS, and that the department had 
tried to reach consensus and compromise with DHS but organizational 
challenges could not be overcome. We acknowledge that DOJ took steps to 
collaborate on IWN; however, we also note that when the challenges of 
collaborating could not be overcome, progress stalled. Rather than 
contradicting our conclusions, we believe these facts support our 
analysis that key practices for collaborating were not established or 
sustained. Unless such practices are established and sustained, the 
departments are unlikely to succeed at implementing a joint 
collaborative solution. 

Third, department officials stated that we unfairly characterized the 
results of the Seattle/Blaine pilot and failed to recognize DHS’s lack 
of contribution to the pilot and its requirements development. However, 
the pilot and its requirements development occurred prior to DHS’s 
involvement in the program. Further, we acknowledge within our briefing 
that the pilot provided a working demonstration and test of the 
preliminary network design as well as several specific benefits. 
Nevertheless, our discussions with users in the pilot area reveal that 
the pilot network did not meet many of their needs. In order to make 
progress in addressing unmet needs through a joint partnership, it will 
be important that the departments collaborate on alternative approaches 
based on lessons learned from this pilot. 

Finally, DOJ expressed concern that our findings did not address the 
business and operational issues facing IWN, including differing 
missions and priorities and a lack of funding. While these issues can 
be challenging, the departments have not implemented the governance 
structure or employed the key collaboration practices needed to 
overcome these challenges. 

Officials from DHS’s National Protection and Programs Directorate did 
not state whether they agreed or disagreed with our findings but 
provided suggestions for consideration in the development of a joint 
strategy, including expanding the partnership to include other federal 
departments, leveraging existing infrastructure across all levels of 
government, and ensuring that interoperability is a priority focus. The 
additional considerations proposed by DHS for inclusion in the joint 
partnership are consistent with our results and may merit attention as 
the partnership develops. DHS officials also provided technical 
comments that we have incorporated into the briefing slides, as 
appropriate. 

[End of Results in Brief] 

Background: 

Radio frequency communications are vital to public safety organizations 
that respond to natural disasters and terrorist acts. These 
organizations include the nation’s first responders (such as 
firefighters, police officers, and ambulance services) as well as 
federal agencies that have law enforcement and public safety 
responsibilities, such as the Federal Bureau of Investigation. Federal 
law enforcement agencies rely on wireless land mobile radio systems for 
their day-to-day operations and use radio communications to provide for 
the safety of agents and the public. Further, in order to perform 
public safety operations effectively, these communications must be 
secure as well as reliable. 

The origins of the IWN program date back to 2001. At that time, DOJ and 
Treasury were independently pursuing efforts to upgrade their land 
mobile radio systems to meet a National Telecommunications and 
Information Administration (NTIA) requirement to reduce their use of 
radio frequency spectrum.[Footnote 5] Due to the similarity of their 
law enforcement missions and overlapping geographic jurisdictions, the 
two departments began discussing a joint project in August 2001. 

The subsequent events of 9/11 further underscored the need for secure, 
wireless, interoperable communications for all levels of government, 
and in November 2001, DOJ and Treasury[Footnote 6] took the initiative 
to create the IWN program by signing a memorandum of understanding to 
collaborate on achieving cost efficiencies and improving communications 
operability[Footnote 7] among their own law enforcement agencies as 
well as with other federal, state, and local organizations. The IWN 
joint program was intended to be a nationwide radio communications 
system that would provide secure, seamless, and reliable wireless 
communications in support of law enforcement. In addition, the IWN 
program would serve as a means for upgrading aging equipment. 

In November 2002, DOJ awarded a contract to obtain the services, 
hardware, and software to develop a pilot for the IWN network in the 
Seattle/Blaine area and test the viability of a proposed IWN design and 
technology.[Footnote 8] After 2 years in development, the pilot was 
considered operational in December 2004 at a cost of approximately $32 
million. This pilot provided a digital, trunked,[Footnote 9] Project 
25[Footnote 10]-compatible radio communications network for several 
federal agencies and enabled interoperability with several state and 
local law enforcement organizations in the Seattle/Blaine area. 

Following the establishment of DHS, several law enforcement components 
from DOJ and Treasury were transferred to the new department and the 
scope of IWN was expanded. In June 2004, DOJ,[Footnote 11] DHS, 
[Footnote 12] and Treasury[Footnote 13] signed a new memorandum of 
understanding. This agreement established the following governance 
structure to oversee and carry out the implementation of IWN: 

* The Joint Program Office, consisting of staff assigned to the office 
on a full-time basis from each of the departments, was responsible 
for—among other things—performing all IWN program administrative and 
project management functions. 

* The IWN Executive Board, consisting of the Chief Information Officer 
from each of the departments, was responsible for providing executive-
level guidance and policy and program direction to the Joint Program 
Office. 

* The National Project Team, comprised of representatives from each 
component/bureau participating in the IWN program, was responsible 
for—among other things—providing information to the Joint Program 
Office required for the development, implementation, and administration 
of the IWN system. 

The memorandum of understanding described identical responsibilities 
and resource contributions for DOJ and DHS. However, Treasury was not 
required to share the costs of designing and building IWN, given its 
reduced number of law enforcement personnel after creation of DHS. 

In July 2004, the IWN Executive Board initiated an acquisition strategy 
to award a contract to: 

* obtain reliable, secure, nationwide wireless communication 
capabilities; 

* reduce costs by leveraging economies of scale; 

* enable rapid deployment of radio communications functionality 
nationwide; 

* enhance interoperability, operational effectiveness, and support 
though increased coverage and capabilities; and; 

* establish interoperability with other federal and non-federal 
wireless users through the consistent application of standards 
developed from this effort. 

