Homeland Defense and Weapons of Mass Destruction
Additional Steps Could Enhance the Effectiveness of the National Guard's Life-Saving Response Forces Gao ID: GAO-12-114 December 7, 2011The 2010 National Security Strategy emphasizes the importance of strengthening our security and resilience at home and building capability to respond to and recover from major chemical, biological, radiological, nuclear, and high-yield explosive (CBRNE) incidents. The National Guard has established 17 CBRNE Enhanced Response Force Packages (CERFP), which are staffed with National Guard part-time personnel, to provide life-saving capabilities in response to a CBRNE event. The teams are intended to coordinate operations with multiple response partners at the local, state, and federal levels--including Department of Defense (DOD) forces. The National Guard Bureau (NGB) is responsible for managing the CERFP program. GAO assessed (1) how well CERFPs are prepared to perform their mission and how such readiness is measured and reported; (2) how effectively CERFPs coordinate with incident response partners and how well this is evaluated; and (3) the effectiveness of the CERFPs' command and control framework. GAO reviewed program documentation, surveyed National Guard and emergency management officials from 27 states, observed training exercises, and interviewed DOD, NGB, and CERFP officials
The National Guard's CERFPs face personnel, training, and equipment challenges that have adversely affected their preparedness to effectively execute the CBRNE mission. For example, state National Guard and CERFP officials cited ongoing difficulty in maintaining adequate numbers of personnel with the proficiency needed to execute many specialized tasks they are to perform, and stated that additional equipment may be needed to perform the mission. These challenges highlight that NGB has not established a process to comprehensively review and validate personnel, training, and equipment requirements. In addition, CERFPs' readiness information is not comprehensively available to potential DOD response partners because such information is not yet included in DOD's centralized readiness-reporting system, and final plans to do so have not yet been developed. In the absence of accurate requirements and comprehensive readiness information, NGB is unable to effectively prioritize funding and mitigate resource deficiencies that could jeopardize the CERFPs' preparedness levels. CERFPs coordinate with some of their potential response partners--such as local and state organizations--through activities such as briefings but have achieved varying levels of success in educating such partners about CERFP capabilities because of insufficient guidance on how to conduct interagency coordination. Existing coordination guidance is imprecise on the frequency and targeting of coordination activities, thereby providing little direction for prioritizing responsibilities. Additionally, opportunities exist to enhance regional coordination through interstate agreements and planning. Such agreements would allow more effective pooling and sharing of resources across state boundaries; however, few interstate agreements exist between states with and without CERFPs. NGB is taking steps to assess the CERFPs' performance of coordination activities, but NGB's evaluation tool, based on existing guidance, does not have coordination standards against which CERFP performance can be measured. In the absence of sufficient interagency coordination guidance and evaluation standards, NGB is unable to foster a consistent approach to coordination that improves the CERFPs' ability to respond to regional events. NGB has a framework in place for the operational command and control of CERFPs that outlines how teams will integrate with civilian and military command structures. However, the command and control of operations involving CERFPs may be limited because of (1) inadequate communications equipment; (2) the absence of required agreements between some CERFPs and their out-of-state elements; and (3) infrequent opportunities to practice potential command and control arrangements in a realistic response environment. For example, the CERFPs' authorized communications equipment is not interoperable with the equipment used by some other response organizations, such as first responders, and has a limited range. In addition, NGB has initiated plans to introduce 10 new forces--called Homeland Response Forces--to assist civil authorities in responding to disasters of all kinds. This plan will affect the existing command and control framework, but NGB has not issued updated command and control guidance to the CERFPs. As a result of these factors, NGB lacks assurance that CERFP operations can be commanded and controlled effectively. GAO recommends that DOD take a number of actions to increase CERFP preparedness, strengthen pre-incident coordination with potential response partners, and ensure the effective command and control of operations involving CERFPs. DOD agreed with the recommendations.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Janet A. St. Laurent Team: Government Accountability Office: Defense Capabilities and Management Phone: (202) 512-4402GAO-12-114, Homeland Defense and Weapons of Mass Destruction: Additional Steps Could Enhance the Effectiveness of the National Guard's Life-Saving Response Forces
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
December 2011:
Homeland Defense and Weapons of Mass Destruction:
Additional Steps Could Enhance the Effectiveness of the National
Guard's Life-Saving Response Forces:
GAO-12-114:
GAO Highlights:
Highlights of GAO-12-114, a report to congressional requesters.
Why GAO Did This Study:
The 2010 National Security Strategy emphasizes the importance of
strengthening our security and resilience at home and building
capability to respond to and recover from major chemical, biological,
radiological, nuclear, and high-yield explosive (CBRNE) incidents. The
National Guard has established 17 CBRNE Enhanced Response Force
Packages (CERFP), which are staffed with National Guard part-time
personnel, to provide life-saving capabilities in response to a CBRNE
event. The teams are intended to coordinate operations with multiple
response partners at the local, state, and federal levels”-including
Department of Defense (DOD) forces. The National Guard Bureau (NGB) is
responsible for managing the CERFP program. GAO assessed (1) how well
CERFPs are prepared to perform their mission and how such readiness is
measured and reported; (2) how effectively CERFPs coordinate with
incident response partners and how well this is evaluated; and (3) the
effectiveness of the CERFPs‘ command and control framework. GAO
reviewed program documentation, surveyed National Guard and emergency
management officials from 27 states, observed training exercises, and
interviewed DOD, NGB, and CERFP officials.
What GAO Found:
The National Guard‘s CERFPs face personnel, training, and equipment
challenges that have adversely affected their preparedness to
effectively execute the CBRNE mission. For example, state National
Guard and CERFP officials cited ongoing difficulty in maintaining
adequate numbers of personnel with the proficiency needed to execute
many specialized tasks they are to perform, and stated that additional
equipment may be needed to perform the mission. These challenges
highlight that NGB has not established a process to comprehensively
review and validate personnel, training, and equipment requirements.
In addition, CERFPs‘ readiness information is not comprehensively
available to potential DOD response partners because such information
is not yet included in DOD‘s centralized readiness-reporting system,
and final plans to do so have not yet been developed. In the absence
of accurate requirements and comprehensive readiness information, NGB
is unable to effectively prioritize funding and mitigate resource
deficiencies that could jeopardize the CERFPs‘ preparedness levels.
CERFPs coordinate with some of their potential response partners”such
as local and state organizations”through activities such as briefings
but have achieved varying levels of success in educating such partners
about CERFP capabilities because of insufficient guidance on how to
conduct interagency coordination. Existing coordination guidance is
imprecise on the frequency and targeting of coordination activities,
thereby providing little direction for prioritizing responsibilities.
Additionally, opportunities exist to enhance regional coordination
through interstate agreements and planning. Such agreements would
allow more effective pooling and sharing of resources across state
boundaries; however, few interstate agreements exist between states
with and without CERFPs. NGB is taking steps to assess the CERFPs‘
performance of coordination activities, but NGB‘s evaluation tool,
based on existing guidance, does not have coordination standards
against which CERFP performance can be measured. In the absence of
sufficient interagency coordination guidance and evaluation standards,
NGB is unable to foster a consistent approach to coordination that
improves the CERFPs‘ ability to respond to regional events.
NGB has a framework in place for the operational command and control
of CERFPs that outlines how teams will integrate with civilian and
military command structures. However, the command and control of
operations involving CERFPs may be limited because of (1) inadequate
communications equipment; (2) the absence of required agreements
between some CERFPs and their out-of-state elements; and (3)
infrequent opportunities to practice potential command and control
arrangements in a realistic response environment. For example, the
CERFPs‘ authorized communications equipment is not interoperable with
the equipment used by some other response organizations, such as first
responders, and has a limited range. In addition, NGB has initiated
plans to introduce 10 new forces”-called Homeland Response Forces-”to
assist civil authorities in responding to disasters of all kinds. This
plan will affect the existing command and control framework, but NGB
has not issued updated command and control guidance to the CERFPs. As
a result of these factors, NGB lacks assurance that CERFP operations
can be commanded and controlled effectively.
What GAO Recommends:
GAO recommends that DOD take a number of actions to increase CERFP
preparedness, strengthen pre-incident coordination with potential
response partners, and ensure the effective command and control of
operations involving CERFPs. DOD agreed with the recommendations.
View GAO-12-114 or key components. For more information, contact Janet
St. Laurent at (202) 512-4300 or stlaurentj@gao.gov.
[End of section]
Contents:
Letter:
Background:
CERFPs Face Personnel, Training, and Equipment Requirements
Challenges, and Readiness Is Not Comprehensively Reported:
Opportunities Exist to Enhance Coordination with Other Response
Organizations:
A Command and Control Framework Is in Place, but Several Factors May
Inhibit CERFPs' Operational Effectiveness:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: CERFP Interagency Training, 2008-2010:
Appendix III: Comments from the Department of Defense:
Appendix IV: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Number of CERFPs with Authorized Levels of Personnel
Available to Perform Mission Tasks All of the Time, as Reported by
State Adjutants General:
Table 2: Number of CERFPs That Had Authorized Quantities of Equipment
as of October 2010:
Figures:
Figure 1: States That Have CERFPs within the 10 FEMA Regions:
Figure 2: Approximate Time Frames within Which Some DOD CBRNE
Consequence Management Forces Are Expected to Deploy after an Incident:
Figure 3: CERFPs Are Formed from the State's National Guard:
Figure 4: States That Will Host CERFPs and Homeland Response Forces by
September 2012:
Figure 5: Adjutants General Responses on CERFP Interaction with Local,
State, Regional, and Federal Response Organizations:
Figure 6: Command and Control Structure for State Active Duty and
Title 32 CERFP Response Operations:
Figure 7: Potential CERFP Incident Site Response Partners and
Communications Pathways:
Figure 8: CERFP Joint Field Training with Select Potential Response
Partners, 2008-2010:
Figure 9: CERFP Joint Field Training with Emergency Management
Agencies from States with CERFPs, 2008-2010:
Figure 10: CERFP Joint Field Training with Emergency Management
Agencies from States without CERFPs, 2008-2010:
Figure 11: CERFP Joint Field Training with State National Guards from
States without CERFPs, 2008-2010:
Abbreviations:
CBRNE: chemical, biological, radiological, nuclear, and high-yield
explosive:
CCMRF: CBRNE Consequence Management Response Force:
CERFP: CBRNE Enhanced Response Force Package:
CST: Civil Support Team:
DCRF: Defense CBRN Response Force:
DOD: Department of Defense:
DRRS: Defense Readiness Reporting System:
EMAC: Emergency Management Assistance Compact:
FEMA: Federal Emergency Management Agency:
HRF: Homeland Response Force:
NGB: National Guard Bureau:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
December 7, 2011:
Congressional Requesters:
The potential use of weapons of mass destruction”characterized by the
Department of Defense (DOD) as chemical, biological, radiological,
nuclear, and high-yield explosive (CBRNE) material”-presents a
continuing threat to the United States and its citizens. The 2010
National Security Strategy emphasizes the importance of strengthening
our security and resilience at home and building our capability to
respond to and recover from major CBRNE incidents.[Footnote 1]
A catastrophic CBRNE incident in the United States would require a
unified national response involving entities at the local, state, and
federal levels. Responding to a major CBRNE incident would include
such response partners as local and state police and fire departments,
state National Guard forces, and federal agencies”including the
Federal Emergency Management Agency (FEMA) and possibly federal
military forces, such as the U.S. Marine Corps‘s Chemical Biological
Incident Response Force.
