Homeland Defense

National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges Gao ID: GAO-06-498 May 31, 2006

To prepare for potential attacks in the United States involving weapons of mass destruction (WMD), Congress approved the development of National Guard Civil Support Teams (CST) tasked to identify chemical, biological, radiological, nuclear, or high-yield explosive weapons; assess consequences; advise civil authorities on response measures; and assist with requests for additional support. Thus far, 36 of the 55 approved teams have been fully certified to conduct their mission. The National Guard Bureau (NGB) is in the process of establishing, certifying, and planning for the long-term sustainment of the CSTs. GAO was asked to address the extent to which (1) the CSTs are ready to conduct their mission and (2) effective administrative mechanisms are in place for the CSTs.

The established CSTs have thus far been trained, equipped, and staffed and have command and control mechanisms in place to conduct their domestic mission. However, confusion resulting from a lack of guidance on the types of non-WMD missions the CSTs can conduct to prepare for their WMD terrorism mission could impede coordination between state authorities and local emergency management officials on the appropriate use of the CSTs. CSTs were created to focus on assisting civil authorities in domestic WMD events. Based on its review of the CSTs' training, equipment, and staffing criteria; analysis of CST readiness data; site visits to 14 CSTs; and discussions with state, local, and federal responders, GAO found the certified teams visited to be ready to conduct their mission. NGB and the states have a clear structure for operational command and control of the CSTs. Though current NGB guidance and the CSTs' message to state and local officials emphasize the CST mission as being focused on WMD events, some CSTs have responded to non-WMD events, such as providing emergency assistance to the Gulf Coast states after the 2005 hurricanes. While NGB views such missions as useful preparations for WMD events, guidance has not been clarified to reflect the type of non-WMD missions that would be appropriate. This lack of clarity has caused confusion among state, local, and NGB officials, potentially slowing coordination efforts. Also, DOD is proposing a limited role for the CSTs to coordinate and operate with Mexican and Canadian officials in the event of a cross-border WMD incident. DOD and NGB are informally considering limited overseas missions for the teams, though they have no plans to request a further expansion of the CSTs' mission to encompass overseas operations. According to NGB and the CST commanders, some overseas missions could provide valuable experience and have a positive effect on CST readiness, while other, more demanding missions, such as supporting the warfighter, could be detrimental to the readiness and availability of the CSTs. Although NGB continues to develop a long-term sustainment plan for the CST program, going forward, it faces challenges to the administration and management of the CSTs that could impede both the progress of newer teams and the long-term sustainment of the program. NGB has made progress in establishing an administrative management structure for the CSTs, including issuing a broad CST management regulation and initiating a standardization and evaluation program. However, the CSTs face challenges in personnel, coordination plans, equipment acquisition and planning, training objectives, readiness reporting and facilities. Further, insufficient NGB guidance on state National Guard roles and responsibilities for overseeing and supporting their CSTs has resulted in varied support at the state National Guard level. NGB is aware of the challenges and has efforts under way to address them. While these challenges have not yet undermined CST readiness, if NGB efforts are unsuccessful, the progress of newer teams could be impeded and the long-term sustainment of the CST program put at greater risk.

Recommendations

Our 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.

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GAO-06-498, Homeland Defense: National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges This is the accessible text file for GAO report number GAO-06-498 entitled 'Homeland Defense: National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges' which was released on June 30, 2006. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. 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Report to the Chairman, Subcommittee on National Security, Emerging Threats, and International Relations, Committee on Government Reform, House of Representatives: May 2006: Homeland Defense: National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges: GAO-06-498: GAO Highlights: Highlights of GAO-06-498, a report to the Chairman, Subcommittee on National Security, Emerging Threats, and International Relations, Committee on Government Reform, House of Representatives Why GAO Did This Study: To prepare for potential attacks in the United States involving weapons of mass destruction (WMD), Congress approved the development of National Guard Civil Support Teams (CST) tasked to identify chemical, biological, radiological, nuclear, or high-yield explosive weapons; assess consequences; advise civil authorities on response measures; and assist with requests for additional support. Thus far, 36 of the 55 approved teams have been fully certified to conduct their mission. The National Guard Bureau (NGB) is in the process of establishing, certifying, and planning for the long-term sustainment of the CSTs. GAO was asked to address the extent to which (1) the CSTs are ready to conduct their mission and (2) effective administrative mechanisms are in place for the CSTs. What GAO Found: The established CSTs have thus far been trained, equipped, and staffed and have command and control mechanisms in place to conduct their domestic mission. However, confusion resulting from a lack of guidance on the types of non-WMD missions the CSTs can conduct to prepare for their WMD terrorism mission could impede coordination between state authorities and local emergency management officials on the appropriate use of the CSTs. CSTs were created to focus on assisting civil authorities in domestic WMD events. Based on its review of the CSTs‘ training, equipment, and staffing criteria; analysis of CST readiness data; site visits to 14 CSTs; and discussions with state, local, and federal responders, GAO found the certified teams visited to be ready to conduct their mission. NGB and the states have a clear structure for operational command and control of the CSTs. Though current NGB guidance and the CSTs‘ message to state and local officials emphasize the CST mission as being focused on WMD events, some CSTs have responded to non-WMD events, such as providing emergency assistance to the Gulf Coast states after the 2005 hurricanes. While NGB views such missions as useful preparations for WMD events, guidance has not been clarified to reflect the type of non-WMD missions that would be appropriate. This lack of clarity has caused confusion among state, local, and NGB officials, potentially slowing coordination efforts. Also, DOD is proposing a limited role for the CSTs to coordinate and operate with Mexican and Canadian officials in the event of a cross- border WMD incident. DOD and NGB are informally considering limited overseas missions for the teams, though they have no plans to request a further expansion of the CSTs‘ mission to encompass overseas operations. According to NGB and the CST commanders, some overseas missions could provide valuable experience and have a positive effect on CST readiness, while other, more demanding missions, such as supporting the warfighter, could be detrimental to the readiness and availability of the CSTs. Although NGB continues to develop a long-term sustainment plan for the CST program, going forward, it faces challenges to the administration and management of the CSTs that could impede both the progress of newer teams and the long-term sustainment of the program. NGB has made progress in establishing an administrative management structure for the CSTs, including issuing a broad CST management regulation and initiating a standardization and evaluation program. However, the CSTs face challenges in personnel, coordination plans, equipment acquisition and planning, training objectives, readiness reporting and facilities. Further, insufficient NGB guidance on state National Guard roles and responsibilities for overseeing and supporting their CSTs has resulted in varied support at the state National Guard level. NGB is aware of the challenges and has efforts under way to address them. While these challenges have not yet undermined CST readiness, if NGB efforts are unsuccessful, the progress of newer teams could be impeded and the long- term sustainment of the CST program put at greater risk. What GAO Recommends: To ensure the sustainment of CSTs, the Secretary of Defense should work with NGB and the Secretaries of the Army and of the Air Force to clarify the types of non-WMD response efforts that belong in the CST mission; develop guidance to address CST management challenges; and develop guidance and work with state adjutants general to clarify administrative oversight and support structures for CSTs. The Department of Defense (DOD) generally agreed with our recommendations. [Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-498]. To view the full product, including the scope and methodology, click on the link above. For more information, contact Davi M. D'Agostino at (202) 512-5431 or dagostinod@gao.gov. [End of Section] Contents: Letter: Results in Brief: Background: CSTs Are Prepared to Conduct Their Mission, but the Role of Non-WMD Missions Causes Confusion: CST Program Faces Management Challenges That Could Increase Risk to Long-term Sustainment: Conclusions: Recommendations for Executive Action: Agency Comments and Our Evaluation: Appendixes: Appendix I: Scope and Methodology: Appendix II: CST Program Management Efforts: Appendix III: Data Collection Instrument: Appendix IV: Comments from the Department of Defense: Appendix V: GAO Contact and Staff Acknowledgments: Tables Tables : Table 1: Examples of Civil Support Team Section Tasks: Table 2: CST Response Management Plan Sectors: Table 3: Summary of CST Nontraining Deployments, 2001-05: Figures Figures : Figure 1: The Unified Command Suite: Figure 2: The Analytical Laboratory System: Abbreviations: CBRNE: chemical, biological, radiological, nuclear, and high-yield explosive: CERFP: CBRNE Enhanced Response Force Package: CST: Civil Support Team: DOD: Department of Defense: DOTMLPF: doctrine, organization, training, materiel, leadership, and education, personnel, and facilities: NGB: National Guard Bureau: WMD: weapons of mass destruction: May 31, 2006: The Honorable Christopher Shays: Chairman: Subcommittee on National Security, Emerging Threats, and International Relations: Committee on Government Reform: House of Representatives: Dear Mr. Chairman: To help prepare the United States for potential terrorist attacks involving weapons of mass destruction (WMD),[Footnote 1] Congress in 1998 approved the development of federally funded, state[Footnote 2] controlled, National Guard WMD Civil Support Teams (CSTs). The CSTs' principal mission is to assist civil authorities in the United States in responding to incidents involving WMD or catastrophic terrorism, including the use of chemical, biological, radiological, nuclear, or high-yield explosive weapons and agents. The CSTs are to identify these agents and substances, assess current or projected consequences, advise civil authorities on response measures, and assist with requests for additional support. Like traditional National Guard units, the CSTs are under the control of the governors of their respective states and territories, unless they are activated for federal service, at which time they would fall under the control of the Department of Defense (DOD). However, unlike traditional National Guard units, these highly specialized teams are each composed of 22 members who are on full-time duty. The teams include both Army and Air National Guard personnel who are divided into six sections, including command, operations, administration/logistics, medical science, communications, and survey. The teams possess highly technical mobile laboratory and communications equipment to accomplish their mission. Congress initially approved the establishment of 10 CSTs.[Footnote 3] Since 1998, Congress has incrementally increased the number of authorized teams to the currently approved 55: one in each state; a second team in California; and one each in the District of Columbia, Puerto Rico, the Virgin Islands, and Guam. DOD established the stationing plan for the CSTs in five phases. The National Guard Bureau (NGB), the managing organization for the CSTs, executed the establishment, certification, and sustainment program for the teams. Phase one comprised 10 teams; phase two 17 teams; phase three 5 teams; phase four 12 teams; and phase five 11 teams. Each team must be certified by the Secretary of Defense as capable of conducting its mission. To accomplish this, each team must complete a battery of individual and team training, receive all its authorized equipment, achieve full staffing, pass an external evaluation by Army experts, and apply (via its state adjutant general) to the Secretary of Defense for certification. Thirty-six teams have been certified as of May 2006; the remaining 19 will be certified by the end of fiscal year 2007. The approximate cost for establishing all 55 teams is $424 million, and it costs approximately $3.4 million annually to sustain each team. The challenges DOD faces in managing its reserve forces and allocating its resources across services and programs are some of the many issues that we highlighted for Congress as the nation entered the 21st century. For example, we issued a report in November 2004 that recommended the establishment of readiness standards and measures for the National Guard's homeland security missions.