The strategy envisioned selecting a single contractor to implement the 
entire IWN program using a 3-phased process: 

* In phase 1, vendors submitted information regarding their high-level 
conceptual approach, organizational experience, and past performance. 
As a result of this process, four vendors continued in the acquisition 
process. This phase was completed in December 2004. 

* In phase 2, the four vendors submitted detailed technical, 
management, and cost proposals to accomplish the entire IWN program. 
Based on an evaluation of these proposals, two vendors were awarded 
contracts to prepare detailed system designs. This phase was originally 
scheduled for completion in May 2005 but was not completed until June 
2006. 

* Phase 3 was to select the winning contractor based on evaluation of 
the detailed system designs submitted by each contractor. As a result 
of this process, General Dynamics C4 Systems was selected as the IWN 
systems integrator in April 2007. Figure 1 shows a timeline of major 
events related to IWN. 

Figure 1: Timeline of Events Related to IWN: 

[Refer to PDF for image] 

September, 1993: NTIA issued requirement for reducing use of radio 
frequency spectrum; 

November, 2001: DOJ and Treasury signed MOU; 

November, 2002: DOJ and Treasury begin developing an IWN pilot in the 
Seattle/Blaine area; 

June, 2004: DOJ, DHS, and Treasury signed IWN MOU; 

July, 2004: IWN Executive Board initiated acquisition process; 

December, 2004: Seattle/Blaine pilot became operational; 

April, 2007: IWN systems integration contract awarded. 

[End of figure] 

We have previously reported on the importance of communications 
interoperability to effective public safety operations.[Footnote 14] 
Interoperability has been significantly hampered by the use of 
incompatible radio systems. Different technologies and configurations, 
including proprietary designs made by different manufacturers, have 
limited the interoperability of such systems. 

In 2004, we reported that a fundamental barrier to successfully 
establishing interoperable communications for public safety was the 
lack of effective, collaborative, interdisciplinary, and 
intergovernmental planning.[Footnote 15] Further, in 2007, we made 
recommendations to DHS to improve interoperable communications among 
federal, state, and local first responders.[Footnote 16] Among other 
things, we recommended that DHS develop a plan that strategically 
focused its interoperability programs and provided quantifiable 
performance measures. Program officials indicated that they were in the 
process of developing such a plan; however, they had not established a 
completion date for it. 

We have also previously reported on key practices agencies should 
employ to help them overcome the barriers to successful inter-agency 
collaboration.[Footnote 17] These practices include: 

* Defining and articulating a common outcome or purpose that overcomes 
differences in department missions, cultures, and established ways of 
doing business. 

* Establishing a governance structure, including a collaborative 
management structure with defined leadership, roles and 
responsibilities, and a formalized process for making decisions and 
resolving disputes. 

* Establishing mutually reinforcing or joint strategies that work in 
concert with those of the partners or are joint in nature to align 
activities and resources to accomplish the common outcome. 

Implementing these practices is critical to sustaining a successful 
inter-agency project such as IWN. 

[End of Background section] 

DOJ, DHS, and Treasury are no longer pursuing a joint solution: 

Given the importance of radio communications and the reality of limited 
resources, it is critical that agencies find ways to work together to 
achieve effective and efficient interoperable solutions. In particular, 
the advantages of collaborating to develop a joint radio communications 
solution clearly outweigh the benefits of each department pursuing its 
own radio communications initiative, as DOJ, DHS, and Treasury agreed 
when they signed on to the IWN program. The benefits of developing IWN 
as a joint communications solution, as identified by the program, 
include: 

* supporting departmental missions effectively and efficiently, 

* providing sufficient communications coverage for current operations, 

* achieving efficient use of radio spectrum, 

* improving interoperability with federal, state, and local law 
enforcement agencies, and; 

* achieving cost efficiencies through resource consolidation and 
economies of scale. 

Achieving these benefits hinges on successful inter-agency 
collaboration. 

Despite early progress, the departments are pursuing independent 
solutions: 

Although the departments made early progress in jointly developing and 
implementing a pilot program, they are no longer pursuing IWN as a 
joint solution and instead are independently modernizing their own 
wireless communications systems. 

DOJ and Treasury (and later DHS) contributed resources to develop an 
operational pilot in the Seattle/Blaine area to demonstrate the 
original IWN design. This pilot provided a working demonstration and 
test of the preliminary network design, generally improved 
communications in the coverage area, addressed federal encryption 
requirements through new equipment, established technical solutions for 
interoperability with selected state and local organizations, and 
provided valuable lessons learned. While the pilot remains operational 
and has been expanded to increase coverage in areas of Washington and 
Oregon, several DOJ and DHS components in the region have been unable 
to fully use the system due to unmet requirements. Components in the 
area continue to maintain legacy networks to ensure complete coverage. 

Since the pilot demonstration, DOJ and DHS have concluded that the 
pilot design could not be implemented jointly on a nationwide scale. 
DOJ officials expressed concern that it would be too expensive to 
expand the pilot network to fulfill DOJ, DHS and Treasury requirements 
on a nationwide scale, while DHS officials were also concerned that the 
design would not be technically well suited to meet DHS needs. 