The National Guard provides governors with a wide array of
capabilities to assist in mitigating the consequences of a CBRNE
incident”referred to as consequence management. These capabilities
include (1) CBRNE detection/identification, which is provided by the
Weapon of Mass Destruction Civil Support Teams (CST), and (2) search
and rescue, patient decontamination, and medical capabilities that are
provided by CBRNE Enhanced Response Force Packages (CERFP). Both of
these National Guard capabilities are under the command of the
respective state governors via the state adjutants general[Footnote 2]
but could also be part of a federal response, if so designated by the
President. In the latter case, these National Guard forces would most
likely come under the command of DOD‘s U.S. Northern Command.
The National Guard established 12 CERFPs in 2004 in order to perform
the CBRNE response mission and has placed at least one of them in each
of the 10 FEMA regions. In 2006, Congress authorized end strengths for
the Army National Guard and Air National Guard that, according to the
conference report accompanying the National Defense Authorization Act
for Fiscal Year 2006, would allow for the creation of five additional
CERFP teams for a total of 17 CERFPs.[Footnote 3] DOD has described
the CERFP program as the life-saving bridge between local and state
responders and a federal DOD response. Because these packages are
formed from existing units primarily staffed with part-time National
Guard personnel who usually are also responsible for other missions,
concerns have arisen regarding their ability to respond effectively
during a major CBRNE incident. The National Guard Bureau (NGB) is
responsible for managing the CERFP program and is a principal channel
of communication between DOD and the states. [Footnote 4] In fiscal
year 2010 the federal government provided the CERFP program
approximately $20 million through the Departments of the Army and of
the Air Force for personnel, training, and equipment. At the state
level each adjutant general provides command and oversight to the
CERFP in that state (as part of the National Guard). Each state also
has some form of emergency management agency that coordinates
emergency response plans and activities for the governor.[Footnote 5]
This report is the latest in a body of work GAO has issued since 2006
on elements of National Guard and active DOD CBRNE consequence
management capabilities. In May 2006, we reported that the CSTs were
generally organized and prepared for their mission, although we
highlighted management challenges that needed to be addressed.
[Footnote 6] DOD has since taken action on all of the recommendations,
including clarifying the teams‘ mission and establishing a
standardized evaluation program to evaluate the teams. We did not
include the CERFPs in our scope at the time because the program was
just getting started. We reported in 2009 that as part of a federal
response, DOD planned to provide needed capabilities for CBRNE
consequence management through the brigade-sized CBRNE Consequence
Management Response Forces (CCMRF) but that this response may be
insufficient, and that challenges remain in force structure planning
and in ensuring personnel and equipment for the CCMRF.[Footnote 7]
Further, the 2010 Quadrennial Defense Review initiated changes to the
existing structure of DOD‘s consequence management response efforts.
[Footnote 8] These changes included shifting National Guard resources
to create new Homeland Response Forces (HRF) in each of the 10 FEMA
regions. DOD intends to use these forces to provide, among other
things, command and control to CERFPs.
As requested and agreed with your office, we are reporting on the
CERFPs as part of our body of work on DOD‘s CBRNE consequence
management response capabilities. This report assesses (1) how well
CERFPs are prepared to perform their mission based on comprehensively
evaluated requirements and how such readiness is measured and
reported; (2) how effectively CERFPs are coordinating with response
partners and how well this effectiveness is evaluated; and (3) the
extent to which an effective framework has been established to command
and control the CERFPs during CBRNE consequence management operations.
To address our objectives, we reviewed regulations, studies and
memorandums regarding the status of the CERFP program and compared the
current status of the program with the requirements set forth in DOD
and NGB guidance. To further address our objectives, we conducted five
site visits to observe CERFP field training exercises including those
where CERFPs were being evaluated on their mission proficiency and
those where CERFPs were training with other response partners. To
obtain views at both the state National Guards and state emergency
management agencies, we developed and administered surveys to (1)
State Adjutants General of all 17 states that host CERFPs, (2) state
level emergency managers in all 17 of the states that host CERFPs, and
(3) State Adjutants General and state-level emergency managers from 10
non-randomly selected states that do not host CERFPs, including one
from each of the 10 FEMA regions. All of the 17 State Adjutants
General and 13 of the 15 emergency managers in states that host CERFPs
responded to our survey. Also, all of the 10 State Adjutants General
and 7 out of the 9 emergency managers we surveyed from states that did
not host CERFPs responded.[Footnote 9] These surveys addressed
questions regarding command, control and coordination, collective
training, and issues related to the implementation of the HRF program.
Additionally, the survey given to state Adjutants General in states
that host CERFPs also addressed their preparedness. To supplement this
information, we conducted interviews with representatives of all 17
CERFPs, as well as officials from DOD and NGB, and performed content
analysis of the CERFP interview responses to identify recurring themes
and perspectives.
To further identify the extent to which the CERFPs are prepared to
execute their mission in terms of required equipment, staffing,
training, and funding, we also reviewed readiness data within the
National Guard‘s CERFP-specific, spreadsheet-based readiness system
and CERFP readiness data from the DOD‘s Defense Readiness Reporting
System (DRRS) to determine the mechanisms for and the processes
involved in CERFP readiness reporting.
We conducted this performance audit from December 2009 to December
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. Appendix I
provides additional details on the scope and methodology of this
report.
Background:
The National Response Framework establishes the principles that guide
all response partners in preparing for and providing a unified
national response to disasters--including those involving chemical,
biological, radiological, nuclear, and high-yield explosive materials.
[Footnote 10] Under the Framework, disaster response is tiered; local
governments and agencies typically respond immediately following an
incident. When additional resources are requested, a state may provide
assistance with its capabilities, including its National Guard, or may
request assistance from other states through interstate mutual
agreements or the Emergency Management Assistance Compact (EMAC).
[Footnote 11] If an incident requires capabilities beyond those
available at the local and state levels, the governor can seek federal
assistance. The Department of Homeland Security--via FEMA--is usually
the primary federal agency for coordinating federal assistance,
including that provided by DOD.
Responding to CBRNE-related incidents can be especially challenging
because of the additional measures needed to work in a contaminated
environment and to treat victims who may have been exposed to
contaminants. DOD plays a support role in managing the consequences of
CBRNE incidents, including providing those capabilities needed to save
lives, alleviate hardship or suffering, and minimize property damage
caused by the incident. DOD has developed specialized CBRNE response
capabilities that could augment a federal CBRNE response and
contribute to the organization, training, and equipping of state-
controlled National Guard capabilities focused on CBRNE response.
These capabilities include those provided by the:
* National Guard CSTs, which are comprised of 22 full-time personnel,
with at least one team located in each state, the District of
Columbia, U.S. Virgin Islands, Puerto Rico, and Guam. There are a
total of 57 civil support teams.
* National Guard CERFPs, which are comprised of roughly 200 personnel,
with at least one team located in each of the 10 Federal FEMA regions.
There are a total of 17 CERFPs. (See figure 1):
* DOD's Defense Chemical, Biological, Radiological, and Nuclear
Response Force (DCRF), consisting of approximately 5,200 troops
separated into two force packages to provide federal military
assistance in response to a request for assistance from a state
governor, a lead federal agency, or at the direction of the President
when a CBRNE incident exceeds local and state capabilities--including
the CSTs and CERFPs. DOD previously referred to this force as the
CCMRF.
Figure 1: States That Have CERFPs within the 10 FEMA Regions:
[Refer to PDF for image: illustrated U.S. map]
CBRNE Enhanced Response Force Package states:
Region 1:
Massachusetts.
Region 2:
New York.
Region 3:
Virginia;
West Virginia.
Region 4:
Florida;
Georgia.
Region 5:
Illinois;
Minnesota;
Ohio.
Region 6:
Texas.
Region 7:
Missouri;
Nebraska.
Region 8:
Colorado.
Region 9:
California.
Region 10:
Washington.
Source: GAO analysis of NGB and DOD information.
[End of figure]
The CERFPs are intended to provide state governors with the
capabilities that could relieve or augment first responders within the
first few hours after an incident. CERFPs also serve to bridge the
capability gap between the time local and state civilian first
responders arrive and the time a federal response--including
federalized DOD capabilities--is likely to be available during a large-
scale CBRNE incident. Figure 2 shows the approximate time frames that
the forces listed above are expected to deploy to a CBRNE incident
after being notified to respond.
Figure 2: Approximate Time Frames within Which Some DOD CBRNE
Consequence Management Forces Are Expected to Deploy after an Incident:
[Refer to PDF for image: illustration]
CBRNE Incident:
National Guard Weapon of Mass Destruction Civil Support Teams Response:
immediate to 24 hours.
National Guard CBRNE Enhanced Response Force Packages:
6 to 48 hours.
Defense Chemical, biological, Radiological, and Nuclear Response Force
(DCRF):
24 hours to 96 hours.
Source: GAO from DOD information.