[Footnote 4] In 2001, the DOD Inspector General highlighted a number of structural and management problems with the CST program, including the standards for certification and readiness of the teams as well as other problems that may impede the CSTs from conducting their mission. We examined the operational readiness of the Army National Guard's WMD CSTs. Our objectives were to address (1) the extent to which the CSTs are ready to conduct their mission and (2) the extent to which there are effective administrative mechanisms in place for the CSTs. To address these objectives, we reviewed the readiness criteria and categories for the two systems used to track CST readiness.[Footnote 5] We also incorporated these criteria into our questions as we designed and distributed a broad data collection instrument to all 55 CSTs to collect information regarding the status and availability of CST equipment, training and certification, mission, coordination, and personnel. We received complete responses from 52 CSTs. Further, we supplemented this information with visits to 14 CSTs, and we conducted interviews with state National Guard personnel as well as with local, State, and federal officials who currently or will potentially work with CSTs. In preparing the data collection instrument, we tested the reasonableness of our questions in discussions with the commanders of two CSTs not included in our 14 site visits. During several of our site visits, we observed exercises, an external evaluation, and other training events. We also compared the information collected during our visits, including interviews; after-action reports; and existing command, control, and coordination mechanisms, with policies and the expectations of officials with whom the CSTs must work in the states. We selected the site-visit sample to comprise a wide distribution of states and territories based on such criteria as geographic distribution, age of team, certification status, state size, and population. Additionally we collected cost data related to the establishment and sustainment of the CSTs from NGB, state National Guard personnel, and the CSTs themselves. We did not independently verify cost data, but we interviewed NGB officials who manage the data about data quality control procedures. We determined the data were sufficiently reliable for the purposes of this report. Further details on our scope and methodology appear in appendix I. We performed our work from April 2005 through March 2006 in accordance with generally accepted government auditing standards. Results in Brief: The certified CSTs have thus far been ready to conduct their mission in terms of having the training, equipment, and staff required of them, and the teams have a functioning command and control structure. However, confusion resulting from a lack of guidance on the types of non-WMD missions the CSTs can conduct to prepare for their WMD terrorism mission could impede coordination between state authorities and local emergency management officials on the appropriate use of the CSTs. Congress authorized the creation of the CSTs for the primary purpose of assisting civil authorities in responding to domestic incidents involving WMD. Based on our review of the CSTs' training, equipment, and staffing criteria; data we collected for the CSTs in all three areas; our site visits to 14 CSTs; and our discussions with state, local, and federal responders who have worked with those teams, we found the certified teams we visited to thus far be ready to conduct their mission. NGB and the states have a clear structure for operational control of the CSTs, including procedures for who can authorize CST deployment, to whom they should report at an incident scene, and when command authority shifts because of a federalized effort. State and local officials we interviewed reported that the command and control of the teams is well understood and exercised. Though the CSTs' mission is focused on WMD events, and the CSTs emphasize this focus when coordinating with state and local emergency management officials, some CSTs have responded to non-WMD events, such as providing emergency assistance to the Gulf Coast states after the 2005 hurricanes. Beyond the benefits they provide to civil authorities, the CSTs use such missions to prepare for responding to a WMD event. However, the lack of clarity and guidance on what types of non-WMD operations the CSTs should use to prepare for a WMD response, as well as the desire of civil authorities to call upon the teams for other emergencies, is causing confusion among state, local, and National Guard officials about the appropriate use of the CSTs. This potentially slows coordination between local and state responders and the CSTs and coordinated NGB-level responses involving multiple CSTs. Also, DOD is proposing a limited role for the CSTs to coordinate and operate with Mexican and Canadian officials in the event of a cross-border WMD incident. DOD and NGB are also informally considering limited overseas missions for the teams, though they have no plans to request a further expansion of the CSTs' mission to encompass overseas operations. According to NGB and the CST commanders, some overseas missions could provide valuable experience and have a positive effect on CST readiness, while other, more demanding missions, such as supporting the warfighter, could be detrimental to the CSTs. Although NGB continues to develop a long-term sustainment plan for the CST program, going forward, it faces challenges to the administration and management of the CSTs that could impede both the progress of newer teams and the long term sustainment of the program. As the managing authority for the CST program, NGB has made progress in establishing an administrative management structure for the CSTs, including issuing a broad CST management regulation and initiating a standardization and evaluation program. However, NGB also faces challenges to the CSTs in such areas as staffing, coordination plans, equipment maintenance and acquisition, training and exercise oversight, readiness reporting, and facilities. Further, NGB guidance explaining state National Guard roles and responsibilities for overseeing and supporting their CSTs is insufficient to fully inform the states about the unique nature and requirements of the CSTs and how to integrate such a unit into the state National Guard command structure. The result has been varied and generally problematic oversight and support of CSTs at the state level in such areas as staffing and equipment augmentation and designing and building the facilities to house the teams. According to CST members and NGB officials we interviewed, these challenges have yet to harm readiness, and NGB officials recognize the importance of these challenges and have individual initiatives to address many of them. If NGB's efforts are not successful, the challenges could, in the long run, impede the progress of newer teams and compromise the long-term sustainment of the CST program. This report makes recommendations to help DOD and NGB address management challenges and further its efforts to sustain the CST program. We are recommending that DOD work with NGB and the Army and Air Force to clarify the domestic CST mission, develop guidance to address management challenges, and create a clear and effective administrative support structure at the state level. In comments on a draft of this report, DOD generally agreed with our recommendations and described steps it is taking or will take to implement them. Background: In response to an increase in the threat of potential terrorist attacks in the United States involving WMDs, Congress directed the federal government to enhance its capability to deter, prevent, respond, and recover from terrorist attacks using such weapons.[Footnote 6] Among the resulting efforts, Congress in fiscal year 1999 approved the development of National Guard WMD CSTs.[Footnote 7] The CSTs are designed to support civil authorities in the event of a domestic WMD event by identifying WMD agents and substances, assessing current and projected consequences, advising on response measures, and assisting with appropriate requests for additional support. In describing WMD agents, DOD commonly uses the term chemical, biological, radiological, nuclear, and high-yield explosives (CBRNE). Like traditional National Guard units, the CSTs are under the day-to-day control of the governors of their respective states and territories. The CSTs can also be activated for federal service by the President, at which time they would fall under DOD command. Unlike traditional National Guard units, which generally consist of part-time soldiers who conduct regular drills, the CSTs are composed of full-time Army and Air National Guard members. Each 22-person team is divided into six sections: command, operations, communications, administration and logistics, medical/ analytical, and survey. The members of the CSTs are trained in their various disciplines and operate sophisticated equipment that helps them accomplish their mission. Table 1 shows examples of some of the tasks associated with each CST section. Table 1: Examples of Civil Support Team Section Tasks: Section: Command; Number of personnel: 2; Examples of tasks: * Provides command and control of the team; * Interfaces with external agencies and organizations; * Provides advice to the first responder community; * Facilitates introduction of follow-on DOD forces into a consolidated response team; * Ensures that sample collection and handling procedures are conducted safely and are accurately documented and the chain of custody is maintained. Section: Operations; Number of personnel: 4; Examples of tasks: * Conducts hazard modeling; * Provides information for vulnerability analysis; * Coordinates and directs CBRNE surveys; * Coordinates and monitors unit training; * Prepares site safety and incident action plans. Section: Medical/ analytical; Number of personnel: 4; Examples of tasks: * Establishes and maintains medical surveillance and monitoring programs for the unit; * Conducts lab analysis of incident- related samples; * Conducts medical reach-back coordination with medical labs; * Secures and prepares samples for transport and subsequent transfer; * Provides emergency medical stability for CST members. Section: Communications; Number of personnel: 2; Examples of tasks: * Provides voice and data communications through a variety of networks designed to support CST operations; * Maintains communications within the team, with higher headquarters, with other responding agencies, and with subject matter experts; * Establishes secure communications links, as required. Section: Survey; Number of personnel: 8; Examples of tasks: * Conducts missions in appropriate protective equipment; * Enters a suspected hot zone to conduct search for CBRNE hazards; * Collects and preserves incident-related samples for delivery to analytical equipment; * Identifies, marks and reports contaminated areas. Section: Administration and logistics; Number of personnel: 2; Examples of tasks: * Sustains the ability of the CST to conduct operations; * Maintains logistics status reports; * Procures and stores unit equipment according to command guidance. Source: DOD. [End of table] The CSTs employ military-provided equipment that is common to active duty military units, such as chemical defense equipment and uniforms. They also use a large variety of specialized commercial equipment, such as the protective ensembles worn in the hazard zone and much of the teams' laboratory equipment. The CSTs employ several vehicles for transporting and supporting the six sections of the team. Among these are two specially constructed vehicles: the Unified Command Suite, which contains a wide range of radio, data, and video communications equipment, and the Analytical Laboratory System, which contains such equipment as a gas chromatograph/mass spectrometer for organic material analysis and a gamma spectrometer for radiological material analysis as well as other laboratory support equipment. Figures 1 and 2 show the Unified Command Suite and the Analytical Laboratory System, respectively. Figure 1: The Unified Command Suite: [See PDF for image] Source: DOD. [End of figure] Figure 2: The Analytical Laboratory System: [See PDF for image] Source: GAO. [End of figure] The equipment in the Analytical Laboratory System helps the CSTs conduct a "presumptive identification" of a CBRNE sample. If requested by the incident commander, the CST then transfers a sample to a Centers for Disease Control and Prevention-approved laboratory for confirmation and official identification. NGB is responsible for managing the CST program and is the principal channel of communication between DOD and the adjutant general commanding the National Guard unit in each state. NGB also coordinates with other DOD commands and organizations to support various aspects of the CST program. For example, the joint service Chemical and Biological Defense Program conducts the acquisition process for much of the CST equipment, and the Army's Maneuver Support Center assists in developing CST doctrine and conducting key CST-specific training. The Secretary of Defense must certify each CST as ready to execute its WMD mission.[Footnote 8] This certification involves a series of staffing, equipping, and training steps that take from 18 to 24 months. To achieve certification, each CST must complete the following steps: 1. Have the required personnel and equipment resources and be trained to undertake the full mission for which it is organized or designed. For example, at least 85 percent of assigned personnel must have completed all of their CST-specific individual training. 2. Undergo an external evaluation by Army experts according to the CST's approved mission training plan. 3. Notify its adjutant general that it has completed the above steps, whereupon the adjutant general submits a request for certification to NGB, which then reviews and forwards the request to the Army Staff and to the Assistant Secretary of Defense for Homeland Defense.