Since deciding not to proceed with the IWN pilot design jointly, the 
departments have not developed an alternative approach for 
collaborating on a joint communications solution, either through 
development of a single, nationwide network, such as an extension of 
the original IWN design, or a through a mutually agreed-upon strategy 
for developing separate but interoperable networks and systems that can 
accommodate the needs of all participants and incorporate the lessons 
learned from prior efforts (such as the pilot). For example: 

* The departments have not used their IWN contract as a vehicle for 
development of a joint solution. For nearly three years, DOJ, DHS, and 
Treasury jointly participated in the process of selecting a systems 
integrator. However, since that selection, the departments have not 
used the IWN contract (awarded a year and a half ago) to begin 
developing a joint nationwide radio communications solution. Instead, 
the task order that has been issued based on the IWN contract is being 
used for establishing a joint program office for the contractor and 
DOJ—not for DHS or Treasury. The task order specifies that the 
contractor will draft architecture documents for developing a 
communications system for DOJ—it does not include DHS or Treasury. 

* The formal governance structure for IWN originally supported by the 
three departments has been disbanded. Specifically, the IWN Executive 
Board and the National Project Team stopped meeting after award of the 
IWN contract. In addition, the Joint Program Office that was intended 
to manage IWN is no longer supported by shared staff and resources from 
the three agencies.[Footnote 18] Although officials from the three 
departments stated that they talk to each other about radio 
communications issues, these discussions have not occurred on a regular 
basis and have not been used to re-establish a formal governance 
structure for developing a joint communications solution. 

Further, despite initial agreement to establish IWN as a joint program, 
the departments have been actively working to develop independent 
communications systems. DOJ is currently planning to implement a 
nationwide network for its components, while DHS and its components are 
pursuing multiple approaches to meet their individual priorities. 
Specifically: 

* DOJ is developing a department-level nationwide radio network, which 
officials refer to as the Law Enforcement Wireless Communications 
solution. It is intended to ensure basic operability for its components 
that need to replace legacy systems that Drug Enforcement 
Administration officials noted can be as old as 20 years. According to 
department officials, the DOJ Wireless Management Office is working 
with the IWN contractor to develop a phased approach to implementing 
this network. As part of the first phase, DOJ plans to consolidate 
legacy systems on a regional basis, replace or decommission certain 
systems, and deploy new systems to meet federal requirements for 
reduced spectrum use and encryption. Establishing interoperability with 
other federal, state, and local organizations; network redundancy; 
trunking; and spectrum efficiency are to be included in later phases, 
as funding is available. According to the department, the total cost is 
estimated at $1.23 billion, and the system will be implemented over 6-7 
years. 

* DHS is pursuing multiple approaches at both the component and 
department levels to meet different priorities. For example, since 
2005, Customs and Border Protection has been developing and 
implementing a nationwide radio communications network intended to 
improve and update radio communications for Customs and Border 
Protection officers and agents—referred to as the Tactical 
Communications Modernization Project. In contrast, Immigration and 
Customs Enforcement officials have adopted a different approach, 
looking for opportunities to strategically partner with other agencies 
and leverage existing assets to meet their operational requirements. 
Immigration and Customs Enforcement has submitted a number of proposals 
to the department for approval. While initiatives such as these are 
reviewed by the DHS Office of the Chief Information Officer, they are 
funded at the component level and focus on meeting the needs of 
individual components. 

In addition to such component initiatives, the DHS Office of Emergency 
Communications (OEC), which is responsible for IWN, is pursuing a high-
level strategy for developing radio communications networks, based on 
shared infrastructure, as an alternative to the original IWN design. 
The OEC approach, which has been explored with the assistance of the 
Federal Partnership for Interoperable Communications,[Footnote 19] 
focuses on coordination with federal, state, and local organizations 
that are building or planning to build large communications networks so 
that these networks might also meet the needs of member federal 
agencies. However, the OEC’s shared infrastructure approach has yet to 
be approved at the department level. In addition, this approach focuses 
on coordination with other government agencies and not specifically 
among DHS components or the law enforcement community, which was an 
original goal for the IWN program. 

The departments have not employed key cross-agency collaboration 
practices: 

A primary reason that collaboration on a joint communications solution 
has not been successful and the benefits envisioned by the departments 
have not been realized is that the departments did not effectively 
employ key cross-agency collaboration practices. As we previously 
mentioned, these practices include defining and articulating a common 
outcome or purpose, establishing a governance structure, and 
establishing mutually reinforcing or joint strategies to accomplish a 
common outcome. For example: 

* The departments have not defined and articulated a common outcome or 
purpose that overcomes differences in department missions, cultures, 
and established ways of doing business. Although the departments 
originally recognized the benefits of collaborating on a joint 
solution, they allowed differences in priorities and opinions to stall 
their collaboration efforts. Specifically, DOJ saw IWN as a concept or 
vision for new development, which would culminate in a nationwide radio 
communications network for federal law enforcement. DHS, in contrast, 
considered the IWN contract to be a vehicle for systems integration. In 
addition, DHS considered improving radio communications around the 
nation’s borders to be a major priority, while DOJ’s priorities were 
focused in other areas of the nation. Further, the departments could 
not agree on the direction that IWN should take after deciding that the 
design of the pilot would not be appropriate for a nationwide network. 
DOJ and DHS program officials have both acknowledged that differing 
priorities led to an inability to resolve conflicts. They further 
explained that delays in progress and continued deterioration of legacy 
systems led the departments to independently pursue other solutions. 

* The departments did not establish a collaborative governance 
structure that includes a management structure, defined roles and 
responsibilities, and a formalized process for decision making and 
resolving disputes. Although the departments attempted to establish a 
joint governance structure, it was not effective at decision making and 
resolving disputes and the partnership was discontinued. Both DOJ and 
DHS stated that making joint decisions in their original partnership 
depended on reaching consensus among the departments, and when 
consensus could not be reached, progress on IWN stalled. 

* The departments did not establish a mutual or joint strategy to align 
activities and resources to accomplish a common outcome. Despite 
acknowledging the potential benefits from collaborating on a joint 
solution, the departments have not produced a strategic or 
implementation plan that outlines a strategy for developing a joint 
radio communications solution, whether that solution is IWN or an 
alternative joint approach. 