[End of figure]
As National Guard units, CERFP personnel may operate in Title 10
status, Title 32 status or state active duty status.[Footnote 12]
Personnel in a Title 10 status are federally funded and under the
command and control of the President. Personnel in a Title 32 status
are federally funded, but under the command and control of the
governor. Title 32 status is the status in which National Guard
personnel typically perform training for their federal mission.
Personnel in state status are under the command and control of the
governor and are state funded.
NGB is responsible for managing the CERFP program and is the principal
channel of communication between DOD and the states. The CERFPs are
comprised primarily of part-time reservists who are drawn from
National Guard units in the host state or, in some cases, from other
states. These reservists who comprise the CERFPs also support their
reserve unit's dual missions--wartime and domestic missions. They are
expected to train for both traditional military responsibilities and
specialize in CBRNE consequence management responsibilities. Figure 3
shows how CERFP units are built from other National Guard elements.
Figure 3: CERFPs Are Formed from the State's National Guard:
[Refer to PDF for image: illustration]
State National Guard:
Unit members serve part-time;
Occasional rotation of parent units including to serve in overseas
contingencies.
Parent units contain multiple personnel and those assigned to CERFP.
CERFP elements are comprised of personnel from National Guard units.
Parent unit: Battalion or Squadron Headquarters:
CERFP elements[A]: Command and Control:
* Authorized number of personnel: 16;
* Direct the employment of CERFP response elements;
* Coordinate with military and civilian response partners;
* Establish communications operations.
Parent unit: Medical Group:
CERFP elements[A]: Medical:
* Authorized number of personnel: 45;
* Medical triage;
* Emergency medical care;
* Patient tracking,
Parent unit: Engineer Company:
CERFP elements[A]: Search and Extraction;
* Authorized number of personnel: 50;
* Victim search and extraction operations;
* Confined space rescue and recovery operations.
Parent unit: Chemical Company:
CERFP elements[A]: Decontamination;
* Authorized number of personnel: 75;
* Mobile and immobile victim decontamination and monitoring;
* Contaminant monitoring.
Parent unit: Fatality Search and Recovery Team:
CERFP elements[A]: Fatality Search and Recovery Team;
* Authorized number of personnel: 11;
* Fatality search and recovery operations;
* Movement of fatalities to transfer points designated by the Incident
Commander.
Source: GAO analysis of NGB information.
[A] The CERFP elements are usually geographically separated within the
host state, and occasionally across multiple states.
[End of figure]
The CERFPs are formed from existing units within a state. Typically,
Army National Guard chemical units and engineering units are the
sources of the decontamination element and the search and extraction
element, respectively. Air National Guard medical units are the source
of the medical element. National Guard battalion or squadron
headquarters units are the source of the command and control element.
The CERFP regulation requires all CERFPs to undergo formal external
evaluations of their mission capability when initially established and
that they be reevaluated periodically, between months 24 and 36 in the
CERFP training cycle, or earlier if the state determines it is
necessary.[Footnote 13] In order to prepare the CERFPs for their
mission, NGB has allotted CERFP members 14 additional training days
beyond the 39 traditional days allotted to most other National Guard
members. CERFP members use this additional time to conduct required
individual training in domestic operations and to train collectively
at least twice a year.
DOD measures a unit's readiness based on its ability to perform the
functions necessary to execute the mission for which it was designed,
based on identified indicators; these include possessing the required
personnel, equipment, and training, and having established reporting
systems to communicate readiness status. On June 3, 2002, DOD
established the Defense Readiness Reporting System (DRRS)--a
capabilities-based, adaptive, near-real-time readiness reporting
system--which measures and reports on the readiness of military forces
and the supporting infrastructure to perform mission essential tasks.
In addition, in June 2004, the Secretary of Defense directed the Under
Secretary of Defense for Personnel and Readiness to develop DRRS in a
manner that would support the data requirements of various users of
readiness information, such as the Chairman of the Joint Chiefs of
Staff, the combatant commands, the secretaries of the military
departments, and the Chief of the National Guard Bureau, including
their requirements for data on the availability, readiness, and
redeployment of forces.[Footnote 14]
The 2010 Quadrennial Defense Review introduced several key changes to
DOD's CBRNE response strategy to enhance the life-saving capabilities
and flexibility of its forces and reduce response times. These changes
include plans to restructure two of its three CBRNE response forces in
order to establish 10 state-controlled Homeland Response Forces (HRF)-
-one in each of the 10 FEMA regions.[Footnote 15] The HRFs are to be
comprised of elements from existing National Guard forces and are
expected to be able to deploy within 6 to12 hours of an incident.
Eight of the HRFs will be hosted by single states, while the other two
will be sourced from multiple states within those regions.
Each HRF will be composed of approximately 570 personnel including a
brigade-sized command and control headquarters organization. In
addition, HRFs will possess the same life-saving capabilities as a
CERFP and will also have a security force element. Each HRF will be
capable of providing command and control for up to five CSTs and three
CERFPs and will be expected to focus on planning, training, and
exercising within its FEMA region, with the goal of establishing links
between the local, state, and federal authorities.
The first two HRFs, hosted by Ohio and Washington, are expected to be
operational by the end of fiscal year 2011; the remaining eight--New
York, Massachusetts, Pennsylvania, California, Texas, Missouri,
Georgia and Utah--are expected to follow by September 2012. Each of
the HRFs, except Utah's, will be converted from an existing CERFP. In
order to maintain the National Guard's prescribed force structure of
17 CERFPs, new ones will be established in 9 states to replace the
CERFPs converting to HRFs. Figure 4 shows the placement of existing
CERFPs and the anticipated placement of future CERFPs and HRFs.
Figure 4: States That Will Host CERFPs and Homeland Response Forces by
September 2012:
[Refer to PDF for image: illustrated U.S. map]
Region 1:
CERFP state:
Maine;
HRF state:
Massachusetts.
Region 2:
CERFP state:
Puerto Rico;
HRF state:
New York.
Region 3:
CERFP states:
Kentucky;
Virginia;
West Virginia.
HRF state:
Pennsylvania.
Region 4:
CERFP states:
Alabama;
Florida;
HRF state:
Georgia.
Region 5:
CERFP states:
Indiana;
Illinois;
Minnesota;
Wisconsin
HRF state:
Ohio.
Region 6:
CERFP state:
Louisiana;
HRF state:
Texas.
Region 7:
CERFP state:
Nebraska;
HRF state:
Missouri.
Region 8:
CERFP state:
Colorado;
HRF state:
Utah.
Region 9:
CERFP states:
Hawaii;
Nevada;
HRF state:
California.
Region 10:
CERFP state:
Oregon;
HRF state:
Washington.
Source: GAO analysis of NGB and DOD information.
[End of figure]
CERFPs Face Personnel, Training, and Equipment Requirements
Challenges, and Readiness Is Not Comprehensively Reported:
The National Guard's CERFPs face personnel, training, and equipment
challenges that increase the risk that they are not fully prepared to
effectively execute their domestic CBRNE consequence management
mission. State Adjutants General and CERFP officials cite that CERFPs
often have the authorized levels of personnel and equipment but that
these levels don't reflect actual needs. They also further cite
personnel, training, and equipment deficiencies that may reduce the
effectiveness of a potential CERFP response. In part, this can be
attributed to NGB's not systematically reevaluating personnel,
training, and equipment requirements to determine if they are
appropriate. CERFPs also have difficulty maintaining proficiency in
many of the specialized tasks they could be called on to perform
during a CBRNE incident, because they train infrequently or not at all
on key deployment tasks and with all CERFP elements and interagency
response partners. NGB has developed new training goals but does not
have a strategy to assure CERFP progress in achieving these goals. In
addition, comprehensive CERFP readiness information is not available
to potential DOD response partners, because such information is
captured in an informal spreadsheet and not yet available in DOD's
centralized readiness reporting system. This impedes the ability of
all response partners to know how prepared CERFPs are to fit into a
broader CBRNE consequence management response. NGB does not have a
plan with timelines for completing the transition of reporting CERFP
readiness data into DOD's readiness reporting system.
CERFPs Are Challenged in Maintaining Adequate Numbers of Personnel to
Execute the CERFP Mission:
The CERFPs are intended to provide state governors and incident
commanders with life-saving capabilities that could relieve or augment
first responders after an incident. NGB guidance states that CERFPs
must be fully trained and prepared to deploy when notified of a CBRNE
event. Each CERFP is expected to be ready at all times to deploy to a
regional or national level response within 6 hours. The CERFPs are
staffed primarily with traditional National Guard personnel, who are
part-time. But NGB also provides some full-time staff to carry out the
day-to-day administrative and preventive equipment maintenance
activities of the CERFP. Each CERFP is currently authorized a total of
186 personnel; five of whom are designated as full-time.[Footnote 16]
This full-time staffing level contrasts with other DOD CBRNE-related
capabilities staffed with higher percentages of full-time personnel.
For example, all 22 personnel assigned to each of the CSTs who respond
to events to ascertain the type of chemical or biological attack that
has occurred, are full-time.[Footnote 17] Also, the Marine Corps'
Chemical Biological Incident Response Force, which served as the model
for the CERFP, uses all full-time personnel. Both state Adjutants
General and CERFP officials stated that five full-time personnel are
not enough to meet the day-to-day requirements. For example, 10 of the
17 state Adjutants General we surveyed responded that their state's
CERFPs did not have a sufficient number of full-time personnel to
support their daily planning and operating requirements. Similarly,
officials from 13 of the 17 CERFPs we interviewed also said that an
insufficient number of full-time personnel challenged their ability to
adequately perform tasks, such as training personnel, maintaining
equipment, and coordinating with other response organizations.
Additionally, CERFP officials stated that having a larger core of full-
time personnel could better ensure preparedness for responding to
potential CERFP deployments.[Footnote 18] According to the NGB
officials we spoke with, the CERFPs have raised the need for
additional full-time staff positions and stated that NGB plans to add
five full-time personnel to each CERFP between fiscal years 2012 and
2013 for a total of ten full-time personnel, but no specific study had
been performed to determine whether ten full-time personnel would be
sufficient to perform the CERFP's daily planning and operating
requirements.