[Footnote 9] The Secretary of Defense makes the final determination of approval for CST certification. Although certification is a onetime event, a CST that loses a significant number of key personnel associated with command and control or with medical and assessment capabilities that substantially degrades the team's ability to conduct its mission must undergo a revalidation process. In addition, each CST undergoes an external evaluation every 18 months, during which Army experts assess each team's ability to meet specific mission standards associated with all related WMD threats. Both civil and military responders, including the CSTs, conduct WMD response operations in a three-tiered approach based on the National Response Plan and the National Incident Management System. The National Response Plan represents a comprehensive all-hazards approach intended to enhance the ability of the United States to manage domestic incidents. Fire and rescue, law enforcement, and emergency medical personnel constitute the first tier. If the extent of the event exceeds the ability of the first tier to manage the consequences of the situation, the state-level civil and military forces may be activated and deployed as the second tier. If the governor determines that the forces and resources available in the state require additional support, then the governor may request assistance from the President of the United States, constituting the third tier. The CSTs are generally included in the second tier of the response. In addition to preparing to respond to WMD and catastrophic terrorist events in their respective states, the CSTs also adhere to NGB's Response Management Plan. Under this plan, NGB monitors the readiness status of each certified CST to ensure that at a given time, a designated number of CSTs are always ready to respond to a national need or the need of a state without an available CST. To facilitate planning for such responses, the plan divides the nation into six response sectors, as shown in table 2. Table 2: CST Response Management Plan Sectors: Response sector: 1; States or territories: Pennsylvania, New Jersey, New York, Connecticut, Rhode Island, Massachusetts, New Hampshire, Vermont, and Maine. Response sector: 2; States or territories: West Virginia, Virginia, District of Columbia, Maryland, Delaware, Illinois, Indiana, Ohio, Michigan, and Wisconsin. Response sector: 3; States or territories: Alabama, Georgia, South Carolina, North Carolina, Tennessee, Kentucky, Florida, Puerto Rico, and the U.S. Virgin Islands. Response sector: 4; States or territories: Louisiana, Texas, Oklahoma, Arkansas, Kansas, Missouri, Minnesota, Iowa, and Mississippi. Response sector: 5; States or territories: New Mexico, Arizona, California, Nevada, Utah, Colorado, Hawaii, and Guam. Response sector: 6; States or territories: South Dakota, North Dakota, Wyoming, Montana, Idaho, Washington, Oregon, Alaska, and Nebraska. Source: National Guard Bureau. [End of table] Under the Response Management Plan, the CSTs are scheduled on either "bronze," "silver," or "gold" status on a rotating basis. At any given time one certified team per response region is in gold status and must be ready to deploy a full CST (personnel and equipment) within 3 hours from its home station to an incident site within its region, should the need arise. At the same time, another certified team per response region is placed in silver status. While this team is in a slightly lower state of readiness it must be prepared to assume gold status in the event the gold team is deployed. The remaining certified teams are in bronze status and are focused more on training, block leave, equipment preparation, and state-directed missions. Bronze teams must, however, be prepared to respond to incidents within their region within 72 hours and to assume silver or gold status within 48 and 96 hours, respectively. Because the CSTs are state-controlled units, the respective governors are the final deployment authority for CST missions and, unless the CSTs are federalized, they remain under the command authority of the governors and state adjutants general. The CSTs generally conduct three types of mission: response, stand-by, and assist. Response missions are deployments in support of requests from local, state, or federal agencies, such as a CST deployment to help civil authorities identify a potentially toxic chemical left by a suspected terrorist. Stand-by missions involve providing CST expertise at special events, such as the national political conventions. Assist missions include a range of CST involvement, including technical assistance, reconnaissance, or assistance with CBRNE vulnerability assessments. For example, CST commanders and team members may provide technical assistance by phone to a local incident commander at a hazardous materials scene. Table 3 summarizes deployments of the CSTs for missions other than training exercises. Table 3: Summary of CST Nontraining Deployments, 2001-05: Mission type: Response; Number: 405; Percentage of missions: 8. Mission type: Stand-by; Number: 580; Percentage of missions: 11. Mission type: Assist; Number: 4,109; Percentage of missions: 81. Mission type: Total; Number: 5,094; Percentage of missions: 100. Source: GAO. [End of table] As shown in table 3, CSTs deployed on response missions far less often than on stand-by and assist missions. The table does not show total activity by the CSTs, since the majority of their time is devoted to training in order to maintain individual and team readiness. It also may not reflect all CST deployments to assist in states affected by hurricanes in 2005. Each CST costs approximately $7.7 million to establish, or approximately $424 million to establish all 55 CSTs. This cost estimate includes initial equipment, vehicles, personnel, and training support. Sustaining each CST in these categories costs approximately $3.4 million a year, or $189 million a year to sustain all 55 teams. DOD funds the establishment and sustainment of the CST program and NGB manages most of this funding. These estimates do not include utilities for CST facilities, which are paid by the states via a general calculation of all state facilities requirements and funded through NGB. The estimates also do not include federally funded costs for construction of CST facilities, since these costs vary widely depending on how and where the states decide to station their teams. There are also additional federal costs associated with the CST program that are not associated with the specific teams themselves. For example, approximately $65 million for fiscal year 2006 is associated with the following categories: * funding for CST airlift; * various CST-unique training courses; * equipment replenishment and modifications; * maintenance of secure Internet access for CSTs; * government-owned vehicles; * communications links; * Unified Command Suite maintenance and support; * civilian personnel involved in CST oversight functions; and: * U.S. Army personnel whose mission is to evaluate, train, and develop doctrine for CSTs. NGB is also in the process of creating additional units meant to follow CSTs in response to WMD events and to be part of larger National Guard response forces. The mission of the 17 currently authorized National Guard CBRNE Enhanced Response Force Packages (CERFP) is to support local, state, and federal agencies managing the consequences of a CBRNE event by providing capabilities to conduct personnel decontamination, emergency medical services, and casualty search and rescue. Each CERFP comprises approximately 186 personnel taken from existing Army and Air National Guard medical, engineer, chemical, and other units. Unlike CST members, CERFP personnel do not serve in their units on a full-time basis but rather must be mobilized for duty. Like CSTs, however, CERFPs are intended to be part of the state response to a WMD incident and can also be federalized and placed under DOD authority. CSTs Are Prepared to Conduct Their Mission, but the Role of Non-WMD Missions Causes Confusion: Based on the CSTs' readiness measures for staffing, training, and equipment; the data we obtained from the CSTs on each of these measures; the process NGB has in place to maintain and monitor CST readiness; and the discussions we had with CSTs and state, local, and federal officials in the 14 states and territories we visited, we found that the certified CSTs have thus far been trained, equipped, and staffed to conduct their mission. Further, NGB, DOD, and the states have guidance in place for operational command and control of the CSTs, specifying how and when teams will operationally respond to a WMD event. However, confusion about the types of non-WMD missions the CSTs conduct to help them prepare for WMD missions could impede coordination between state, local, and federal officials about the appropriate use of the CSTs. Certified CSTs Are Ready to Perform Their Mission: The certified CSTs have thus far had the staff, equipment, and training they need to conduct the mission that Congress intended for them. Staffing, equipment, and training data we collected from 52 of the 55 CSTs in late 2005 confirmed this state of readiness, as did the discussions we had with CST personnel in the 14 states and territories we visited and state National Guard command staff, CST program managers at NGB, and state and local emergency responders. Additionally, NGB has a clear plan to maintain, monitor, and periodically evaluate the teams' overall readiness. For example, for the certified CSTs we visited, in addition to fulfilling initial certification criteria that established strict standards for staffing, equipment, and training readiness, these teams have passed the external evaluations they are required to undergo every 18 months and have continued to prepare and execute training and exercise plans to maintain their readiness. Based on our review of the mission and training standards for the CST program and our interviews and observations of CST personnel during our site visits, we found CST members to be motivated soldiers who have mastered complex technical tasks and can perform them under duress. The teams we visited reported that they maintain high morale in spite of the training pressures, the need for around-the-clock availability, and the added burden of training to perform the duties of other positions on the team so that the CST will have added depth and flexibility. Their fitness regimen is designed to keep them in superior physical condition, allowing them to perform in physically challenging response environments for an extended time. For example, teams are trained to conduct their work in fully contained protective suits and masks while carrying their own oxygen supply tanks on their backs. This is physically challenging even in moderate climate conditions. CST personnel are prepared for their mission through a regimen of individual training that varies from 376 to 1,148 hours in the first 2 years, depending upon the duty position. The teams complete an initial external evaluation in order to obtain DOD certification, and they undergo a similar evaluation every 18 months thereafter. The teams are required to conduct 12 collective training events each year to help them develop and maintain the skills necessary to complete the WMD response tasks outlined in the CST's Mission Training Plan. NGB further monitors the 55 CSTs through two readiness reporting databases that inform NGB as to how well teams are meeting basic readiness criteria and provide detailed information on their personnel, equipment, and training status. One of these systems is a primary mechanism for NGB's administration of the Response Management Plan. DOD assesses the teams' proficiency in their critical tasks through external evaluations administered by U.S. Army subject matter experts. We observed an external evaluation for a phase one CST that required the team to locate and identify small amounts of chemical, biological, and radiological substances hidden inside a large warehouse, and it was able to do this successfully. Following the event, the Army experts and the CST members held an after-action review during which they discussed and assessed the team's performance in critical mission areas, highlighting processes and procedures that worked well and those that required improvement. Army experts administer external evaluations to each CST every 18 months to assure both DOD and NGB of the team's continued readiness. In response to our data collection instrument, 94 percent of CST commanders characterized external evaluations as an accurate indicator of their readiness. Some CST commanders who responded to our data collection instrument said the evaluations were good measures of the basic readiness of the teams to conduct their mission but did not adequately assess teams for their ability to interact with and support a civilian incident commander while at a site in company with multiple other local, state, and possibly federal authorities. CST members told us that a multiple-agency incident response site will be the normal circumstance for an actual CST WMD mission. In addition to the external evaluations, the CSTs conduct a number of exercises every year that involve other civil responders with which they would work in the event of an actual WMD response. CST members and state, local, and federal officials we met with reported that these exercises are invaluable for helping all stakeholders understand each other's capabilities and how best to work together. Emergency responders and state officials who work with CSTs in the states and territories we visited gave generally positive reviews of the teams. Reflecting mostly on their experience with the CSTs in exercises and other coordinating venues, state and local officials we interviewed reported a high degree of confidence in the readiness of the CSTs to conduct their mission. They also reported that the CSTs' ability to provide on-scene initial identification of CBRNE substances, along with their communications capability, exceed that of most civilian response teams and are vital assets for WMD response in their states. Mechanisms Are in Place for CSTs to Operationally Respond to Missions: NGB, DOD, and the states have guidance in place for operational command and control of the CSTs, specifying how and when teams will operationally respond to a WMD event. The basis of CST operational deployment guidance is the National Response Plan and the National Incident Management System.