The departments are aware that efforts to collaborate have not been 
successful. Although they have established three high-level initiatives 
to address coordination, these initiatives are not focused on 
implementing a collaborative joint communications solution across DOJ, 
DHS, and Treasury. Specifically: 

* The three departments signed a new memorandum of understanding in 
January 2008 that aims at coordinating their joint wireless programs. 
Although the goals of the current memorandum are similar to those that 
the departments specified in their 2004 agreement for IWN, DOJ and DHS 
officials have stated that no progress has been made in re-establishing 
the joint governance structure outlined by the agreement. In addition, 
decision-making procedures outlined in the 2008 memorandum—like those 
in the 2004 agreement—do not clearly define how to overcome barriers 
faced when consensus cannot be reached among the departments. DOJ and 
DHS officials agreed the memorandum serves primarily as a means for 
facilitating communication among the departments when opportunities and 
funding are available. 

* Participation in the Federal Partnership for Interoperable 
Communications is voluntary for both federal and state entities, 
coordination occurs on an ad-hoc basis, and meeting participants do not 
necessarily include officials who are in positions to make decisions 
about their agency’s radio communications programs. As previously 
described, the DHS OEC’s shared infrastructure approach is intended to 
explore collaboration through the Federal Partnership for Interoperable 
Communications and focuses on coordinating radio communications 
initiatives among federal, state, and local organizations based on 
operational needs. However, DOJ officials stated that the Federal 
Partnership for Interoperable Communications serves primarily as a 
working group of technical staff, while Treasury officials noted that, 
to date, they have attended the group’s meetings primarily as observers 
rather than as active participants. Therefore, it is unclear whether 
this initiative can address the day-to-day mission needs of law 
enforcement agencies. 

* In accordance with the 21st Century Emergency Communications Act, 
[Footnote 20] the Emergency Communications Preparedness Center[Footnote 
21] (ECPC) has been created and is supported by the OEC. The purposes 
of this group include serving as the focal point for interdepartmental 
efforts and providing a clearinghouse for relevant information 
regarding the ability of emergency response providers and relevant 
government officials to communicate in the event of natural or man-made 
disasters and acts of terrorism. DHS officials believe that the 
creation of the ECPC will address collaboration and may be the proper 
forum for coordinating a joint solution. However, the charter for this 
organization has not yet been approved. Although DOJ and Treasury both 
participate in the Emergency Communications Preparedness Center, DOJ 
officials noted that this group is focused on emergency communications 
and response, and it is unclear whether this group can address the day-
to-day operational requirements of law enforcement agencies. 

Although these initiatives are focused on coordination, participation 
is not required and joint governance and decision-making structures 
have not been established. Further, with DOJ and DHS pursuing 
independent solutions, it is clear that the departments do not view 
these initiatives as a means to collaborate on the IWN program and have 
not defined or committed to an alternative approach to develop a joint 
communications solution. Without a commitment to collaborate on a joint 
solution, they will continue to invest significant resources in 
independent solutions that risk duplication of effort and inefficient 
use of resources. Further, these stovepipe efforts will not ensure the 
interoperability needed to serve day-to-day law enforcement operations 
or for responding to terrorist or other events that require a 
coordinated response. 

[End of section] 

Conclusions: 

Despite early progress on the pilot effort, the departments have been 
unable to sustain development of a joint radio communications solution 
on their own. As a result, after seven years of effort, they are no 
longer pursuing IWN as a joint solution and are instead pursuing 
potentially duplicative and wasteful independent solutions. 

A primary reason that collaboration on a joint communications solution 
has failed and the benefits envisioned by the departments have not been 
realized is that the departments did not effectively employ key cross-
agency collaboration practices that could overcome the challenges faced 
in such programs. Specifically, they lacked a means to overcome 
differences in missions and cultures, a collaborative governance 
structure that could make decisions and resolve disputes, and a joint 
strategy to align activities and resources to achieve a joint solution. 

As long as the departments pursue separate initiatives and expend their 
resources independently, they risk duplication and inefficiency, and 
may fail to achieve the level of interoperability that is vital for 
both law enforcement and emergency communications. While successful 
collaboration on a joint solution is necessary, this joint solution 
could be based on a single, nationwide network, such as an extension of 
the original IWN design, or it could also be a mutually agreed-upon 
strategy for developing separate but interoperable networks and systems 
that incorporate lessons learned from past efforts. Given the 
importance of collaborating effectively toward improving radio 
communications among federal agencies, reducing costs, and eliminating 
duplication where possible and the departments’ failure to develop a 
joint radio communications solution through their own initiative, 
Congressional action should be considered to ensure that this 
collaboration takes place. 

[End of Conclusions section] 

Matters for Congressional Consideration: 

The Congress should consider requiring that the Departments of Justice, 
Homeland Security, and Treasury collaborate on the development and 
implementation of a joint radio communications solution. Specifically, 
Congress should consider requiring the departments to: 

* establish an effective governance structure that includes a formal 
process for making decisions and resolving disputes; 

* define and articulate a common outcome for this joint effort; and; 

* develop a joint strategy for improving radio communications. 

Congress should also consider specifying deadlines for completing each 
of these requirements. 

[End of Matters for Congressional Consideration section] 

Agency Comments and Our Evaluation: 

We received comments via e-mail from DOJ and DHS on a draft of these 
briefing slides. Treasury officials stated that they had no comments on 
the draft briefing slides. 