State Adjutants General we surveyed reported that authorized levels of
personnel for each aspect of the mission were generally available but
would not meet the program requirements of being available and
qualified all of the time. As shown in table 1, just over half of the
17 state Adjutants General reported that, as of October 2010, their
CERFPs' authorized levels of personnel would not meet program
requirements to be available to conduct selected aspects of their
mission all of the time.
Table 1: Number of CERFPs with Authorized Levels of Personnel
Available to Perform Mission Tasks All of the Time, as Reported by
State Adjutants General:
Authorized levels of personnel have been available and qualified to:
Perform command and control of CERFP operations;
All of the time: 13;
Less than all of the time: 4.
Authorized levels of personnel have been available and qualified to:
Perform intended mission;
All of the time: 8;
Less than all of the time: 9.
Authorized levels of personnel have been available and qualified to:
Perform hazardous materials operations;
All of the time: 8;
Less than all of the time: 9.
Authorized levels of personnel have been available and qualified to:
Perform search and rescue operations;
All of the time: 8;
Less than all of the time: 9.
Source: GAO Survey of CERFP State Adjutants General.
Note: These numbers are based on a total of 17 CERFPs.
[End of table]
NGB's authorized levels of personnel for the CERFPs are considered
insufficient by CERFP officials and state Adjutants General. Officials
from 11 of the 17 CERFPs we interviewed stated that these levels were
insufficient for at least one of the elements (medical, search and
extraction, decontamination, command and control) of their CERFP. For
example, several CERFP officials stated that the personnel
authorization for the decontamination element should be doubled in
order for decontamination personnel to be able to perform sustained
operations, or because of the need to frequently cycle replacement
personnel who suffer fatigue from operating in protective suits and
respirators. During some field training exercises, we observed
personnel suffering from heat-related injuries, thereby reducing the
number of available personnel. Exercise evaluators present at one of
the training exercises we observed stated that more typical summer
temperatures would have further reduced the amount of time that
personnel could spend in the protective suits, increasing the need for
replacements. To address these insufficiencies, some states have been
assigning additional personnel in order to have better assurance that
their states have a sufficient number of personnel to perform the
mission. State Adjutants General we surveyed reported that they use
different approaches to ensure that they have a sufficient number of
people to execute the CERFP mission. The following reflect some of the
comments we received regarding how different states individually
address personnel deficiencies:
* Assigns close to 280 personnel to ensure that the CERFP will have
the 186 personnel authorized for the CERFP.
* Plans to assign the entire company of 160 to perform decontamination
tasks, instead of the authorized 75 personnel for this element.
* Assigns an entire battalion headquarters staff to perform CERFP
command and control functions, instead of the 16 personnel authorized.
* Assigns 420 personnel in order to have 186 personnel mission-ready.
NGB officials stated that the CERFP was initially developed in 2003 as
a prototype capability and was developed quickly to fill a gap in
DOD's CBRNE response capabilities. Accordingly, CERFPs, including
their size, were designed largely based on the composition of the
Marine Corps' Chemical Biological Incident Response Force, which was
the only DOD CBRNE response capability at that time. Initial personnel
authorizations have been modified by field experience during the
prototype period, but no comprehensive CERFP unit-level study has been
conducted to determine if the number of assigned personnel could meet
workload requirements, such as stated victim-throughput goals,
subsequent to the CERFP's being approved as a formal DOD program in
2008. NGB officials stated that some of the discrepancy between the
number of personnel used by individual CERFPs and the number of
personnel authorized is caused by differences in assumptions about
whether individual CERFPs will be operating continuously for 24 hours.
NGB envisions that additional CERFPs from other states, as well as
future Homeland Response Forces, could provide augmentation for larger
scale incidents that could mitigate the number of personnel needed by
individual CERFPs. However, unless these personnel challenges that
have been frequently raised by CERFPs and the states Adjutant Generals
are addressed in a comprehensive and systematic manner, there is
reduced assurance that individual CERFPs have the proper number of
personnel.
CERFPs Are Challenged to Maintain a Trained and Ready Response Force
and Do Not Have a Training Strategy or a Mechanism to Track CERFP
Participation:
CERFPs face challenges in maintaining a trained and ready response
force because there are (1) limited opportunities for all elements to
train collectively and with other civilian and military response
partners, (2) competing demands from other missions, and (3) limited
training opportunities on key deployment tasks that CERFPs could be
called on to perform during a CBRNE incident. NGB recently published
new collective training goals that provide promise for focusing future
training, but NGB does not have a programwide strategy for CERFPs to
achieve these goals within the time and funding that CERFPs are
provided or a mechanism to track whether CERFPs are receiving
opportunities to conduct the necessary training.
To achieve mission proficiency, National Guard guidance requires the
personnel of each CERFP element to participate in collective training
exercises, among other kinds of training. One purpose cited is to
bring all CERFP elements together to conduct the collective tasks in a
realistic training environment. National Guard guidance and joint
training guidance also require CERFPs to conduct at least two state or
national level collective training exercises annually under realistic
conditions, and to be externally evaluated periodically, between
months 24 and 36 in the CERFP training cycle or earlier if the state
determines it is necessary.[Footnote 19] Upon successful completion of
an external evaluation, state Adjutants General validate that their
CERFP is properly staffed, equipped, trained and ready to respond, and
will submit a validation letter to the NGB. According to NGB
officials, all 17 original CERFPs were evaluated as "trained" during
their most recent external evaluation exercises, which were conducted
between 2009 and 2011 and were validated by the state Adjutants
General. NGB officials do not track whether CERFPs meet the annual
collective training exercise goals found in guidance, but CERFP
officials we interviewed stated that the collective training field
exercises are conducted infrequently. As a result, CERFP officials
stated that units lose proficiency as skills acquired during these
exercises decline over time. For example, officials from six CERFPs
stated that because of the time that had elapsed from their prior
collective field training exercises, their CERFP needed several days
of training before regaining proficiency. More specifically, one CERFP
commander stated that because some critical skills are perishable, it
is difficult to maintain proficiency between external evaluations.
Similarly, another CERFP commander noted that maintaining skill
proficiency with limited training opportunities is a challenge and
that it takes his CERFP several days of field training to "knock the
rust off" of skills necessary to perform their mission requirements.
An official from another CERFP stated that the infrequency of training
makes it feel as if they are starting from scratch each time they
train collectively. Moreover, all elements that comprise the CERFP are
not always present for all collective field exercises. For example,
officials from 8 of the 17 CERFPs we interviewed told us that their
CERFP had never trained with its Fatality, Search, and Recovery Team
element, and nine of the CERFPs we interviewed told us that their
medical elements are often unable to participate in all collective
field training exercises because funding or personnel are unavailable.
Regulations and training guidance require CERFPs to conduct at least
two state or national level collective training exercises annually
under realistic conditions, but we found that interagency
participation in CERFP training events is similarly limited, creating
few opportunities for CERFPs to integrate with other response
organizations that may be present during a large-scale incident. For
example, according to the results of our four surveys, most CERFPs
have had limited opportunities to train with other key partners, such
as federal DOD response organizations and state emergency management
agencies. For additional information regarding interagency
participation in CERFP training events, see appendix II. As a result,
CERFPs have little assurance that they can operate effectively with
other potential response partners. As we discuss later, such limited
interaction between CERFPs and interagency partners also affects the
establishment of viable command and control relationships.
Moreover, we found that NGB training guidance is vague regarding the
extent to which CERFPs should participate with potential interagency
response partners and that NGB has not articulated a strategy for
ensuring that CERFPs conduct interagency training or developed a
methodology to track the extent that CERFPs train with these partners.
According to the 2008 CERFP Joint Training Plan, CERFPs were
encouraged to include potential response partners in collective team
training exercises and were required to participate in at least one
regional exercise in fiscal year 2008 or 2009 in an interagency
environment under the control of the CERFP's state National Guard
headquarters.[Footnote 20] NGB has not provided specific guidance for
participation in interagency field exercises (including the frequency
of that participation) beyond 2009.[Footnote 21]
CERFPs also face challenges in maintaining proficiency because the
CBRNE mission is not the only mission that units are responsible for
performing. The dual capability nature of the National Guard
necessitates that units meet operational and training requirements for
both the CERFP and the wartime mission. For example, officials from a
majority of the CERFPs we interviewed stated that unit rotations are a
challenge to maintaining proficiency as new personnel have to be
trained. Officials from 13 of the 17 CERFPs we interviewed stated that
they had had at least one element replaced by personnel from another
unit because of unit rotations necessitated by, among other things,
overseas deployments. One state Adjutant General commented that the
current requirement to deploy within 6 hours after notification
requires additional study because it is difficult to achieve in a part-
time environment. This Adjutant General believed that the 6-hour
requirement was based on the National Guard CST model, which provides
22 full-time personnel who are solely dedicated to the civil support
mission. Moreover, preparing for both the CERFP and wartime mission
while in a part-time status is also difficult. For example, 10 of the
17 state Adjutants General we surveyed reported most or all of their
CERFP elements have had difficulty in managing competing requirements
from other domestic or warfighting missions, and officials from 14 of
the 17 CERFPs we interviewed stated that balancing such competing
requirements is a challenge.
Maintaining a trained force is also challenging because CERFPs have
not conducted key deployment exercises that could enhance their
assurance that they could deploy rapidly throughout the country.
National Guard guidance states that an incident taking place beyond a
500-mile radius of a CERFP's home station could warrant the use of
aircraft rather than ground transportation to move necessary equipment
and personnel.[Footnote 22] This guidance states that training CERFPs
for air transport activities allows these forces to become familiar
with the loading and unloading of equipment in the event that units
must travel by air. However, 11 of the 17 State Adjutants General we
surveyed stated that their CERFP had never practiced loading or
transporting equipment and personnel by aircraft to either a real-
world or simulated event. Consequently, if a CBRNE incident occurred
more than 500 miles from the nearest CERFP's home station or if road
travel became infeasible, then more than half of the 17 CERFPs would
not be adequately trained to rapidly deploy by air to an incident.