[Footnote 10] States and territories we visited were in the process of updating their emergency response plans, and these plans identify the state National Guard's role, and sometimes specifically the CST role, in the response. State officials acknowledged that their plans were being revised to conform to the National Response Plan. Officials in states and territories we visited expressed a need to become better organized to address homeland security and WMD threats. CSTs have successfully tested their command and control structures by deploying to response, stand-by, and assist missions under the authority of their respective state governors and adjutants general. To practice operational command and control, the CSTs also participate in various training exercises with federal, state, local, and nongovernmental agencies and organizations. Evaluation data on these missions and exercises are limited and often informal. However, the information available indicates that CSTs met NGB, state, and local expectations about coordination command and control, and comments by state and local officials we interviewed were overwhelmingly positive. In addition to operations within their states, CSTs have sometimes deployed outside their state based on requests for assistance. In these cases, the CSTs come under the command and control of the governors and adjutants general of the states in which they are operating. The CSTs have also been deployed to other states based on NGB requests that they respond to an event or disaster. For example, NGB managed the deployment of the CSTs to states affected by hurricanes in 2005 using the Response Management Plan to maintain enough teams in a high state of readiness in each response region. According to after-action reports on these events and comments from officials we interviewed during our site visits, the CSTs were integrated into the operational command and control of state military commands in the Gulf states, reported to incident commanders when responding to specific events, and performed their duties according to the response plan. DOD also has guidance in place for operational command and control of the CSTs in the event the teams are federalized. In such an event, the CSTs would come under the command of DOD's U.S. Northern Command. To date, no CSTs have been federalized. Role of Non-WMD Missions Causes Confusion: While the CSTs principally focus on responding to WMD and catastrophic terrorist attacks,[Footnote 11] some CSTs are preparing for this mission by responding to non-WMD events, causing confusion among civilian as well as National Guard officials about when the CSTs should and should not be employed. This confusion results from a lack of clear guidance interpreting the legislation that establishes the CST mission to "prepare for or to respond to" WMD or terrorist attacks[Footnote 12] and from DOD's use of the term chemical, biological, radiological, nuclear, and high-yield explosives (CBRNE) in its characterization of the CSTs' official mission. In a 2004 memo, the NGB's Deputy Director for Domestic Operations advised all state National Guard headquarters that approve missions for their respective CSTs to ensure that their teams responded only to intentional uses of WMD, to terrorist attacks, or to threatened terrorist attacks. He cautioned that the military's formal definition of CBRNE included unintentional events, such as accidental hazardous materials spills, that were outside the scope of the CSTs' mission. As part of their coordination efforts with state and local emergency management officials, CST members highlight the WMD and catastrophic terrorism mission limitation of the CSTs. While CST commanders and team personnel accepted this formal limitation on their mission, they also reported that it is sometimes necessary for mission readiness purposes to respond to events that have no connection to WMD or terrorism. For example, 61 percent of CST commanders who responded to our data collection instrument consider it to be part of their respective CST's mission to respond to CBRNE incidents that are known to be the result of accidents or acts of nature--that is, to incidents that are not attacks. Additionally, 92 percent of commanders who responded thought that this type of response should be part of their mission, and many of those with whom we met endorsed responding to non- CBRNE events as well. CST commanders value non-WMD and nonterrorism responses for a variety of reasons, and NGB officials agreed. Deployments to actual incidents, regardless of the cause, can function as a valuable means of exercising the CSTs' core capabilities, such as communication and coordination with state, local, and federal responders and authorities, and help CSTs prepare for responses to incidents that are WMD related. Moreover, CST commanders and other officials explained that it is often difficult to determine the cause of a destructive event until the CST arrives on scene--only then can the possibility of terrorism be conclusively dismissed. The Hurricane Katrina response provides a recent example of CST deployments that were not directly related to WMD or terrorism but provided CSTs with real-life opportunities to exercise their capabilities to respond to WMD events. Following an NGB request, 18 teams sent personnel and vehicles to assist in the response effort. This assistance, often in the form of satellite communications capabilities, enabled local authorities to coordinate with each other as well as with state and federal officials. For example, one southeastern CST sent personnel to establish a communications outpost just outside the Louisiana Superdome. According to NGB officials, there were lengthy discussions about whether these types of responses were appropriate CST missions. They ultimately concluded that response to large-scale disasters like Katrina were within the CSTs' mandate to prepare for or respond to WMD or terrorism events. The use of CSTs for missions that do not involve catastrophic terrorist acts or WMD, as well as deployment criteria that can differ across 54 state and territorial governments, can lead to confusion at the local level and the potential for unmet expectations. Local responders we met in the 14 states and territories we visited reported that they value the CSTs' expertise and capabilities and think that they can be put to wider use within their communities, although they recognized the need to protect the CSTs from overuse. But there remains no guidance that would assist CSTs or state and local officials in understanding what types of non-WMD missions are appropriate for the CSTs to conduct in preparing for their WMD terrorism mission. As a result, the parameters of allowable CST missions vary across states and among state civilian authorities, state National Guard headquarters staff, CST commanders, and others involved in approving CST missions. For example, some states did not acknowledge NGB's requests for use of their CSTs for hurricane response operations, and at least one state refused to allow its team to participate. Following the destruction of the space shuttle Columbia in February 2003, multiple CSTs were involved in collecting debris across five states; but some state authorities and CST commanders declined to assist because they did not consider it to be a legitimate deployment. Further, in their responses to our data collection instrument, 59 percent of CST commanders recognized a need for their CSTs to provide operational support to local hazardous materials teams prior to those teams' deployment to an incident scene, while 41 percent did not. Seventy-eight percent of commanders who responded identified a need to support hazardous materials teams during the response itself, while 22 percent did not. NGB officials acknowledged that while the conduct of non-WMD specific operations by the CSTs is a valuable way for the teams to satisfy their mission to prepare for or respond to WMD or catastrophic terrorist attacks, some confusion results among the CSTs and state and local officials. They also acknowledge that NGB needs to work with DOD to clarify the types of missions that are appropriate for CSTs to perform as part of the preparation to respond to a WMD or catastrophic terrorist attack. A February 2006 report by the White House on lessons learned from the Hurricane Katrina operations recommended that the option of expanding the role of CSTs to an all-hazards approach should be explored.[Footnote 13] Further, DOD has requested that Congress expand the CSTs' mission to include man-made and natural disasters. If the types of such non-WMD missions in which the CSTs participate are not made clear, this could exacerbate confusion at the state and local levels about the mission of the CSTs. DOD Plans to Expand Role of CSTs Outside the United States: The CSTs are currently limited to conducting operations within the borders of the United States and its territories. However, DOD has requested that Congress allow CSTs to operate in conjunction with officials in Mexico and Canada in order to help accomplish their mission in states bordering these countries. CST members and NGB and DOD officials also told us that there have been informal discussions within DOD regarding a range of potential overseas operations for CSTs, including training, cooperative programs with foreign countries, prestaged support missions, as well as possibly direct support to the warfighter. However, DOD officials could not identify for us whether there is a validated requirement for CSTs to operate overseas, and they told us they have no plans to request a further expansion of the CST's mission to encompass overseas operations. Legislation governing the CST program specifically prohibits the CSTs from conducting operations outside the borders of the United States or its territories.[Footnote 14] This law emphasizes this restriction by requiring that any request by the Secretary of Defense for a legal change be submitted with a justification for the request and a written plan to sustain the CSTs' capabilities. Regulations detailing the composition, management, training, and doctrine of the CSTs explicitly define the CST mission as supporting civil authorities at a domestic CBRNE incident site, whether the CSTs are operating in a state or federal status.[Footnote 15] DOD has requested that Congress allow CSTs to coordinate and operate with Mexican and Canadian officials in the event of a cross-border WMD incident. The CSTs in border states are currently not permitted to conduct exercises and coordination that involve cross-border movement, which may limit their effectiveness in planning for WMD events in their regions. Therefore, the legislative change DOD proposed could improve the effectiveness of state WMD emergency planning. DOD officials said that the CSTs would be federalized in order to conduct operations across the border. Some CST members we spoke with during our site visits said they would like to engage in training outside the United States in order to exploit unique or superior training opportunities. For example, several CSTs expressed a desire to train at facilities such as the Defense Research and Development Center in Alberta, Canada, in order to undergo live-agent training, which several CST members told us would significantly enhance their training and exercise efforts. They also pointed out that the U.S. Marine Corps' Chemical and Biological Incident Response Force has trained at the Canadian facility and greatly benefited as a result. CST members with whom we spoke said that permitting the CSTs to train at superior or unique facilities in other countries could increase their knowledge, skills, and experience, better preparing them to execute their mission. DOD and NGB are also informally considering such limited overseas missions as assisting foreign nations in developing CBRNE response teams similar to the CSTs and prepositioning CSTs at international events, such as the Olympics, to help provide critical monitoring and response support. CST commanders with whom we spoke told us that limited overseas roles for CSTs, such as foreign assistance and prestaged support missions, may provide them valuable experience and therefore have a positive effect on CSTs' readiness to perform their stated mission. During the course of our work, we heard from NGB and DOD officials and some CST commanders that NGB and DOD have also informally considered even more demanding overseas missions for the CSTs, including assisting warfighting forces in such places as Iraq and Afghanistan. DOD officials could not identify for us whether a validated requirement exists for any of these more expansive overseas missions, and they told us that they have no plans to request that Congress expand the CSTs' mission to encompass them. Should such overseas missions be contemplated in the future, however, our review of CST capabilities, along with our discussions with CST members, indicates that support to the warfighter in places like Iraq and Afghanistan is not practicable because of inappropriateness of the CSTs' commercial-grade equipment for use in austere conditions. Further, such operations would likely have a negative effect on CST readiness and availability, drawing much more heavily on existing CST equipment and personnel and reducing states' access to CSTs, a critical component of the domestic WMD response infrastructure. CST Program Faces Management Challenges That Could Increase Risk to Long-term Sustainment: NGB has made progress in establishing an institutional management approach to sustain the CST program once all 55 teams are certified. However, NGB faces several challenges to the program in such areas as staffing, coordination planning, equipment maintenance and acquisition, training and exercise oversight, readiness reporting, facilities, and varying state oversight and support of their CSTs. Although these challenges have not yet affected the overall readiness of the CSTs, if the current efforts to address them are unsuccessful, they could impede the progress of the newer teams and increase the risk to the long-term sustainment of the program. NGB Is Pursuing Institutional Management Efforts: NGB recognizes that the CST program--with 19 teams not yet certified-- is still in the development process. In seeking to fully establish and sustain the CST program, NGB has made progress in developing institutional mechanisms that should facilitate standardization and continuous improvement within individual CSTs and across the program as a whole. For example, NGB's CST standardization program is an attempt to establish a baseline level of interoperability among all CSTs in critical areas, such as training, logistics, personnel administration, and budgeting. One of the CST program managers responsible for developing the standardization program explained that it was initiated to ensure total program oversight and accountability for the CSTs and to assist the states in their CST oversight responsibility. Under the standardization program, NGB will evaluate each CST every 18 months. This evaluation will be coordinated with state-level command inspections that the Army requires. Program personnel have completed a series of test visits to uncertified CSTs, and NGB expects to begin formal evaluative visits in May 2006. NGB has also issued a CST regulation that details the processes and procedures for CST management.