Officials from DOJ’s Office of the Chief Information Officer disagreed 
with our findings and conclusions in several areas and expressed 
concerns that we did not accurately characterize the department’s 
efforts to collaborate. Officials from DHS’s National Protection and 
Programs Directorate did not state whether they agreed or disagreed 
with our findings, but provided suggestions for additional 
consideration; in addition, DHS officials provided technical comments 
that we incorporated into the briefing slides, as appropriate. 

Officials from DOJ’s Office of the Chief Information Officer disagreed 
with our findings and conclusions in several areas. First, the 
officials stated that our analysis was flawed and unrealistic in 
focusing on a single, common project as the best solution for 
supporting missions, improving interoperability, and achieving cost 
efficiencies. However, we disagree that our conclusions advocate a 
single, common project or system as the best solution. We concluded 
that successful collaboration on a joint solution, whether that 
solution is IWN or an alternative approach, is necessary to promote 
efficient use of resources, reduce duplicative efforts, and encourage 
interoperability. Although a joint solution could be based on a single, 
nationwide network, such as an extension of the original IWN design, it 
could also be, for example, a mutually agreed-upon strategy for 
developing separate but interoperable networks and systems. 

Accordingly, we have clarified our briefing slides to emphasize that we 
have not concluded that a single monolithic project or system is the 
most appropriate joint collaborative solution. 

Second, the department officials stated that we misrepresented DOJ 
efforts to work with other agencies, including DHS. Specifically, DOJ 
officials stated that they had tried to reach consensus and compromise 
with DHS, but DHS leadership had not embraced the concept of a joint 
program, forcing DOJ to work individually with the DHS components 
instead of with a single, consolidated program office within the DHS 
organization. Furthermore, the DOJ officials cited lack of centralized 
funding at DHS to be another key challenge to collaborating with that 
department. We acknowledge that DOJ took steps to collaborate on IWN, 
but when the challenges could not be overcome, progress stalled. We 
recognize the challenges faced in collaborating among departments, and, 
in particular, the challenges described by DOJ in collaborating with 
DHS. However, rather than contradicting our conclusions, we believe 
these facts support our analysis that key practices for collaborating 
were not established or sustained. Unless such practices are 
established and sustained, the departments are unlikely to succeed at 
implementing a joint collaborative solution. 

Third, DOJ officials also stated that we unfairly characterized the 
results of the Seattle/Blaine pilot and failed to recognize DHS’s lack 
of contribution to the pilot and its requirements development. However, 
the pilot and its requirements development occurred prior to DHS’s 
involvement in the program. Further, in our briefing, we note that the 
Seattle/Blaine pilot afforded several benefits to users in Washington 
and Oregon, including improving communications in the coverage area and 
establishing technical solutions for interoperability with state and 
local organizations. Further, we agree that the pilot served as a 
working demonstration and test of the IWN design and that additional 
participation from DHS might have resulted in additional requirements 
being met. However, our discussions with users and potential users 
revealed that the pilot network did not meet many of their needs. In 
order to make progress in addressing unmet needs through a joint 
partnership, it will be important that the departments collaborate on 
alternative approaches based on lessons learned from this pilot. 

Finally, DOJ officials also expressed concern that our findings did not 
address business and operational issues facing IWN, including a lack of 
adequate funding and the differing missions, priorities, funding 
structures, and existing capabilities at DHS and DOJ. While we agree 
that the departments have faced significant challenges, we believe that 
collaboration on a joint strategy remains critically important. We 
recognize that the departments have taken initial steps to re-establish 
coordination, such as signing a revised memorandum of understanding. 
However, an effective governance structure needs to be implemented 
before decisions can be made and procedures established for overcoming 
the differing missions, priorities, funding structures, and 
capabilities among the departments. 

We also obtained comments on a draft of this briefing via e-mail from 
DHS’s National Protection and Programs Directorate officials. In these 
comments, the DHS officials did not state whether they agreed or 
disagreed with our findings, but they supported the continued 
development of a joint federal radio communications strategy and stated 
that more specific guidance was needed. Specifically, DHS identified 
three elements for inclusion in the development of a joint strategy: 

* Expand the partnership to include other federal departments that rely 
on mission-critical wireless communications beyond the law enforcement 
community. 

* Leverage existing infrastructure across all levels of government to 
ensure cost effectiveness and reduce duplication of effort. 

* Ensure that interoperability is a priority focus beyond the upgrade 
and modernization focuses of the original IWN concept. 

In addition, the department stated that there was a need within DHS to 
further align authority and resources with responsibility for a joint 
solution. For example, while the Office of Emergency Communications was 
given responsibility for IWN, it was not given authority and only 
limited resources for the management of the program and therefore had 
limited ability to drive stakeholders toward a joint solution. The 
additional considerations proposed by DHS for inclusion in the joint 
partnership are consistent with our results, and may merit attention as 
the partnership develops. DHS officials also provided technical 
comments on our draft briefing slides, which we have incorporated, as 
appropriate. 

[End of Agency Comments and Our Evaluation section] 

[End of Appendix I] 

Appendix II: Comments from the Department of Justice: 

U.S. Department of Justice: 
Washington, D.C. 20530: 

November 28, 2008: 

Mr. Joel C. Willemssen: 
Director, Information Technology: 
U.S. Government Accountability Office: 
441 G. Street, N.W. 
Washington, DC 20548: 

Dear Mr. Willemssen: 

The Department of Justice (DOJ) appreciates the opportunity to comment 
on the General Accounting Office (GAO) draft report entitled, Radio 
Communications: Congressional Action Needed to Ensure Agencies 
Collaborate to Develop a Joint Solution, GAO-09-133. DOJ is concerned 
about the report's findings and conclusion. Our primary issue with the 
report is that it does not recognize the changed circumstances since 
the inception of the project. GAO began the audit with the view that a 
single, shared project among law enforcement entities would be the best 
solution and its findings in this report continue to assert that this 
is the best approach. In fact, leadership of the three agencies 
addressed in the audit--DOJ, the Department of Homeland Security (DHS), 
and the Department of Treasury (DOT) -- have since agreed upon and are 
pursuing a common approach that should address the GAO concerns and 
render the recommendations outdated. Most importantly, we need to be 
certain that Congress does not act upon the GAO report in a manner that 
pursues a path that is different than the one that now best addresses 
our collective business needs. 