Also, rapid response organizations conduct exercises to evaluate their
ability to respond without prior notice to a simulated operational
emergency, under conditions similar to those that may be encountered
during an actual emergency. Officials from 13 of 17 CERFPs told us
that their CERFP had not conducted a no-notice deployment exercise to
test the ability to assemble and conduct deployment activities within
time frames required for the mission. However, officials from 6 CERFPs
told us that they have conducted telephone or other alert exercises to
confirm the extent that their personnel can be located and estimate
how long it may take to arrive at a designated area. A common theme
from CERFP officials was that it would be impractical to conduct such
exercises because it would strain relations between Guardsmen and
their full-time employers as it would further increase the time that
personnel may be away from their workplaces.
NGB recognizes the need to improve aspects of CERFP field training
exercises. To improve training focus, it has recently issued new
training guidance in March 2011 that establishes several new
collective training goals that CERFPs should address during the fiscal
year.[Footnote 23] Specifically, fiscal year 2011 training goals
include:
* working to demonstrate interoperability with other CERFPs and other
National Guard CBRNE organizations;
* exercising within local and State Incident Command Systems and with
first responders;
* conducting air movement training to include load-planning,
deployment, and redeployment operations;
* conducting at least two no-notice recall exercises;
* conducting joint training with active duty and other DOD CBRNE
response organizations;
* expansion of CERFP liaison with local, state, and regional agencies;
and:
* increasing opportunities to exercise with and evaluate the Fatality,
Search, and Recovery Team.
Moreover, NGB officials stated that they are developing plans to have
CERFPs train in regional and national level exercises, including
exercises with U.S. Northern Command's Defense CBRN Response Force.
These training goals provide promise for focusing future training, but
they do not provide a programwide framework for how all CERFPs will
achieve these goals within the time and funding that CERFPs are
provided, particularly if all of these goals are to be met every
fiscal year. CERFP officials have identified instances where training
was not accomplished in the past because funding was unavailable or
personnel were unavailable because of their part-time status. Without
a strategy for accomplishing this training across the CERFP program,
NGB has reduced assurance that all CERFPs will achieve and maintain
proficiency and will be prepared to integrate effectively with local,
regional, and federal response partners. Additionally, NGB's process
for managing and tracking the CERFPs' inclusion in these exercises is
decentralized, providing little assurance that all CERFPs have such
opportunities. For example, NGB selects the CERFPs that participate in
these events on a volunteer rather than a rotational basis; as a
result, participation is partially driven by CERFP initiative and
availability, which varies across the CERFP program. Further, NGB
training officials told us that they do not comprehensively track
CERFP participation in interagency exercises to determine how
frequently each CERFP trains with interagency partners. Without
specific and reliable data to track participation, NGB has little
assurance that all CERFPs are getting access to the range of potential
response partners that they may have to work with during a CBRNE
incident.
CERFPs Generally Have Their Authorized Equipment, but Additional
Equipment May Be Needed to Adequately Perform Mission:
The NGB has deemed certain specialized equipment critical for the
CERFPs' mission and has authorized the CERFPs to have specific
quantities of this equipment. This specialized equipment, much of
which is different from the equipment authorized for wartime missions,
includes commercial-off-the-shelf items such as collapsed-structure
listening devices, search cameras, specialized respiratory masks,
extraction tool kits, and mass decontamination equipment. Most
Adjutants General reported that their CERFPs had the authorized
quantities of equipment all or most of the time. Table 2 shows the
Adjutants General survey responses regarding the number of CERFPs that
generally had their authorized quantities of equipment needed to
perform four types of tasks as of October 2010.
Table 2: Number of CERFPs That Had Authorized Quantities of Equipment
as of October 2010:
CERFPs had the authorized levels of equipment needed to: Conduct mass
casualty decontamination;
All of the time: 12;
Most of the time: 5;
Some of the time: 0.
CERFPs had the authorized levels of equipment needed to: Extract
victims from contaminated environments;
All of the time: 10;
Most of the time: 7;
Some of the time: 0.
CERFPs had the authorized levels of equipment needed to: Provide
emergency medical triage services;
All of the time: 11;
Most of the time: 6;
Some of the time: 0.
CERFPs had the authorized levels of equipment needed to: Perform
command and control;
All of the time: 12;
Most of the time: 4;
Some of the time: 1.
Source: GAO survey of State Adjutants General.
Note: Numbers are based on a total of 17 CERFPs.
[End of table]
However, despite reporting that CERFPs generally have the equipment
they are authorized, CERFPs stated that they do not have some critical
equipment specific to the CBNRE mission. Specifically, our surveys and
interviews showed some CERFPs were concerned about the adequacy of
their protection and transportation equipment. For example, some CERFP
officials we interviewed stated that the authorized quantity of
protective equipment (suits and respirators) provided to CERFPs and
the level of protection it provides is inadequate for responding to a
domestic CBRNE incident in some instances.[Footnote 24] CERFP
officials stated that the current protective suits worn by CERFP
personnel are not well suited for domestic CBRNE incidents because
they do not protect against the full range of potential toxic
materials CERFP personnel may be exposed to. Another CERFP official
stated that the respirators do not provide the appropriate level of
protection. A CERFP working group has raised concerns to NGB about the
adequacy of protection provided by the currently authorized protection
equipment, but no solution has been identified. Officials from one
CERFP expressed concern that the issue has not received high priority.
To the extent that equipment shortfalls exist, CERFPs' effectiveness
in responding to domestic incidents will be limited.
State Adjutants General and CERFP officials told us that because
authorized quantities of equipment are not always adequate to
successfully operate in a domestic CBRNE environment, state National
Guards have provided CERFPs with extra equipment, predominately to
facilitate their transportation and communication. For example, 11 of
the 17 state Adjutants General reported in our survey that their
state's National Guard had provided their CERFPs with equipment beyond
what is authorized so that the CERFP could better execute its mission.
They commonly cited vehicles to transport CERFP personnel and
communications equipment. Officials from a majority of CERFPs stated
in interviews that their authorized vehicles are not sufficient to
transport the entire CERFP to an incident site. To correct the
transportation equipment deficiency, NGB has plans to provide a
standardized solution to transporting CERFPs by providing buses and
vans during fiscal year 2011 to provide ground transportation for
CERFP personnel.
National Guard Has Not Established an Annual Requirement Review and
Validation Process:
National Guard guidance states that integrated working groups will be
established to annually review and validate CERFP personnel, training,
and equipment.[Footnote 25] NGB has taken steps to establish and
maintain various mechanisms to identify deficiencies in the CERFPs'
personnel, training, and equipment capabilities, but these efforts
have not yet led to a process that would comprehensively review
program requirements. For example, various working groups and
conferences are used as forums to discuss potential resource
deficiencies, corrective actions, and other mitigation strategies.
However, a formal process is not yet in place that could validate
shortfalls and determine solutions. NGB drafted a CERFP working group
charter in November 2009 that provides the basis for annually
reviewing and validating program requirements raised by the working
groups. But the charter has never been approved, and thus the formal
process has not been established. NGB has addressed some deficiencies
such as transportation equipment and is evaluating communication
equipment deficiencies, but without a formal review process, it is
unable to comprehensively assess program requirements to address
potential deficiencies in personnel, training and equipment.
CERFP Readiness Data Is Not Transparent or Complete and Cannot Be
Efficiently Disseminated to Other DOD Response Partners:
NGB has not yet implemented a readiness reporting system that can
comprehensively report readiness data and share it with DOD
stakeholders and the data being collected is not complete. NGB is
currently using a stand-alone spread-sheet-based system as the primary
method for measuring the CERFPs' readiness, but it is not integrated
with other readiness systems that are used by DOD units, and there is
no plan with timelines for completing the transition to integrated
CERFP readiness with these other DOD readiness systems. CERFP
readiness information is also found in other DOD readiness systems,
but it is not standardized, comprehensive, or consistently reported.
As such, NGB cannot facilitate efficient dissemination of complete and
accurate readiness data to potential response partners in order to
strengthen coordination on preparedness for CBRNE consequence
management. Moreover, to the extent that program requirements have not
been regularly reviewed, as previously mentioned, CERFP readiness will
be limited by being assessed against potentially unrealistic
authorization levels for the appropriate number and type of personnel,
equipment, and training needed to carry out the CERFP mission.
In 2007, we reported that DOD recognized the need to have greater
visibility over the National Guard's capabilities for domestic
missions and that DOD had begun taking steps to assess the Guard's
preparedness for those missions.[Footnote 26] To achieve this improved
visibility, DOD planned to include in its Defense Readiness Reporting
System (DRRS) information on the National Guard's readiness to perform
both its warfighting missions and domestic missions.[Footnote 27] DRRS
draws from selected DOD computer information systems and databases and
is intended to capture DOD readiness data from multiple sources into a
single integrated, authoritative source and provide these data to DOD
decision makers and other stakeholders.
National Guard guidance requires NGB to establish and maintain a
standardized reporting and information analysis system,[Footnote 28]
and NGB established a spreadsheet-based system in which CERFPs report
on both the readiness of the separate elements that comprise the
CERFP, in terms of various indicators of their CERFP's operational
status, including personnel, equipment, and training levels. CERFPs
also report on an overall assessment of the entire CERFP to perform
mission tasks. This information is reported through secure networks
through the state National Guard, which in turn is submitted to NGB.
Although NGB uses this information to assess CERFP readiness, the
spreadsheets are incompatible with other readiness reporting systems
that feed into DRRS, which is intended to allow a more comprehensive,
DOD-wide picture of readiness to execute critical missions of all
kinds. NGB officials told us that they have been sharing CERFP
readiness information with other DOD response partners, such as U.S.
Northern Command, through informal methods like briefing charts, but
only sporadically.
NGB's goal is to eliminate the spreadsheet-based readiness system and
instead incorporate CERFP readiness information directly into DRRS,
which would improve the consistency and access to readiness
information to all DOD commands with CBRNE response responsibilities.