[Footnote 16] One of the CST program managers described the regulation as a desk reference guide for state officials as well as for the CSTs themselves. It clarifies CST operations in many areas, including mission requests and validation, command and control, personnel and administration, reporting requirements, funding, and certification. Other general management efforts NGB has led or helped coordinate include the following: * The recent consolidation of Army-directed training and external evaluation responsibilities for the CSTs. This should facilitate progress and consistency across the program in terms of collective training and external evaluations. * Establishment of working groups at both the CST and program management levels to facilitate improvements in doctrine, organization, training, materiel, leadership and education, personnel, and facilities for the CST program. * Development and oversight of doctrine and other guidance to assist the establishment of the 55 CSTs.[Footnote 17] In creating this doctrine and guidance, NGB and the Army organization responsible for writing the doctrine have sought to incorporate lessons learned by the teams from the first few phases of the program as they established themselves in their respective states and territories. Further information on DOD management efforts related to the CSTs can be found in appendix II. CSTs Struggle to Fully Staff Teams: NGB faces several challenges to the CST program that could impede the progress of the newer teams as well as hinder the long-term sustainment of the CST program. One challenge is that CSTs struggle to maintain their official allotment of 22 fully trained, mission-capable personnel because of turnover, team structure, and retention challenges. NGB officials reported that CST positions exhibit an annual turnover rate of 25 to 35 percent. This is due to team members departing after their tours are complete, dismissal of team members for a variety of reasons, and reassignments within teams to replace departed personnel. After vacant positions are filled, new CST members are away from their teams for the first year, satisfying training requirements. Once they return they must be integrated into the team's collective exercises and other existing operations. As a result, CSTs sometimes conduct their missions with less than full unit strength, and 75 percent of CST commanders responding to our data collection instrument reported that the ability of CSTs to perform their mission is adversely affected by the lack of available personnel because of training, leave, and other manpower issues. However, the commanders also said that their teams remain ready to conduct their mission, reporting, for example, that a CST can perform its mission with less than 22 people as long as other members of the team can substitute for a gap. The CST structure also creates a staffing challenge because few of the advanced military occupational specialties on the team are represented by more than one person. For example, the nuclear medical science officer, who is responsible for operating the CST's mobile laboratory and is critical to the CST's ability to identify CBRNE substances, is the only member of the team with that special skill. Likewise, there is a single physician's assistant and a single modeler assigned to each team. If these or other highly technical positions remain vacant for an extended period, the team must rely upon cross-trained personnel within the team or borrow key personnel from other teams. Seventy-nine percent of CST commanders responding to our data collection instrument reported that this lack of depth among key personnel adversely affects the team's ability to perform its mission. Additionally, 88 percent of commanders who responded report that there are too few duty positions in the team's eight-member survey section. CST commanders reported to us that the survey teams should have more people and that responding with too few personnel restricts a CST's ability to make multiple entries into an incident scene in search of suspected CBRNE substances, degrades its ability to remain on scene for long periods without relief, and increases the time required for resolution of an incident. CSTs reported that their teams have still been able to conduct their missions and that cross-training other team members to add depth to various team sections may actually increase their overall capabilities. CST staffing challenges are further exacerbated by recruiting and retention difficulties. When key personnel such as the nuclear medical science officer or physician's assistant depart, the resulting open spots are especially hard to fill because qualified applicants are difficult to attract from the civilian world and are not widely represented within the military. CST commanders and NGB officials explained that the lack of promotion opportunity within the teams was another major factor affecting a soldier's decision to become or remain a CST member, and that career progression is particularly limited for the team's Air Guard contingent. They also listed other factors that frustrate a team's ability to recruit and retain CST members, including the team's substantial training requirements and its full-time alert status for possible deployment. NGB has pursued a number of efforts aimed at addressing these staffing challenges. For example, during live responses, NGB augments the lead CST with additional individuals and sometimes with entire teams. NGB has also been working to fund and conduct a limited operational experiment to validate the CSTs' personnel and equipment list. Recommendations for adjustments to the number of authorized personnel may result from this experiment. In a further attempt to address staffing challenges, NGB is currently compiling the latest turnover data and other relevant personnel information to send to the service secretaries to encourage them to authorize $150 per month incentive pay for CST personnel in accordance with Title 37 United States Code, Section 305(b). Although these efforts may ease some of the staffing challenges discussed above, it is too early to know whether they will fully address them. CSTs Lack Guidance on Conducting Coordination in Their States: Another challenge is that NGB provides little guidance to the CSTs on how they should coordinate with state and local emergency responders and officials, potentially lengthening the amount of time it takes new teams to become incorporated into their home state emergency response infrastructure. CST coordination and outreach efforts vary in nature and scope from state to state, and they include practices such as briefing state and local officials and responders on the mission and capabilities of the CST, developing protocols for working with emergency responders and state officials, participating in training with other responders, conducting exercises with other responders, and offering technical advice to other responders. Established CSTs, state and local officials, and state and local responders have identified CST coordination and outreach efforts as being critical to the success of CST operations. Such efforts increase the CSTs' visibility at the local level, improve responders' understanding of the CST mission (for example, when they can be legitimately deployed), solidify working relationships and open communication between the CSTs and state and local responders, and increase the CSTs' familiarity with the vulnerabilities and strategic targets in all areas of their states. Some CSTs reported a learning curve with respect to conducting successful coordination and outreach. For example, a few CSTs initially did not have good relationships with other emergency responders until outreach efforts clarified the role of the CST as working to support local and state emergency responders. One CST we visited coordinated closely with its state and local partners to prepare a clear set of written protocols and coordination mechanisms that it found to be highly successful. Some state officials reported that their CSTs have not yet developed written coordination protocols for state and local emergency responders, even though responders expressed confusion regarding CST capabilities and mission. NGB has not issued any guidance or requirements regarding the development, implementation, or assessment of CST coordination plans and outreach efforts. NGB has not included such outreach efforts in CST regulations as a mission- essential task, there is no formal system in place for sharing coordination best practices across teams, and there are no requirements to develop written protocols with local and state officials and responders. NGB officials told us that they recognize the importance of coordination and outreach to ensure the success of CSTs in their home states. However, they have not yet considered formal guidance for the teams on the subject. CSTs Face Equipment, Training, Readiness Reporting, and Facilities Challenges: CSTs experience other challenges that NGB recognizes as important, and it has efforts under way to address them. Many of these efforts are new or ongoing, and it is therefore not clear how effective they will be in addressing the specific challenges. While these challenges have not yet affected the CSTs' overall readiness, if the current efforts to address them are unsuccessful, the challenges could threaten the long-term success and sustainability of the program. One of challenges the CSTs face is maintaining and replacing military and commercial equipment at the pace required to sustain CST readiness. CST members told us that they experience varying or poor maintenance support for their military equipment, which is the responsibility of the National Guard in each state. They, as well as state National Guard and NGB officials, told us that the varying degree of state National Guard support stems mostly from the state National Guards' lack of understanding of the unique nature of the CST as a unit as opposed to a more traditional National Guard military unit. CST members reported that maintenance support for their commercial equipment, which is done through the NGB-managed Consequence Management Support Center in Lexington, Kentucky, tends to be better. They also expressed concern that the pace of equipment replacement and development is too slow to ensure that the CSTs have the most relevant equipment available to accomplish their mission and that their existing equipment is updated to prevent its being worn out. NGB officials report that NGB and DOD have heard these concerns from the CSTs and are taking the following steps to address these equipment-related challenges: * NGB is working with the Joint Program Executive Office for Chemical and Biological Defense and the Army Maneuver Support Center to plan for future generations of CST equipment. * NGB Logistics is assessing the cost of each piece of CST equipment and developing new items where appropriate. * NGB Resource Management is requesting an increase in funds in future years to maintain the CST equipment sets. These efforts may help address some equipment challenges, such as adequate equipment update and re capitalization plans, but it is not yet clear whether they will be successful in the near or long term. NGB's standardization program may help the state National Guard organizations provide better maintenance support for the CSTs' military equipment, but it will take time and cooperation between NGB, the CSTs, and their respective state National Guard commands to accomplish this. Another challenge the CSTs face is a lack of oversight and evaluation of exercises required of CSTs each year. Unlike the external evaluations the CSTs undergo before certification and every 18 months thereafter, the 12 or more exercises the CSTs plan for and conduct each year do not follow the same specific set of objectives and criteria and are not evaluated to determine the extent to which those objectives were met. NGB officials told us that they recognize the need for more oversight of these exercises at the NGB and state levels. NGB and DOD have the following efforts under way to help address the lack of exercise oversight and evaluation: * NGB and the Army Maneuver Support Center revised the CST Commanders Pre-Command Course to include instruction on training management. * NGB is incorporating into its ongoing standardization initiative training management components to ensure teams are adhering to Army training regulation. * NGB is bringing a member of the standardization initiative to NGB to assist in training oversight. * DOD is consolidating Army-directed external evaluations and related training responsibilities under U.S. Army North to facilitate progress and consistency across the CST program. These efforts should help NGB and the states better oversee and evaluate the effectiveness of the CST program. However, since many of the initiatives are new, particularly the standardization program, it is not clear how effective they will be. The CSTs use two separate systems to report their readiness measures. CST members we interviewed said that one system, the standard Army readiness system (DOD's Status of Resources and Training System), is ill suited to the unique nature of the CSTs. They also said that while the other system--maintained by NGB--is better suited to the CSTs as a unit, the system requires constant effort by team members to update and involves using secure Internet connections the teams do not always have readily available at their home stations. Many of the CST members we interviewed said that because the two systems overlapped, they should be merged or one should be eliminated. NGB officials explained that the system they maintain is critical for administering the Response Management Plan and is not meant to supplant the standard Army system. They also said that DOD is transitioning to the new Defense Readiness Reporting System. NGB expects the CSTs to replace the two existing systems with the new one in October 2006. This should solve the problem of having two separate readiness reporting systems. However, until the new system is in place and NGB and CST members can evaluate the extent to which it suits the unique nature of the CSTs and helps NGB administer the Response Management Plan, it remains unclear how fully the new system will address this challenge. Finally, some CSTs have reported that their facilities are inadequate in terms of vehicle, storage, and training space. NGB recognizes that some CST facilities are not adequate and has issued revised planning templates for CST facilities to the states. However, as we discuss further below, the varying degree to which states understand how to use these templates and fully meet the needs of their CSTs indicates that the challenge remains to be fully addressed. NGB Lacks Guidance to Help State National Guard Commands Oversee and Support CSTs: NGB has made progress in issuing guidance that explains state National Guard roles and responsibilities for overseeing and supporting their CSTs, but this has been insufficient to fully inform the states about the unique nature and requirements of the CSTs and how to integrate such a unit into the state National Guard command structure. The result has been varied oversight of the CSTs at the state level in important administrative areas and varied support to their CSTs in areas such as staffing and equipment augmentation and designing and building the facilities to house the teams. According to NGB officials and the certified teams we visited, DOD established the first CSTs without the benefit of a great deal of direction and guidance that would help create a unique unit from scratch and incorporate that unit into a state National Guard structure that is unaccustomed to such units. Subsequently, NGB issued its CST management regulation, which listed responsibilities for state National Guard headquarters to exercise fiscal and administrative management and oversight of the CSTs in their states or territories.