Over the past five years, we have learned that the business environment 
in which we operate is not conducive to a single, mobile-radio 
solution, and in fact our experiences and the progress of technology 
have moved us to a place where we have collectively determined that 
such an approach is not feasible or cost-effective today. We wish that 
the GAO had more fully addressed the history and challenges of the 
project and shown how the current planned and agreed upon approach is 
indeed the best solution. 

Given the separate funding streams and the scarcity of resources 
available to each agency for mobile radio technology, as well as the 
unique operational needs and different work environments of each 
agency, it simply is not realistic or wise to pursue a single, unified 
project approach. The overall project cost estimate was $5 billion. 
DOJ's current estimate of its portion is approximately $1.2 billion, 
which is significantly less than the original projection for DOJ. None 
of the agencies has received such resources to date, and separate 
appropriations further complicate a single project and acquisition 
approach. In addition, while DOJ has centralized its radio resources in 
the Law Enforcement Wireless Communications account, others have not. 
Agency operational priorities and needs also are very different, e.g., 
areas to be covered, types of equipment, etc. For example, DOJ needs 
city and highway coverage, whereas DHS needs ports and border coverage. 
In short, it would be a mistake to pursue a single mobile radio 
solution for all agencies. 

We certainly understand GAO's point that a single solution offers 
savings opportunities compared to redundant, separate systems. However, 
what the three agencies are now pursuing are not redundant systems, it 
is interoperable systems tailored to the differing needs of each 
agency. Thus, we will achieve the cost savings that come with 
interoperability while maintaining the necessary capabilities required 
by each agency's operational and geographic circumstances. 

Rather than a single, central solution, DOJ plans to continue pursuing 
eventual integration and interoperability with DHS and other federal 
partners, and with state/local/tribal entities, using common standards 
and guidelines. The radio market already is evolving toward this model 
given the need of fire and EMS personnel to talk to law enforcement. We 
must build our solutions to these standards, and continue to 
collaborate toward these ends. 

Where the report seems to suggest that DOJ and the other agencies have 
not collaborated, in fact we have worked together and collaborated 
extensively. We developed a memorandum of understanding (MOU) that was 
signed by the Deputy Attorney General and the Deputy Secretaries of 
Treasury and Homeland Security on January 9, 2008, establishing a new 
and realistic plan for moving forward with mobile radio technology 
acquisition. 

Consistent with the MOU, the DOJ integrated wireless network (IWN) 
program plans to continue using the contract awarded to General 
Dynamics and invites other agencies to join us in this. General 
Dynamics was selected by an inter-agency group, its rates are good, and 
the contractor team is skilled at integrating technical 
requirements/needs consistent with funding mechanisms in the Federal 
setting. This contract offers us the staffing flexibility and skills 
needed to get the job done. 

Despite our progress, we understand GAO's concern that the three 
departments risk duplication of effort and inefficient use of 
resources. In fact, we have made great progress and duplication/overlap 
is minimal today, as evidenced by our Seattle pilot program results. 
Users in the field, such as DHS, are satisfied with the new solutions. 
There are new capabilities and increased usage, as well as greater 
efficiency through reduction of communication towers needed. The system 
currently supports 1,426 agents, including 1,031 from DOJ and 291 from 
DHS. Currently, 19 Federal agencies use IWN in the Pacific Northwest. 

In addition, the IWN has: 

* Allowed DOJ to reduce the amount of radio spectrum use by up to 50 
percent; 

* Reduced radio transmission sites by 40 percent thus eliminating lease 
and circuit costs for these sites; 

* Allowed DOJ components to decommission their VHF legacy sites in all 
areas that IWN is currently deployed; and; 

* Provided enhanced coverage using fewer sites by eliminating redundant 
sites, leading to increased coverage for all components over their 
legacy systems. 

Despite our disagreement with GAO's premise that a single solution is 
needed, there are areas of agreement with GAO. We agree that our 
agencies must begin meeting quarterly to improve communications and 
that we must better document our overall, collective strategy beyond 
the MOU. We need to increase our advocacy of industry standards, and 
recognize our collective buying power positions us to push the market 
toward better standards and solutions. 

In summary, we believe we are headed in the right direction with regard 
to mobile radio technology and that pursuing standards to ensure 
integration and interoperability is the solution; not a single, 
collective acquisition or project. We hope that we will have the 
opportunity to brief Congress on the progress we are making and our 
future plans with regard to radio technology. In addition, we would be 
happy to brief Congress on efficiencies gained and lessons learned in 
the Seattle pilot as well. Thank you for the opportunity to review the 
draft report. 

Sincerely, 

Signed by: 

Lee J. Lofthus: 
Assistant Attorney General for Administration: 

[End of section] 

Appendix III: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 
[hyperlink, http://www.dhs.gov] 

December 8, 2008: 

Joel C. Willemssen: 
Managing Director, Information Technology: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Willemssen: 

Subject: Department of Homeland Security input for GAO Draft Report 09-
133, "Radio Communications: Congressional Action Needed to Ensure 
Agencies Collaborate to Develop a Joint Solution," December 2008: 

The Department of Homeland Security (DHS) appreciates the opportunity 
to respond to this draft report before its publication. The report does 
not include specific recommendations but presents four actions related 
to the Integrated Wireless Network (IWN) for consideration by Congress. 
The Office of Emergency Communications within the National Protection 
and Programs Directorate has prepared this response to address the 
actions requested by the Government Accountability Office (GAO) and 
provide comments on the overall report. 