As of September 2011, NGB had not achieved this goal and did not have
a plan with timelines for completing the steps needed to complete the
transition. At that time, some individual "parent" units were
reporting their wartime readiness in DRRS as well as information on
the elements that those units supply to CERFPs.[Footnote 29] However,
our analysis shows that the readiness information about CERFPs that
was included in DRRS was inconsistently reported by different parent
units or was incomplete compared to information found in the CERFP
spreadsheet-based readiness system. For example, information on the
readiness of any entire CERFP is not available in DRRS. NGB officials
said this is because the CERFP is not a separate reporting entity in
established readiness systems. Rather, CERFP elements' readiness is
reported as a component of the parent units' reporting of their
readiness. We found that 10 parent units, which supply personnel and
equipment to CERFPs, reported on some aspect of CERFP readiness in
addition to their wartime readiness in the Army DRRS. These 10 units
were associated with 4 of the 17 CERFPs (each CERFP may be supplied by
up to 5 units). As we have previously stated, the CERFP mission is
considered an additional mission to the units' wartime mission. As
such, most of the readiness information for those units in DRRS was
related to the unit's wartime mission or core mission. The readiness
information in DRRS for CERFPs was less detailed than information
provided in the NGB CERFP spreadsheet-based readiness reporting
system, which includes details on personnel, equipment, and training
status. As a result, comprehensive and standardized information on
CERFP readiness is not available in DRRS, where it could be shared
with all DOD organizations that have access to the system.
NGB officials confirmed that DRRS contained incomplete CERFP readiness
data and that it does not currently have a mechanism to display the
readiness of the entire CERFP in one place even if all parent units
were accurately and comprehensively reporting on CERFP readiness. NGB
officials stated that they continue to work toward the goal of
eliminating the spreadsheet-based system and instead incorporating all
CERFP readiness information directly into DRRS. This step would make
CERFP readiness status accessible to their DOD response partners.
According to these officials, CERFP readiness information is not yet
visible in DRRS and will not be until NGB has completed the
implementation of its planned reporting mechanism that could
distinguish CERFP readiness information within DOD's centralized
readiness reporting system. NGB's efforts to complete the development
of this mechanism have been delayed several times beyond the original
October 1, 2010, planned completion date. As of September 2011, NGB
had not developed new timelines for completing its efforts. According
to NGB officials, time frame extensions have been granted to implement
new reporting guidance and to establish two new DRRS Centers of
Excellence.[Footnote 30] NGB also has plans to increase state National
Guards' access to DRRS by providing additional secure workstations to
state Guard personnel that would link to DRRS--providing contractor
support to states to assist with DRRS and increasing the number of
state National Guard personnel who are trained to use the DRRS system.
But NGB has not developed a plan for completing these steps. In
addition, NGB officials stated that funding delays have directly
affected their ability to add the personnel who they believe are
necessary to reach full CERFP reporting visibility in DRRS. However,
they told us that they are making progress in other areas that will
contribute to including CERFP readiness information in DRRS, for
example:
* In January 2011, DOD issued a new Directive requiring State National
Guard Joint Force Headquarters to report readiness capability in DRRS,
[Footnote 31] and NGB officials stated that it plans to publish an
order that will provide CERFPs with compliance requirements for
reporting readiness information. As of September 2011, NGB officials
stated that a timetable has not been established to publish the order.
* NGB is refining mission essential tasks by CERFP units' core
missions and operations, and it plans to coordinate with all 54 states
and territories as well as the Joint Staff Headquarters to develop a
joint CERFP mission-essential task list.
* Absent a mechanism to disseminate complete CERFP readiness
information within DOD's readiness reporting system, potential DOD
response partners and stakeholders will not be informed of CERFPs'
capacity to perform their mission. Without more consistent,
comprehensive and accessible reporting of CRFP readiness, the ability
of all response partners to know how prepared CERFPs are to fit into a
broader CBRNE consequence management response is impeded. Furthermore,
without this kind of information, NGB cannot effectively prioritize
funding and mitigate resource deficiencies that could jeopardize the
CERFPs' preparedness levels.
Opportunities Exist to Enhance Coordination with Other Response
Organizations:
CERFPs achieved varying levels of success in coordinating with some of
their potential response partners because of challenges, including (1)
insufficient guidance for how CERFPs should conduct coordination
activities, (2) limited awareness of guidance, and (3) limited time
for conducting coordination activities. NGB is taking steps to
formally evaluate the CERFPs' performance of pre-incident coordination
activities, but NGB's evaluation tool does not have coordination
standards against which CERFP performance can be measured.
Additionally, NGB has identified having interstate agreements between
states with and without CERFPs, as well as advanced planning, as key
to enhancing regional preparedness. Such agreements, however,
generally do not exist, and our review showed that CERFPs are
generally not included in state and local response plans.
CERFPs Achieved Varying Levels of Success in Coordinating with Some of
Their Potential Response Partners:
CERFPs coordinate with some of their potential response partners
through various formal and informal activities, but our review found
that these activities have achieved varying levels of success in terms
of educating potential response partners about CERFP capabilities.
National Guard guidance directs CERFPs to participate in local, state,
and federal emergency response planning meetings and to ensure that
CERFP capabilities are understood and integrated appropriately.
According to the CERFP concept of operations, establishing
relationships with these other response organizations is vital and can
be accomplished through response planning meetings as well as
briefings, fact sheets, and other activities. The concept of
operations also notes that CERFPs can enhance coordinated operations
by ensuring other response organizations are aware of their
capabilities and the processes for requesting support. Most of the
CERFP officials we interviewed stated that they coordinate with some
potential response partners through such activities, as well as
through other mediums, such as conferences.
CERFPs make efforts to coordinate with potential response partners,
but we found these efforts vary in frequency and reach, in part
because there are numerous potential response partners within the
CERFPs' host states, in the related FEMA regions, and at the national
level. For example, officials from 10 of the 17 CERFPs stated that
they are unable to coordinate frequently with most other response
organizations. In addition, about half of the state emergency managers
we surveyed responded that there was little to no coordination with
the CERFPs hosted in their states. The Adjutants General we surveyed
from states that host CERFPs reported a higher opinion of coordination
between their states' CERFPs and emergency management offices. Our
interviews and surveys also indicate that the extent to which CERFPs
interact with local, state, and federal response organizations
differs, and that coordination with federal organizations is
particularly limited. For example, officials from most of the CERFPs
we interviewed said that they interact with the CSTs but have little
to no interaction with other federal response organizations, such as
U.S. Northern Command. These views were also held by the 17 Adjutants
General in CERFP host states whom we surveyed and who generally
reported that with the exception of the CSTs, their states' CERFPs
have limited interaction with potential federal response partners.
Figure 5 shows the response of Adjutants General to our survey,
capturing their perspectives regarding the extent to which CERFPs
interact with various local, state, and federal response
organizations. The extent of views on CERFP interaction with the
listed response organizations varies. Although such variability is
reasonable in some cases, the results also capture instances in which
some of the CERFPs have little to no interaction with key response
organizations at the local, state, and federal levels.
Figure 5: Adjutants General Responses on CERFP Interaction with Local,
State, Regional, and Federal Response Organizations:
[Refer to PDF for image: stacked horizontal bar graph]
Entities:
Local or regional entity:
Fire departments:
CERFPs Interaction:
Great or some extent: 15;
Little or no extend, not sure: 2.
Law enforcement:
CERFPs Interaction:
Great or some extent: 9;
Little or no extend, not sure: 8.
Emergency management agencies:
CERFPs Interaction:
Great or some extent: 13;
Little or no extend, not sure: 4.
Hazardous materials teams:
CERFPs Interaction:
Great or some extent: 10;
Little or no extend, not sure: 7.
State entity:
Hazardous materials teams:
CERFPs Interaction:
Great or some extent: 7;
Little or no extend, not sure: 10.
Police:
CERFPs Interaction:
Great or some extent: 7;
Little or no extend, not sure: 10.
Fire Marshal:
CERFPs Interaction:
Great or some extent: 6;
Little or no extend, not sure: 11.
Emergency Management Agency:
CERFPs Interaction:
Great or some extent: 13;
Little or no extend, not sure: 4.
Office of Environmental Management:
CERFPs Interaction:
Great or some extent: 4;
Little or no extend, not sure: 13.
Federal entity:
Weapons of Mass Destruction Civil Support Teams (CST):
CERFPs Interaction:
Great or some extent: 16;
Little or no extend, not sure: 1.
CBRNE Consequence Management Response Forces (CCMRF):
CERFPs Interaction:
Great or some extent: 3;
Little or no extend, not sure: 14.
Chemical Biological Incident Response Force (CBIRF):
CERFPs Interaction:
Great or some extent: 3;
Little or no extend, not sure: 14.
U.S. Northern Command:
CERFPs Interaction:
Great or some extent: 4;
Little or no extend, not sure: 13.
Joint Task Force-Civil Support:
CERFPs Interaction:
Great or some extent: 1;
Little or no extend, not sure: 16.
FEMA response teams:
CERFPs Interaction:
Great or some extent: 10;
Little or no extend, not sure: 7.
EPA response teams:
CERFPs Interaction:
Great or some extent: 0;
Little or no extend, not sure: 17.
Source: GAO Survey of CERFP State Adjutants General on State CBRNE
Response Capabilities.
[End of figure]
Our surveys and interviews show that the CERFPs' coordination efforts
have achieved varying levels of success in educating response partners
about CERFP capabilities. For example, about half of the CERFPs we
interviewed said that many potential response partners--such as first
responders--have little knowledge of the CERFP's capabilities. In
particular, officials from one CERFP told us that despite coordination
efforts, civilians are generally unfamiliar with CERFP capabilities,
that integration of capabilities within the region is poor, and that
the military lacks understanding of civilian and military force
integration. As an example, they cited a recent exercise in which the
civilian organizations with which they were training thought they were
there to provide site security, whereas CERFPs are designed to augment
first responders with life-saving CBRNE capabilities. Officials from
another CERFP noted that the CERFP concept may be difficult for others
to understand until they have had an opportunity to see the team
operate, such as during a training event. Four of the 13 state-level
emergency managers from states that host CERFPs that responded to our
surveys also said that they had a limited understanding of the roles
and capabilities of their states' CERFPs. For example, one emergency
manager contrasted his office's levels of familiarity with his state's
CERFP and its CST, noting that his office coordinates frequently with
his state's CST, but that he was unfamiliar with CERFPs. Another
emergency manager from a state with a CERFP similarly noted that CSTs
are a constant presence in his state, but that CERFPs and other DOD
assets are less well-known.