[Footnote 18] This guidance includes state National Guard responsibility for such CST oversight as issuing training guidance, approving mid-and long-range training plans and objectives, property accountability, and conducting readiness and compliance inspections. While this guidance represents progress in clarifying the roles of NGB and the states in overseeing and supporting the CSTs, it is not as detailed as NGB's guidance on operational command and control and mission-related topics in explaining roles and responsibilities. Although the CST program has been under way for over 7 years, CST members and state National Guard officials with whom we met said the guidance on how the states should integrate the CSTs into their National Guard structures and how CST oversight and support should be conducted is still lacking. NGB officials told us that they recognized that the states have varied widely in how they have integrated the CSTs into their state National Guard structures. They also said they are planning to issue further guidance to clarify how states should integrate their CSTs into the new state Joint Force Headquarters organizations but that they are waiting for these organizations to be fully in place. Because of the lack of clear guidance from NGB on how state National Guard organizations should oversee and support their CSTs, the level and quality of oversight and support for CSTs varies by state. Some states and territories we visited did not have formal plans in place at their National Guard headquarters or at the CST level for evaluating the effective use of resources, and very few of those states conducted periodic internal reviews of the CSTs. The states set up budget and accounting records to ensure funds for the CSTs were available when and where needed, but they conducted no regular program reviews for the CSTs. Many of the states and territories we visited did not have specific objectives for collective training, and they did not measure accomplishments against previously determined specific mission objectives. Therefore, those states could not identify deficiencies or make command management decisions based on such analyses. As a result, NGB and the states were not in a position to know if they were making the most effective use of CST resources. Again, because NGB has no clear guidance to the states, state National Guard support of the CSTs also varies widely in terms of staffing, equipment, and facilities. One state we visited provides additional administrative support to its CST through the use of three or four regular part-time National Guard members. This arrangement also allows those part-time members access to some CST training and, in the event those individuals apply for vacant permanent CST positions, can cut down on hiring and training delays. Another state hired an additional full-time duty member to support the team's logistics. Some states provided limited amounts of additional equipment to support their CSTs, such as laptop computers. Other states do not augment their CSTs. Among the reasons some state National Guard officials reported for why their state's National Guard headquarters did not augment their CSTs were a lack of money and lack of interest by the headquarters in the CSTs because they are small units. NGB officials acknowledged that they need to help the states understand that the CSTs are unique units and should therefore be considered high priority. During our site visits, we found inconsistencies in how states interpret and apply procurement guidance to CST equipment requests. As a result, some states approved equipment for a CST while other states did not. For example, NGB guidance permits the purchase of nonstandard uniforms with state funds only and if necessary for CSTs to accomplish their mission by blending in with other police and first responder personnel. However, some states we visited refused to purchase uniforms for their teams, even though the teams indicated a need. Other states did support the purchase of the nonstandard uniforms. While NGB, state National Guard, and CST officials stated that they believed it was important to have the flexibility to make purchases that best support the CSTs' mission, some CST commanders however thought this subjectivity sometimes negatively affected the CSTs' ability to obtain material support. States have also had difficulties designing and renovating or building facilities that meet the needs of the CSTs. State National Guard officials said the unique nature of the CST mission made it more difficult for states to understand the support requirements and expectations placed upon their CSTs. For example, in addition to the need for climate controlled spaces for sensitive equipment, most CST members we interviewed said that there is a need for enclosed bays for all vehicle storage because it facilitates ready-to-roll deployment, improves vehicle security, and provides an all-weather maintenance and training area. However, 78 percent of the CST commanders who responded to our data collection instrument reported that their facilities are not large enough to hold all vehicles and other CST equipment. Approximately half reported that their facilities are not large enough for all personnel to have an adequate workspace. National Guard officials in the states and territories we visited also identified inadequacies with their facilities. They said they followed Army procurement and budgeting guidance, which sometimes affected whether identified changes could be made to the design or construction. Sometimes the state National Guard did not recognize the unique mission of the CST as compared to building an armory, and sometimes the design was set before the CST commander or other members had a chance to review the plans. Because of varying interpretations, some states have constructed new or remodeled facilities that are in need of further remodeling. Other CSTs we visited were satisfied with their facilities, despite believing that such things as vehicle bay space were not completely adequate. These CST members reported that their state National Guard headquarters worked well with the CST to design the most effective facility they could to meet the unique needs of the team. In addition to the CST management regulation, NGB instituted the CST standardization program partially in response to its concerns that states were not adequately monitoring the CSTs' implementation of key Army management controls in training, logistics, budgeting, and other areas. According to preliminary standardization program reviews, state National Guard headquarters have done few periodic reviews and inspections. NGB officials told us they intend to use these reviews to increase state participation in oversight of the CSTs and will also spell out in greater detail for the states the type of interaction NGB believes is necessary and required by regulation. If pursued consistently, the standardization program should help NGB better coordinate with the states on how to oversee and support the CSTs, though a significant NGB-state National Guard cooperative effort will be needed to facilitate success. Conclusions: In managing the CST program, DOD and NGB have made significant progress toward establishing 55 highly specialized teams in every state and U.S. territory. The focus has thus far been on reaching the goal of certifying all 55 teams. As the CST program seeks to institutionalize its key processes and sustain itself in the long term, we see four areas that could increase the risk to that effort. First, confusion about what types of non-WMD deployments the CSTs can and should use to help them accomplish their mission of preparing for or responding to WMD events could make it more difficult to effectively coordinate efforts at the state and local levels and possibly inhibit regional and national coordination between the states and the federal government. Expanding the CSTs' mission to encompass natural and man- made disasters may not sufficiently clarify what types of such missions are appropriate for the CSTs to conduct, possibly exacerbating confusion among state and local officials about the mission of the CSTs. Second, some limited overseas missions, such as coordinating with officials from Canada and Mexico or training at live agent facilities, may be beneficial to CST training and operational effectiveness. Though DOD indicates that it is not planning to request that Congress expand the CSTs' role to encompass more demanding overseas missions, to the extent missions such as regular CST support to overseas combatant commands are considered in the future, they would likely have a detrimental impact on the readiness and availability of the teams to perform their original mission to support domestic WMD response. Third, despite the progress NGB has made in fully establishing the CST program and formalizing institutional sustainment plans for the teams, many areas of the program face significant challenges that require specific guidance and action from NGB. NGB understands these challenges, particularly in the areas of team staffing, coordination guidance, equipment maintenance and acquisition, training and exercise oversight, readiness reporting, and facility adequacy. While individual team readiness has not yet suffered, if current and planned NGB efforts to address these challenges are not successful, the challenges could eventually cause harm to overall CST readiness. Fourth, despite NGB's progress in establishing such unique and specialized units as the CSTs, there remains a need for additional guidance on the administrative oversight structure for the CSTs at the state level. Small differences between the way each state manages its CST may be expected, given the fact of 54 different military commands. While NGB's plans for additional guidance on the oversight and support of the CSTs and its standardization program should help states better integrate the CSTs, further guidance and coordination efforts between NGB, the CSTs, and the state National Guard commands is warranted. Recommendations for Executive Action: To help address management challenges and further efforts to sustain the CST program, we recommend that the Secretary of Defense, in concert with the Chief of the National Guard Bureau and the Secretaries of the Army and of the Air Force, take the following three actions: * Clarify the types of non-WMD responses that are appropriate for CSTs as part of their mission to prepare for domestic WMD and catastrophic terrorist attacks. * Fully incorporate into ongoing management efforts to sustain the CST program a plan with goals, objectives, and evaluation mechanisms to address challenges such as team staffing issues, coordination guidance, equipment maintenance and acquisition, training and exercise oversight, readiness reporting, and facilities requirements. * Develop clear guidance for the states on how CSTs should be integrated into state National Guard commands in order to facilitate an effective administrative oversight and support structure for the CSTs in each state that reflects familiarization with the role, mission, and requirements of these specialized units, and work with state adjutants general and federal financial officers at the state level to find appropriate ways to exchange ideas and best practices for ensuring effective NGB-state National Guard partnership in overseeing the CST program. One such method could be to create or modify an existing working group or team to allow state National Guard membership. Agency Comments and Our Evaluation: In comments on a draft of this report, DOD generally agreed with the intent of our recommendations. DOD discussed steps it is currently taking as well as actions it plans to take to address these recommendations. DOD also provided technical comments, which we have incorporated into the report where appropriate. In response to our recommendation that DOD clarify the types of non-WMD responses that are appropriate for CSTs, DOD reported that it has requested that Congress authorize the CSTs to respond to catastrophic events of intentional or unintentional origin and that if this is enacted, DOD will direct the Chief of the National Guard Bureau to develop implementing instructions. DOD reiterated its view that the CSTs have been participating in non-WMD responses as training. Expanding the CSTs' mission to include both WMD and non-WMD events should help clarify the role of the latter in the CSTs' overall mission. We continue to believe that as NGB develops implementing instructions, it should provide clear guidance on the types of non-WMD responses that are appropriate for