Effective radio communications systems are critically important for law 
enforcement and public officials responding to events such as natural 
disasters, criminal activities, and domestic terrorism. The IWN 
initiative, begun in 2001, was intended to serve as the contracting 
tool that would be able to improve the Federal tactical communications 
capabilities among DHS, the Department of Justice (DOJ), and the 
Department of Treasury (Treasury), the primary Federal law enforcement 
agencies. Over time, this fundamental concept has evolved and accounted 
for changes in the wireless technology industry and operational 
requirements of the partner agencies. Lessons learned from major events 
(e.g., 9/11, Hurricane Katrina) indicate that Federal wireless needs 
extend beyond a limited number of Federal partners or a single 
discipline (e.g., law enforcement), and that interoperability with 
State, local, and tribal agencies must be considered an essential 
requirement of any joint Federal wireless solution. 

Additional management and administration lessons learned from the IWN 
Program and the Seattle/Blaine Pilot Project identified issues with 
joint governance; the management of priorities and requirements across 
multiple departments; and the addressing of user requirements within 
schedule constraints. The GAO's report is focused on mandating that the 
three agencies have one radio communications solution and implies that 
any other option will result in a stovepipe of noninteroperable 
communication systems. In addition, the GAO report states that the 
governance structure for pursuing a joint communications solution was 
disbanded due to a lack of collaboration and agreement; in fact, DHS 
and DOJ are employing different radio designs funded by Congress that 
are commensurate with spectrum needs in their environments. Because DOJ 
and DHS have different regional priorities - the majority of DOJ users 
operate in highly populated, geographically condensed urban areas with 
limited frequencies, while the majority of DHS users operate in remote 
border areas - a common system will not work on a national level, 
although common systems can work in particular cases. Planning for 
spectrum efficiency is as much a function of the geographic landscape 
in which law enforcement is operating as it is a function of joint 
planning. 

The report does not elaborate on DOJ and DHS's concerns over the 
expense of taking the Seattle/Blaine operational pilot nationwide to 
fulfill the requirements of DHS, DOJ, and Treasury; providing these 
cost estimates would have provided better context for understanding the 
decision not to implement the pilot design on a nationwide scale. 

Specifically, in response to GAO's matters of consideration to 
Congress, the following comments are offered: 

Implement the MOU as articulated. In the event that common ground 
cannot be reached, attempt a new governance model within the framework 
of the Emergency Communications Preparedness Center (ECPC) with 
authority to make decisions and resolve disputes among partners. 

Response: In January, 2008, the DHS, DOJ, and Treasury signed a 
Memorandum of Understanding describing an agreed-upon governance 
structure. Joint wireless programs will be governed by the Joint 
Wireless Programs Coordinating Council, which will meet on a quarterly 
basis. Decisions will be reached by consensus and documented through 
interagency Memoranda of Agreement signed by the Chief Information 
Officers from each participating Department. In the event consensus is 
not reached, the issue will be referred for consideration by the Deputy 
Attorney General and the Deputy Secretaries of DHS and Treasury. Any 
agreed-upon interoperability requirements must be taken into account 
early in the system-design stage and should not in any way delay 
operational upgrade requirements in later stages. It is essential to 
the DHS mission that current radio system modernizations undertaken 
across departments do not result in delays to much-needed upgrades in 
the DHS component radio systems, thus posing risk to mission 
effectiveness and the safety of agents and officers. For example, 
current needs within DHS Customs and Border Protection (CBP) for radio 
systems upgrades are absolutely pressing. Radio systems provide 
critical lifelines to officer safety, but many areas are using radio 
systems that are old and past their life expectancies. 

Similarly, DHS CBP must coordinate its modernization schedule to 
support the operational needs of SBInet, which has a project dependency 
on the Global Positioning System Blue Force Tracking data generated by 
the Land Mobile Radio (LMR) microphones. DHS CBP must implement new 
systems a year ahead of SBInet deployments. LMR modernization efforts 
are long-term projects with significant external schedule dependencies. 
The time required to obtain spectrum certifications, clear spectrum 
licenses with neighboring countries, negotiate site leases, and work 
around environmental and seasonal restrictions (some sites may be 
inaccessible for several months out of the year) pose significant 
obstacles to timely implementation of new systems. 

Develop a joint outcome and strategy for improving radio communications 
among the expanded partnership within the ECPC. 

Response: DHS, DOJ, and Treasury will use a tiered strategy to achieve 
effective radio communications in a timely and cost-effective manner. 
Where necessary, investments will first address immediate mission-
critical operability and coverage requirements. Concurrently, the 
partnership will focus on standardization and optimization of networks 
planned or in service. The first goal of the expanded partnership under 
the ECPC will be to define an outcome and an associated joint strategy. 
The final tier of the strategy will involve partnering with private 
partners on research and development efforts to migrate to emerging 
wireless technologies that meet public safety requirements and 
standards for reliability, sustainability, security, and coverage. 

Sincerely, 

Signed by: 

Jerald E. Levine: 
Director: 
Departmental Audit Liaison Office: 

[End of section] 

Appendix IV: Comments from the Department of the Treasury: 

Department Of The Treasury: 
Washington, D.C. 20220: 

November 13, 2008: 

Mr. Nick Marinos: 
Senior Information Technology Analyst: 
Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Marinos: 

The Department of the Treasury has reviewed the draft report entitled 
Radio Communications: Congressional Action Needed to Ensure Agencies 
Collaborate to Develop a Joint Solution and appreciates the opportunity 
to comment. 