Insufficient Coordination Guidance, Limited Awareness of Guidance, and
Other Challenges Inhibit Coordination Efforts:
CERFPs face potential obstacles to conducting successful coordination
with other response organizations, including insufficient guidance for
conducting pre-incident coordination activities, limited CERFP
awareness of guidance, and limited time for conducting coordination
activities. Nearly half of the CERFPs we interviewed and Adjutants
General we surveyed believed that existing DOD and NGB interagency
coordination guidance--including CERFP-specific guidance such as
National Guard Regulation 500-4/Air National Guard Instruction 10-2504
and the CERFP concept of operations--was insufficient, or they were
unsure whether the guidance was sufficient to facilitate the
development and maintenance of cooperative relationships between
CERFPs and relevant federal, state, and local organizations. Many of
the comments that we received from our interviews and surveys
reflected the theme that guidance had limited usefulness in informing
coordination efforts, for example:
* Officials from 5 of the 17 CERFPs told us that their coordination
activities are driven more by their own initiative than by guidance,
suggesting that the utility of existing CERFP coordination guidance is
limited.
* One host state Adjutant General we surveyed responded that guidance
indicates the most likely relationships for various types of
emergencies, but that it does not prescribe the nature and frequency
of coordination efforts, and that state and regional planning efforts
provide more concrete guidance for CERFP coordination.
* Officials from one CERFP we interviewed told us that the guidance
does not detail when and how to seek out interagency partners.
* Officials from another CERFP told us that guidance helped guide
interactions within the state, but not with other states.
We also found that the CERFP guidance addressing coordination is not
specific on where coordination efforts should be focused--such as on
key state or metropolitan area response organizations. NGB officials
told us that CERFPs should coordinate with major response
organizations within their areas or responsibility, including
metropolitan organizations, state agencies tasked with major disaster
response, federal installations, and other DOD response elements.
However, while CERFP coordination guidance stresses the need to
establish relationships with local, state, and federal response
organizations, such as state emergency management agencies and first
responders, it does not include the level of detail noted by NGB
officials, and in particular, it does not (1) delineate the desired
frequency of coordination efforts, (2) define the CERFP area of
responsibility for coordination, (3) specify where CERFPs should focus
their efforts within that area of responsibility, or (4) fully
identify the key types of organizations that CERFPs should target--
particularly at the state and federal levels, and across state lines.
Without more specific guidance, full-time CERFP staff may be unable to
optimize their limited time for coordination activities.
We also found that awareness of coordination guidance within the
CERFPs is limited. For example, officials from 7 of the 17 teams we
interviewed were unaware that CERFP-specific coordination guidance
existed. Officials from one such CERFP told us that they believe
coordination to be the sole responsibility of their state National
Guard. Similarly, officials from another CERFP told us that they
coordinate with local organizations, but that coordinating with state
and federal organizations was the responsibility of their state
National Guard. Ultimately, deficiencies in the clarity of existing
CERFP coordination guidance, coupled with poor awareness of guidance
within the CERFPs, hamper existing coordination efforts and fail to
foster a consistent approach to coordination that is conducive to
achieving the intended outcomes of these activities. By clarifying
CERFP coordination responsibilities in existing guidance and
increasing awareness of such guidance within the CERFPs, NGB could
better ensure the ability of CERFPs to effectively target their
coordination efforts and achieve desired outcomes.
CERFPs face an array of other challenges in coordinating with
potential response partners. Chief among these is limited time to
conduct coordination activities. Officials from 10 of the 17 CERFPs we
interviewed cited this as a challenge to establishing and maintaining
cooperative relationships with relevant federal, state, and local
organizations. Moreover, officials from one CERFP we interviewed told
us that because they had a limited number of full-time staff, they
simply did not have the time to establish and maintain such
relationships. Further, 12 of the 17 Adjutants General we surveyed
from states with CERFPs reported challenges to coordination and
communication between CERFPs and potential response partners, most
commonly citing insufficient personnel and limited time.
The CERFPs we interviewed and Adjutants General and emergency managers
we surveyed also cited several other challenges to establishing and
maintaining relationships with potential response partners, such as
the frequent turnover of personnel and cultural differences between
civilian and military response organizations. For example, one
emergency manager from a state with a CERFP reported that personnel
turnover in both the National Guard and state agencies can hamper
coordination. Similarly, officials from one CERFP told us that
turnover in one of their CERFP's full-time positions had disrupted the
continuity of coordination efforts. As an example of cultural
differences, officials from two CERFPs told us that the military does
not know how to communicate effectively with civilian responders.
Similarly, an emergency manager we surveyed from a state with a CERFP
reported that differences in civilian and military methods of
communication and terminology are an impediment to successful
coordination.
As previously mentioned, the NGB officials we spoke with said that
CERFPs face challenges because of the current allotment of full-time
CERFP staff and stated that they plan to provide each CERFP with five
additional full-time positions by the end of fiscal year 2013. If
implemented, NGB's plans to increase full-time staff for the CERFPs
could help to alleviate the existing resource constraints. However, it
is unclear to what extent such an increase will improve coordination
without accompanying changes to guidance and because a requirements
evaluation had not been performed to determine the appropriate size of
the increase, according to NGB officials.
NGB's Tool for Evaluating the CERFPs' Coordination Efforts Is Limited
by Current Guidance:
NGB is taking steps to evaluate the effectiveness of some CERFP-led
coordination efforts as part of its overall assessment of the CERFPs'
compliance with program guidance. However, NGB's evaluation tool has
not been fully implemented. Moreover, because existing CERFP
coordination guidance--which forms the basis of the coordination
segment of NGB's evaluation tool--does not provide standards against
which CERFP coordination efforts can be measured, NGB's evaluation
tool will likely supply program officials with limited data regarding
the extent and success of coordination activities.
We have previously reported that federal agencies can enhance and
sustain their collaborative efforts in part by developing mechanisms
to monitor their results.[Footnote 32] We further reported that
reporting on these activities can provide program officials with the
data necessary to improve coordination policy and practice. [Footnote
33] NGB guidance recognizes that the standardization and continual
improvement of activities are key to ensuring consistency and
interoperability among CERFPs. Accordingly, NGB is implementing a
standardization and evaluation program to assess the CERFPs'
performance of a wide array of required activities--including those
pertaining to pre-incident coordination--and to provide NGB management
with detailed information for use in program management decisions.
[Footnote 34] For example, the program assesses whether CERFPs have
coordinated with local, state, and federal military response
organizations to ensure they understand the CERFP mission and
capabilities, and whether CERFPs are involved in local, state, and
federal regional response planning meetings. However, this program is
still in the beta test phase, with full implementation not scheduled
until July 2012. Moreover, because coordination guidance is imprecise
with regard to the frequency and targeting of coordination activities,
as previously mentioned, the evaluation tool is without established
standards against which CERFP performance can be measured. For
example, NGB officials told us that there are no published criteria
for evaluators to measure the CERFPs' performance of pre-incident
coordination activities and that evaluation is at this time
subjective. We were similarly told by an evaluation program
representative that there is currently "no degree of compliance" in
evaluations in the sense that no distinction is made between minimal
and extensive coordination efforts. NGB officials expect this to
change as the CERFPs and the evaluation program mature. These same
officials also noted, however, that as part of the evaluation,
evaluators will need to assess the CERFP's interaction with major
response organizations within the CERFP's area of responsibility,
[Footnote 35] including metropolitan area organizations, state
agencies tasked with major disaster response, federal installations,
and other DOD response elements. Yet because such information is not
formalized by guidance, the CERFPs' approach to pre-incident
coordination will likely vary, and NGB is without specific criteria
that could provide a uniform approach to evaluating CERFP coordination
efforts--thus reducing NGB's assurance that its evaluation results can
provide program officials with data sufficient to shape coordination
policy and practice.
Additional State-to-State Compacts Could Enhance Regional CBRNE
Coordination through Planning:
CERFPs were designed to be regional assets, but we found that states
that host CERFPs generally do not have agreements specific to their
interstate deployment and that CERFPs are generally not included in
state and local response plans. The EMAC establishes a structure for
member states to request and deploy assistance, reimburse states that
provide assistance, and confer liability and workers' compensation
protections.[Footnote 36] As the most widely adopted state-to-state
mutual aid agreement, EMAC constitutes an important mechanism for
interstate resource sharing, and states have increasingly relied on
EMAC during disasters as a means of accessing resources, such as
National Guard assets, from other states.
National Guard guidance recognizes the value of EMAC, but notes that
EMAC is generally for the use of the National Guard personnel in a
State Active Duty Status, not a Title 32 status.[Footnote 37] The
guidance also notes that states may develop other state-to-state
compacts to facilitate National Guard CERFP deployments between states
for response outside of EMAC agreements. Additionally, the CERFP
concept of operations encourages states to develop state-to-state
compacts and memorandums of agreement, outside of the EMAC, to enhance
preparedness, and facilitate a more effective response. NGB stated
that other agreements may be useful in enabling CERFPs to respond to
non-emergency events in other states and in allowing CERFPs to deploy
in advance of preplanned events, such as the Super Bowl or another
major event that CERFPs have supported in the past. The National
Response Framework identifies planning as a cornerstone of
preparedness, providing a common blueprint for activity in the event
of an emergency. For incidents that may occur without notice--such as
those involving CBRNE materials--advanced planning can be of increased
importance. As it relates to interstate response operations involving
CERFPs, planning can establish response coordination and operating
procedures and help ensure that CERFP capabilities are understood and
integrated appropriately--thus improving the timeliness of CERFP
deployments and the efficacy of interstate response operations.
Our surveys of state Adjutants General and state-level emergency
managers indicate that few interstate agreements exist between states
with and without CERFPs and that CERFP roles and responsibilities are
generally not integrated with state and local response plans. For
example, only 1 of 17 Adjutants General and 2 of 13 emergency manager
survey respondents from states with CERFPs stated that their National
Guard or states were party to an agreement outside of EMAC that would
facilitate the interstate deployment of their states' CERFPs.
Similarly, only 1 of 10 Adjutants General and 1 of 7 emergency manager
survey respondents from states without CERFPs reported that their
National Guard or states were party to an agreement outside of EMAC
that would facilitate their states' use of another state's CERFP.