the CSTs. This should help alleviate confusion about the CSTs' mission and prevent their being overemployed to the detriment of their WMD-related training and mission requirements. In its comments on our recommendation regarding incorporation into ongoing CST management efforts of a plan to address critical challenges to the CST program, DOD highlighted some of the CST management efforts we discussed in our report, such as the CST Working Group and the CST standardization program. DOD further stated that additional management efforts should be deferred until the effectiveness of the standardization program can be assessed. We agree that the program offers the potential of a good evaluation tool for NGB, the CSTs, and the states' National Guard headquarters and that further information on many of the challenges we highlight in our report may be gleaned from the results of the standardization program. To the extent the program further highlights these and other challenges for which no immediate corrective measures are in place, we would expect the Chief of the National Guard Bureau to take the appropriate management action. In response to our recommendation that NGB develop clear guidance for the states on how CSTs should be integrated into state National Guard commands to facilitate effective administrative oversight and support, DOD indicated that in addition to guidance on state oversight of the CSTs in the recently published CST management regulation, the CST standardization program and NGB-conducted formal training for state National Guard leadership provide additional measures to review and reinforce state National Guard administrative oversight of their CSTs. DOD further recognized the value of currently available venues for coordination between NGB, the CSTs, and the states' National Guard commands. As we state in our report, we believe that if pursued consistently, the standardization program should help NGB better coordinate with the states on how to oversee and support the CSTs. This should help NGB and the states provide an effective long-term partnership to sustain the CST program. To the extent necessary based on the result of standardization program evaluations, we would expect NGB to expand its efforts to assist state National Guard commands to provide effective oversight and support of their CSTs. DOD's written comments are reprinted in appendix IV. As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this report until 30 days after its date. At that time, we will send copies to the appropriate congressional committees, the Secretary of Defense, and the Secretary of the Army. We will also make copies available to others upon request. In addition, the report will be available at no charge on the GAO Web site at [Hyperlink, http://www.gao.gov]. If you or your staff have any questions concerning this report, please contact me at (202) 512-5431 or d [Hyperlink, dagostinod@gao.gov] agostinod@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key staff members who contributed to this report are listed in appendix V. Sincerely yours, Signed by: Davi M. D'Agostin: Director, Defense Capabilities and Management: [End of section] Appendix I: Scope and Methodology: To assess the extent to which the Civil Support Teams (CST) are prepared to conduct their mission, we gathered information on the categories and process of the two CST readiness measurement mechanisms; reviewed readiness-related documents for the 14 teams we visited; included similar readiness information in a data collection instrument sent to all 55 CSTs; and discussed CST readiness with local, state, and federal officials who have worked with CSTs. We observed the external evaluation of 1 CST by U.S. Army officials and attended the after action review following the evaluation. We also observed an exercise that included one CST and a number of local and state responders. During our site visits, we discussed operational command and control mechanisms with CST members and their National Guard headquarters officials. We compared the published mission of the CSTs to the types of missions the CSTs are performing and discussed the extent to which their mission is well understood with CST members and local, state, and federal officials. Further, we discussed the potential effect of overseas missions on CST readiness with CST members and civilian emergency management officials in the states and territories we visited. To assess the extent to which effective administrative mechanisms are in place for the CSTs, we compared National Guard Bureau (NGB) regulations and guidance on management of the CSTs with the practices in place at the 14 CSTs we visited. We also discussed operational and administrative issues with CST members in those states and their National Guard headquarters officials. We collected similar information in the data collection instrument sent to all 55 CSTs. During our site visits, we discussed with CST members those challenges they believed could inhibit CST readiness in future. We categorized these challenges, discussed them with NGB officials, and compared the challenges to information on NGB efforts related to those areas. We also collected cost data related to the establishment and sustainment of the CSTs from NGB, state National Guard personnel, and the CSTs themselves. We did not independently verify cost data, but we interviewed NGB officials who manage the data about data quality control procedures. We determined the data were sufficiently reliable for the purposes of this report. To address our objectives, we visited and interviewed officials from the Department of Defense (DOD), including the Office of the Assistant Secretary of Defense for Homeland Defense, NGB, U.S. Army Forces Command, First Army, Fifth Army, and United States Northern Command. During each state site visit we met with members of the CST and officials from the state National Guard headquarters, state emergency management and homeland security officials, representatives from local community emergency response agencies (such as fire and police departments), and representatives of federal agencies and organizations (such as the Federal Bureau of Investigation and Department of Energy). Our site visits to 14 of the 55 CSTs were conducted from August through December 2005. We selected the 14 teams in order to obtain a reasonable sample of CSTs based on a number of criteria, including geographic distribution, age of team, certification status, state size, state population, state government emergency management and homeland security organization, and DOD-related command structure. We visited the following locations: * Alabama: * Alaska: * Colorado: * Iowa: * Massachusetts: * Montana: * New Mexico: * New York: * North Carolina: * Puerto Rico: * Rhode Island: * Tennessee: * Texas: * Washington: To supplement the interviews we conducted during the site visits, we collected supporting documents from the CSTs and individuals we interviewed and made physical observations of CST facilities in every state we visited. To further address our objectives, we designed a broad data collection instrument for all 55 CSTs that would collect information regarding CST personnel, equipment, training, certification, costs, coordination, and mission scope. Within these major topic areas, we developed and tested relevant questions based upon previous GAO work, current research, and interviews at both the NGB and CST level. After two formal pretests with the command staff of 2 separate CSTs, we deployed the data collection instrument simultaneously to the National Guard's state supervisory auditors for all 55 teams and asked that they be forwarded to the CST commanders in each of their respective states or territories. The data collection instrument was administered via e-mail using an ActiveX-enabled Microsoft Word attachment. Although every team received an identical version of the data collection instrument, we advised the team commanders that because of differing experiences, locations, certification statuses, and lengths of service, we recognized that not all teams would be able to respond to every question. Each section of the instrument contained questions that could be answered by both certified and uncertified teams, as well as questions that were applicable to certified teams only. The data collection instrument was addressed to the 55 unit commanders, and while these individuals were explicitly responsible for the overall content of the completed data collection instruments, we permitted them to delegate specific questions or sections to other appropriate members within the CST. To ensure a full and candid response, we noted that individual responses would be attributed neither to individual CSTs nor to their individual members. Further, we requested that the teams transmit their responses over a secure e-mail channel to safeguard any sensitive information. We distributed the data collection instrument via e-mail on September 26, 2005, and it was deployed through December 27, 2005. Out of the 55 deployed, we received 52 completed data collection instrument responses during our 3-month response window.[Footnote 19] To analyze the results of the completed responses, we noted responses for all questions and highlighted those we deemed significant, such as responses where there was overwhelming agreement among CST commanders. These responses and others were compared with preliminary results from our site visits and used to verify that the GAO site visit teams had not overlooked significant widespread CST issues. Percentage results from the data collection instrument are discussed in the letter. In some cases, there are fewer than 52 respondents for a given question. Because some respondents did not answer all questions, the percentages we report are calculated using the base of respondents who answered the question. In no cases did fewer than 48 of the 52 respondents answer a question whose percentage results appear in the report. Because this was not a sample survey, there are no sampling errors. However, the practical difficulties of conducting any data collection effort may introduce errors, commonly referred to as nonsampling errors. For example, difficulties in how a particular question is interpreted, in the sources of information that are available to respondents, or in how the data are entered into a database or are analyzed, can introduce unwanted variability into the survey results. We took steps in the development of the data collection instrument, the data collection, and the data analysis to minimize these nonsampling errors. For example, GAO staff with subject matter expertise designed the data collection instrument in collaboration with social science survey specialists. Then, the draft questionnaire was pre-tested with the command staff of two CSTs to ensure (1) the questions were relevant, clearly stated, and easy to comprehend; (2) terminology was used correctly; (3) the questionnaire did not place an undue burden on the respondents; (4) the information was feasible to obtain; and (5) the survey was comprehensive and unbiased. Finally, when the data were analyzed, a second, independent analyst checked all computer programs. The entire data collection instrument appears in appendix III. We performed our work from April 2005 through March 2006 in accordance with generally accepted government auditing standards. [End of section] Appendix II: CST Program Management Efforts: NGB has focused much of its management on establishing and certifying all 55 of the authorized CSTs. But NGB also recognizes that a significant amount of effort is required to ensure that the CST program is sustained for the long term, while it also provides for the continued improvement of the process for establishing the teams and modifying doctrine, training, equipment, and operational considerations as necessary. Some of the institutional efforts NGB has coordinated or led include a CST standardization program, coordinating Army-directed CST training and evaluations, and establishing working groups to evaluate and recommend improvements to the CST program. Standardization and Evaluation Program: The standardization program is scheduled to evaluate each CST every 18 months and is intended to be coordinated with state-level command inspections that the Army requires. The process begins with a precoordination meeting 6 months prior to the scheduled standardization visit that explains the purpose, evaluation method, and desired outcome for the upcoming visit. Ninety days prior to the scheduled visit, a second coordination meeting is held to resolve any remaining administrative details and to allow the standardization team personnel responsible for conducting the evaluation to become familiar with the CST's location. During the visit itself, these personnel conduct compliance-oriented evaluations using a series of checklists that monitor various subtasks within the evaluated areas. For example, the training checklist assesses 55 items, including whether the CST has an approved Mission Essential Task List, whether the team publishes quarterly training guidance, and whether the team conducts after-action reports for all training. Each checklist item is evaluated as "go," "no- go," or "not applicable." Items that are initially characterized as needing improvement (no-go) may be upgraded to satisfactory (go) as a result of on-the-spot corrections. At the evaluation's conclusion, standardization team personnel will present the results of their evaluation to the state adjutant general. They must issue a formal report to the adjutant general within 6duty days after the end of their visit. Among the standardization program's objectives is integrating with state and intermediate command inspections that could reduce the total amount of time committed to the inspection process, as well as imposing CST-specific management controls to assist in the prevention of fraud, waste, and abuse of Army resources. Program personnel have completed a series of test visits to CSTs, and they expect to begin formal evaluation visits in May 2006. Army Training and Evaluation Support: As of October 1, 2005, Fifth Army assumed sole responsibility for all CST external evaluations and related training, with the exception of CSTs in Hawaii, Alaska, and Guam, which remain under U.S. Army Pacific. Under Fifth Army, the organization and protocols of all CST training and evaluation teams should be standardized. Army, NGB, and CST officials