The Department continues to be highly supportive of the overall goals 
of the Integrated Wireless Network program and the Federal Partnership 
for Interoperable Communications. Treasury looks forward to continuing 
to work with the Departments of Justice and Homeland Security, as well 
as other Federal agencies, to advance law enforcement and emergency 
services communications. 

Please contact me at 202-622-5093 or at Michael.Duffy@do.treas.gov 
should you have any questions. 

Sincerely, 

Signed by: 

Michael D. Duffy: 
Deputy Assistant Secretary for Information Systems and Chief 
Information Officer: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Joel C. Willemssen, (202) 512-6253, or willemssenj@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Linda D. Koontz, Director; 
John de Ferrari, Assistant Director; Shannin O'Neill; Neil Doherty; 
Nancy Glover; Nick Marinos; Melissa Schermerhorn; Jennifer Stavros- 
Turner; and Shaunyce Wallace made key contributions to this report. 

[End of section] 

Footnotes: 

[1] Interoperability is the ability of different systems to readily 
connect with each other and enable timely communications. 

[2] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005) and GAO, Electronic Government: Potential Exists for Enhancing 
Collaboration on Four Initiatives, [hyperlink, 
http://www.gao.gov/products/GAO-04-6] (Washington, D.C.: Oct. 10, 
2003). 

[3] Interoperability is the ability of different systems to readily 
connect with each other and enable timely communications. 

[4] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005) and GAO, Electronic Government: Potential Exists for Enhancing 
Collaboration on Four Initiatives, [hyperlink, 
http://www.gao.gov/products/GAO-04-6] (Washington, D.C.: Oct. 10, 
2003). 

[5] In 1992, Congress passed the Telecommunications Authorization Act 
of 1992 (Pub. L. No. 102-538 (1992)), which mandated that the Secretary 
of Commerce and the NTIA (the organization responsible for effective 
use of radio frequencies by federal agencies) develop a plan to make 
more efficient use of federal land mobile radio spectrum. In response, 
NTIA required, with certain exceptions, that the channel bandwidth in 
certain frequency bands used by federal agencies for land mobile radio 
systems be reduced from 25 to 12.5 kilohertz. This reduction in channel 
bandwidth is referred to as narrow banding. NTIA specified different 
time frames for the transition based on the frequency band and whether 
it was a new or existing system. 

[6] According to Treasury officials, Treasury agents made up about one-
third of the potential users for the IWN system while DOJ agents 
included about two-thirds of the potential users. 

[7] Operability is the ability of emergency responders to establish and 
sustain communications in support of mission operations. 

[8] Treasury contributed resources to the Seattle/Blaine pilot. 

[9] Trunking is a computer-controlled system that uses all available 
frequencies in a pool, automatically allocating an open frequency each 
time a user on the system initiates a radio call. Although trunking 
provides greater spectrum efficiency and functionality, it costs 
significantly more than conventional technology, which uses dedicated 
frequencies assigned to individual groups of users. 

[10] Project 25 is a suite of national standards which define open 
standards for vendors to use when designing land mobile radio 
communications equipment. 

[11] The DOJ Wireless Management Office is currently responsible for 
funding and management related to wireless communications and IWN for 
the department. 

[12] The Office of the Chief Information Officer was originally 
responsible for the IWN program at DHS. Since DHS was created, the 
department went through a series of management changes. In May 2007, 
the Office of the Chief Information Officer transferred all management 
responsibilities for IWN to the newly formed Office of Emergency 
Communications, which is currently responsible for IWN. The Office of 
the Chief Information Officer retained authority over spectrum 
allocation for the DHS components. 

[13] The Treasury Wireless Program Office represents the department in 
IWN-related activities. However, while Treasury currently has about 
4,500 agents, the total number of agents and officers who are potential 
radio users among all three departments is over 80,000. 

[14] GAO, First Responders: Much Work Remains to Improve Communications 
Interoperability, [hyperlink, http://www.gao.gov/products/GAO-07-301] 
(Washington, D.C.: April 2, 2007). 

[15] GAO,Homeland Security: Federal Leadership and Intergovernmental 
Cooperation Required to Achieve First Responder Interoperable 
Communications, [hyperlink, http://www.gao.gov/products/GAO-04-740] 
(Washington, D.C.: July 20, 2004). 

[16] [hyperlink, http://www.gao.gov/products/GAO-07-301]. 

[17] [hyperlink, http://www.gao.gov/products/GAO-06-15] and [hyperlink, 
http://www.gao.gov/products/GAO-04-6]. 

[18] Treasury currently has one employee collocated with the DOJ 
Wireless Management Office to facilitate exchange of information. DHS 
does not contribute any staff or resources to the joint program office. 

[19] The Federal Partnership for Interoperable Communications, which is 
sponsored by the OEC, is an organization intended to address federal 
wireless communications interoperability by fostering intergovernmental 
cooperation and identifying and leveraging common synergies. It 
includes 44 federal member agencies and approximately 160 participants. 

[20] 21st Century Emergency Communications Act of 2006, §671 of the 
Department of Homeland Security Appropriations Act, 2007, Pub. L. No. 
109-295 (2006). 

[21] Current proposed membership for the Emergency Communications 
Preparedness Center includes the Departments of Commerce, Defense, 
Interior, Homeland Security, Justice, Treasury, Agriculture, Energy, 
Labor, Health and Human Services, the Federal Communications 
Commission, and the General Services Administration. 

[End of section] 

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