report that training, education, and experience requirements of trainer/evaluators will also be standardized. They indicate that this standardization should increase the consistency of external evaluations and related collective training across all teams. Consolidation of Army training, readiness, and oversight responsibilities could also promote better information sharing and guidance development both across the Fifth Army training and evaluation teams and the program as a whole. Responsibility for all CST external evaluations and related training was previously divided geographically between the First Army and Fifth Army under the U.S. Army Forces Command, with the exception of Hawaii, Alaska, and Guam. Although both First and Fifth Armies were required to train and evaluate teams to the standards set forth in the CSTs' Mission Training Plan, Army field manuals and other regulations, each Army organized its CST training and evaluation teams differently and followed different protocols for executing training and external evaluations. CST Working Groups: In April 2005 NGB formally established the Civil Support Team Working Group to (1) increase the operational effectives of CSTs by providing operationally relevant advice on gaps, shortfalls, and improvements to CST doctrine, organization, training, materiel, leadership and education, personnel, and facilities (DOTMLPF); (2) assist in implementing any resulting plans, and (3) promote standardization and interoperability among CSTs. The working group process had already been working informally since the establishment of the first 10 CSTs. In addition to NGB, working group membership includes the CST commanders and representatives from the Army Maneuver Support Center[Footnote 20] and the joint service Chemical and Biological Defense Program. The working group is organized to include several technical working groups and subgroups that focus on specific aspects (e.g., equipment, personnel, and training) or components (e.g., operations, survey, medical and science assessment, communications, computer and information systems, and logistics/sustainment) of the CST program. In June 2004 the Army Maneuver Support Center and NGB initiated the Integrated Concept Team to determine the tasks, schedules, milestones, and products required to develop operational concepts and provide DOTMLPF solutions to support the CST program. In addition to directing the efforts of the other CST working groups with regard to DOTMLPF responsibilities, the Integrated Concept Team is also tasked with more broadly addressing CST issues within the larger scope of DOD force management and operational capabilities plans. [End of section] Appendix III: Data Collection Instrument: Data Collection Instrument for the Weapons of Mass Destruction Civil Support Teams: [See PDF for image] [End of figure] [End of section] Appendix IV: Comments from the Department of Defense: Assistant Secretary Of Defense: 2600 Defense Pentagon: Washington, DC 20301-2600: MAY 12 2006: Homeland Defense: Ms. Davi M. D'Agostino: Director, Defense Capabilities & Management: US Government Accountability Office: 441 G St, N.W.: Washington, DC 20548: Dear Ms. D'Agostino: This is the Department of Defense response to the GAO draft report, GAO- 06-498, "Homeland Defense: National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges," dated April 4, 2006, (GAO Code 350687). We appreciate the opportunity to provide comments to your draft report regarding your review of the Weapons of Mass Destruction- Civil Support Teams (WMD-CST). I have enclosed comments on your recommendations and administrative corrections to the report. Let me take this opportunity to thank you and your staff for including us in your review of the WMD-CST program and subsequent report. Sincerely, Signed by: Paul McHale: Enclosures: As stated: GAO Draft Report-April 4, 2006: GAO Code 350687/GAO-06-498: "Homeland Defense: National Guard Bureau Needs to Clarify Civil Support Teams' Mission and Address Management Challenges" Department Of Defense Comments To The Recommendations: Recommendation 1: The GAO recommended that the Secretary of Defense direct the Chief of the National Guard Bureau to clarify the types of non-weapons of mass destruction responses that are appropriate for civil support teams as part of their mission to prepare for domestic weapons of mass destruction and catastrophic terrorist attacks. DOD Response: Partially concur. The Secretary of Defense has requested that Congress clarify the authorization language for employment of civil support teams (CSTs). Specifically, CSTs should be permitted to respond, using the full range of capabilities developed for a response to an attack using WMD, to catastrophic events arising from unintentional or natural events. Should Congress change the law, the Secretary of Defense will direct the Chief, National Guard Bureau to develop implementing instructions. The CST Contingency Operations Plan in NGR 500-3/ANGI 10-2503 highlights CST employment criteria used by the governor and the adjutant general to assess the mission requirements before committing the CST to a state mission. Teams have been participating in national security events and other high visibility events, to include natural disasters, i.e., the Columbia Shuttle Disaster and the aftermath of Hurricane Katrina, as a training opportunity. Participation in such an event is considered training, until/unless an event occurs which makes it a full operational response under the law. Recommendation 2: The GAO recommended that the Secretary of Defense direct the Chief of the National Guard Bureau to fully incorporate into the National Guard Bureau's on going management efforts to sustain the civil support team program a plan with goals, objectives, and evaluation mechanisms to address challenges such as team staffing issues, coordination guidance, equipment maintenance and acquisition, training and exercise oversight, readiness reporting, and facilities requirements. DOD Response: Partially concur. WMD-CSTs are funded, trained, and supported under the management systems established by Department of the Army and the National Guard Bureau (NGB). In conjunction with the findings of the DoD WMD CST Program Review, the Army conducted a Force Management Analysis (FORMAL) Review and presented the findings to the Army Vice Chief of Staff in March 2003. The FORMAL Review developed a plan to "institutionalize" and fully integrate the WMD CST program into the DoD resource capabilities process, clarifying the proponency for WMD-CSTs as a joint effort between the NGB and the Army Training and Doctrine Command, and identified a process to identify and resolve doctrine, organization, training, leader development, material, personnel and facilities issues. In April 2005, NGB chartered the Civil Support Team Working Group to establish a systematic process to leverage WMD-CST unit member knowledge and experience and to resolve operational problems, issues and recommend program improvements. The Civil Support Team Working Group functions to increase operational effectiveness of the CSTs by providing operationally relevant advice on gaps, shortfalls, and improvements to CST doctrine, operations, training and education, material, leader development, personnel, and facilities requirements; assist with synchronized execution of resultant plans; and promote standardization and interoperability among the CSTs. Further, the NGB has established a Standardization Evaluation and Assistance Team (SEAT) program which will visit each state and territory on an 18-month rotational cycle. While it is clear that CSTs are unique to DoD, the argument for additional or exceptional administrative controls should be deferred until the SEAT program is fully implemented. Improvements can always be made to existing systems and the growth of additional management controls, above those currently in place, is considered premature until we are able to measure the effectiveness of the SEAT program. Recommendation 3: The GAO recommended that the Secretary of Defense direct the Chief of the National Guard Bureau to develop clear guidance for the states on how civil support teams should be integrated into state National Guard commands in order to facilitate an effective administrative oversight and support structure for the civil support teams in each state that reflects familiarization with the role, mission, and requirements of these specialized units, and to work with state Adjutants General and federal financial officers at the state level to find appropriate ways to exchange ideas and best practices for ensuring effective National Guard Bureau - state National Guard partnership in overseeing the civil support team program. One such method could be to create or modify an existing working group or team to allow state National Guard membership. DOD Response: Partially concur. The intent of Congress to have these teams under the control of the governor is clear in the authorizing language. As such, the National Guard Bureau (NGB) has provided guidance for effective management rather than strict control measures. The adjutants general in 23 states are the heads of the state emergency management agencies; therefore, 31 states have different structures. As such, command and control of the CST is left to the state to determine the best fit in order to maximize training and command and control functions. As indicated in this finding, several groups have been created to exchange ideas. These groups provide a valuable venue to share effective management techniques. To ensure that the existing state structure provides the necessary oversight, NGB has recently published the CST Management Regulation, NGR 500-3/ANGI 10-2503, which delineates guidance on the responsibilities, policies and procedures for the management for these teams. Further, NGB has established a Standardization Evaluation and Assistance Team (SEAT) program which will visit each state and territory on an 18-month rotational cycle. These visits will provide the adjutant general with an independent review and validation of state support to the CST and provide recommendations for management controls and changes to ensure that CSTs meet the guidance issued by the Chief, National Guard Bureau. NGB also provides a formal training for state leadership which focuses on the unique requirements of establishing and sustaining CSTs under the CST Concept of Operations. Continued effort will be applied to keep, and possibly expand, the venues currently available to exchange ideas and information. [End of section] Appendix V: GAO Contact and Staff Acknowledgments: GAO Contact: Davi M. D'Agostino (202) 512-5431 or d [Hyperlink, dagostinod@gao.gov] agostinod@gao.gov: Acknowledgments: In addition to those named above, Ann Borseth, Assistant Director; Bari L. Bendell; Jaclyn A. Bowland; David A. Brown; Carole F. Coffey; Lee Cooper; Joseph W. Kirschbaum; David A. Mayfield; Walter K. Vance; and Tamika S. Weerasingha made key contributions to this report. (350687): FOOTNOTES [1] For the purposes of this report, "weapons of mass destruction" means any weapon or device that is intended, or has the capability, to cause death or serious bodily injury to a significant number of people through the release, dissemination, or impact of (1) toxic or poisonous chemicals or their precursors, (2) a disease organism, or (3) radiation or radioactivity. 50 U.S.C. § 2302 (1). [2] For purposes of this report, "state" includes the 50 United States; the territories of Guam, Puerto Rico, and the Virgin Islands; and the District of Columbia. [3] The teams were originally called Rapid Assessment Initial Detection Teams. [4] GAO, Reserve Forces: Actions Needed to Better Prepare the National Guard for Future Overseas and Domestic Missions, GAO-05-21 (Washington, D.C.: Nov. 10, 2004). [5] One system is DOD's Status of Resources and Training System and the other is NGB's CST-specific Operational Reporting System. [6] Pub. L. No. 104-201, § 1411 (1996). [7] Pub. L. No. 105-261, § 510 (1998). [8] 10 U.S.C. § 12310(c)(5). [9] National Guard Bureau, Weapons of Mass Destruction Civil Support Team Management, NGR 500-3/ANGI 10-2503, ch. 14 (Jan. 12, 2006). [10] In Homeland Security Presidential Directive-5, dated February 28, 2003, the President directed the development of a new National Response Plan to align federal coordination structures, capabilities, and resources into a unified all-discipline, and all-hazards approach to domestic incident management. It covers coordination among federal, state, local, and tribal organizations by increasing the speed, effectiveness, and efficiency of incident management. Under the National Response Plan, state, local, and other organizations are, among other things, to utilize established incident reporting protocols and modify their existing incident management and emergency operations plans to align with National Response Plan coordinating structures, processes, and protocols. [11] In 2002 Congress added to the CST's mission "preparation for or response to a terrorist attack or threatened terrorist attack in the United States that results, or could result, in catastrophic loss of life or property." Pub. L. No. 107-314, § 514 (2002). [12] 10 U.S.C. § 12310(c). [13] White House, The Federal Response to Hurricane Katrina Lessons Learned (Washington, D.C.: February 2006). The report also acknowledges that increased costs and other resources would be necessary to support an expanded CST mission. [14] 10 U.S.C. § 12310(c)(3). [15] National Guard Bureau, Weapons of Mass Destruction Civil Support Team Management, ch. 1-1. [16] National Guard Bureau, Weapons of Mass Destruction Civil Support Team Management. [17] Department of the Army, Weapons of Mass Destruction Civil Support Team and Chemical, Biological, Radiological, and Nuclear Installation Support Team Tactics, Techniques, and Procedures, Field Manual 3-11.22 (January 2004). [18] National Guard Bureau, Weapons of Mass Destruction Civil Support Team Management. [19] The three CSTs that did not submit responses included one phase 2 team and two phase 5 teams. [20] Part of the Army's Training and Doctrine Command. GAO's Mission: The Government Accountability Office, the investigative arm of Congress, exists to support Congress in meeting its constitutional responsibilities and to help improve the performance and accountability of the federal government for the American people. 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