Those that indicated they were party to such an agreement generally
reported that, although the agreement was not specific to CERFPs, it
could facilitate their interstate deployment. Several other Adjutants
General we surveyed and state National Guard representatives we
contacted stated that they believed EMAC to be sufficient to
facilitate interstate deployments and were unsure why other agreements
might be needed, indicating that opportunities exist for NGB to inform
relevant stakeholders as to how these agreements could facilitate more
effective responses.
Consistent with CERFP guidance, several of the after-action reports we
reviewed from National Guard exercises highlighted the potential
utility of such agreements. For example, reports from the Vigilant
Guard exercises identified interstate agreements as a vehicle to
specify how states receiving support from out-of-state CERFPs would
use those CERFPs. [Footnote 38] Another Vigilant Guard report
recommended that, because resources obtained through EMAC may arrive
slowly in a terrorist-related scenario in which multiple states are
threatened, states should explore establishing additional agreements
whereby regional resources might be more effectively pooled or shared
across regional boundaries. As previously stated, NGB guidance
recognizes the benefits of agreements outside of EMAC, and NGB is well-
positioned to facilitate National Guard support among states, but NGB
officials told us that they have not taken a role in the development
of such agreements between states.
Regarding planning, the Adjutants General and state-level emergency
managers we surveyed generally reported that broader National Guard
roles, responsibilities, or capabilities are included in their states'
emergency response plans. The overwhelming majority of CERFPs we spoke
with also said that they participate in joint response planning
meetings with federal, state, and local response organizations at
least to some extent. However, only 3 of 13 emergency managers from
states with CERFPs reported in our survey that CERFP roles,
responsibilities, or capabilities were specifically outlined in their
state's CBRNE response plan, emergency response plan, or incident
annexes. Moreover, the overwhelming majority of Adjutants General and
emergency managers we surveyed from CERFP states, and officials from
14 of the 17 CERFPs we interviewed, were unaware of their CERFP's
inclusion in local emergency response plans within their state.
NGB officials told us that the integration of civilian and military
plans is a major challenge and that they are in the process of
developing initiatives to foster this type of collaboration. For
example, officials stated that they expect to leverage the planned
HRFs as regional planning mechanisms to coordinate with FEMA regional
offices and state emergency management agencies to ensure that their
plans reflect military capabilities. According to the draft HRF
concept of operations, between three and eight planners will be
provided to each HRF to develop and synchronize CBRNE plans within
each FEMA region--although their specific activities and
responsibilities have not yet been formalized. Another option cited by
NGB officials is to place National Guard personnel in each FEMA
regional office to allow for ongoing integrated planning. These
efforts, if implemented, could enhance coordination and preparedness,
but it remains unclear how they would affect interstate CERFP
deployments. Specific deployment agreements between states that host
CERFPs and those that may receive CERFPs could improve regional CERFP
support and response planning--specifying, for example, command and
control relationships for interstate operations--and thereby
substantially enhance regional preparedness for CBRNE events.
A Command and Control Framework Is in Place, but Several Factors May
Inhibit CERFPs' Operational Effectiveness:
NGB has a general framework in place for the operational command and
control of CERFPs, outlining how teams will integrate with civilian
and military command structures and operate in support of civil
authorities when under state control or when federalized.[Footnote 39]
However, our review showed that command and control of consequence
management operations involving the CERFPs may be limited because (1)
CERFPs' capabilities for communicating with other response
organizations are inadequate; (2) there are no agreements between
CERFPs and their out-of-state Fatality, Search, and Recovery Teams;
and (3) opportunities to practice and evaluate potential command and
control arrangements in a realistic response environment are
infrequent. Moreover, NGB is establishing 10 HRFs, which--as currently
planned--will affect the existing command and control framework for
the CERFPs by altering their communications and relationships with
other response organizations.
NGB Has Established a Command and Control Framework for CERFP
Operations:
National Guard guidance and the CERFP concept of operations establish
a general framework for the operational command and control of CERFPs,
outlining how teams are to integrate with civilian and military
command structures and operate in support of civil authorities when
under state control and when federalized.[Footnote 40] For example,
according to the CERFP concept of operations, the CERFP is assigned to
the state and operationally committed to support a civilian incident
commander through the military chain of command. NGB's framework is
predicated on national guidance for domestic incident response
delineated by the National Response Framework and National Incident
Management System, as well as military civil support and CBRNE
consequence management doctrine.[Footnote 41] In accordance with
national response protocols, CERFP and other National Guard or federal
military response operations are conducted in support of civil
authorities in a three-tiered approach.[Footnote 42] During
operations, the chain of command that CERFPs operate under corresponds
to the CERFP's duty status and is generally determined by the size and
scope of an incident. CERFPs may operate in state active duty status,
Title 32 status, or Title 10 federal duty status. The state Governor
and Adjutant General provide command and control for state National
Guard forces, such as the CERFP, operating in state active duty status
or operating under the authorities of Title 32 of the U.S. Code. The
President provides command and control of National Guard forces
operating under Title 10 of the U.S. Code. While operating in Title 10
status during large-scale incidents, CERFPs will operate under the
command and control of the designated joint military response
headquarters. In most cases, DOD's federal response within the U.S.
would be under U.S. Northern Command.
According to the National Guard Bureau, CERFPs would normally operate
as an element of a state-level response under a state National Guard
command and control structure in either state active duty or Title 32
status. Each state National Guard has established a standing Joint
Force Headquarters under the Adjutant General--referred to as Joint
Force Headquarters-State. The Joint Force Headquarters-State controls
National Guard forces within the state's borders, either directly or--
in large scale incident responses--through a Joint Task Force-State.
When established, the Joint Task Force-State provides day-to-day
command, control, coordination, and logistical support to deployed
National Guard forces within the state's borders. At the CERFP level,
operations are commanded and controlled by the CERFP Command and
Control element. Among other things, the CERFP Command and Control
element employs the appropriate CERFP capabilities to accomplish the
incident mitigation objectives of the Incident Commander, and
maintains communications with the Incident Commander and Joint Force
Headquarters-State to ensure the synchronization of CERFP actions.
Figure 6 shows the basic command and control structure for State
Active Duty and Title 32 CERFP response operations.
Figure 6: Command and Control Structure for State Active Duty and
Title 32 CERFP Response Operations:
[Refer to PDF for image: structure illustration]
Top level: Governor.
Second level, command relationship with Governor:
State Emergency Management Agency;
State Adjutant General;
Coordination relationship between the 2 entities.
Third level, command relationship with State Adjutant General:
State Joint Force Headquarters.
Fourth level, support relationship with State Joint Force Headquarters:
Joint Task Force - State (if activated[A]); also has a command
relationship with State Adjutant General.
Fifth level, command relationship with Joint Task Force - State:
CERFP Command and Control Element;
Support relationship with:
Civilian Incident Commander.
Sixth level, command relationship with CERFP Command and Control
Element:
Search and Extraction Element;
Medical Element;
Decontamination Element;
Fatality, Search and Recovery Team.
Source: GAO analysis of NGB information.
[A] A Joint Task Force-State may be established under the Joint Force
Headquarters-State to provide day-to-day command, control,
coordination, and logistical support of deployed National Guard
response forces.
[End of figure]
In addition to operations within their states, CERFPs may deploy
outside their states based on requests for assistance and in
accordance with established mutual aid agreements. In such cases,
command and control is conducted according to provisions of the
agreement and applicable military plans and orders. States are
encouraged to develop state-to-state compacts to facilitate regional
CERFP support and response. In the case of an emergency and in the
absence of formal or informal agreements, National Guard guidance
states that the Governor and Adjutant General of a state providing
support may agree with the Governor and Adjutant General of a
supported state or develop a simple memorandum of agreement on CERFP
support on a case-by-case basis. The governor of an affected state may
also request assistance through the NGB for the deployment of a CERFP.
NGB serves a coordinating function to facilitate such requests but
does not have command authority over National Guard forces.
Inadequate Communications Capabilities May Hamper the Command and
Control of Operations Involving CERFPs:
Communications are central to the execution of command and control
functions, allowing commanders to exercise authority and direction and
enabling the information sharing necessary to maintain situational
awareness, but the CERFPs are not assured access to communications
equipment that would enable them to share and manage information with
military and civilian response organizations during a CBNRE incident.
The National Response Framework and DOD respectively identify
communications interoperability as a critical component of
preparedness and a key factor in the effective use of the National
Guard under state control, enabling coordination, cooperation, and
information sharing among federal, state, and local responders.
Moreover, draft NGB guidance addresses possible sources for a
dedicated, deployable long-range communications capability for CERFPs
and states that dedicated communications equipment is essential to
establishing "technical reach-back" capability for the CERFP.[Footnote
43] However, we found that the hand-held radios provided to the CERFPs
as part of their baseline authorization are not interoperable and have
limited range and that the communications platforms provided by state
National Guards to CERFPs are not dedicated to them, reducing
assurance that they would be available during an incident. For
example, officials from 11 of the 17 CERFPs we interviewed cited the
lack of interoperability of CERFP radios with communications equipment
used by other response organizations, such as first responders, as a
challenge. Further, officials from three of the CERFPs we interviewed
noted that the range of these handheld radios is limited, to the
extent that one CERFP representative commented that it will allow you
to communicate with other individuals if they are at the end of the
block--if a building does not get in the way. Such communication
limitations could severely impede information sharing and situational
awareness between the CERFP command and control element and the other
CERFP elements, and between the CERFP and the civilian Incident
Commander it supports--particularly when the CERFP Command and Control
element is not located close to the other CERFP elements or the
Incident Commander. Moreover, as shown in figure 7, CERFPs may
interact with various other potential response partners, requiring
communication pathways for maintaining situational awareness.
Figure 7: Potential CERFP Incident Site Response Partners and
Communications Pathways:
[Refer to PDF for image: illustration]
Communications Pathways: to and from CERFP Command and Control element:
Joint Operations Center;
Local hospital;
State National Guard Joint Force Headquarters/Joint Task Force
Commander;
Incident Commander and staff;
CERFP Incident Commander Liaison Officer;
CERFP Medical element;
CERFP Decontamination element;
CERFP Search and Extraction element;
CERFP Fatality Search and Recovery Team;
Other CERFPs civil support teams, and on-site DOD assets
Other communication pathways:
Local hospital and CERFP Medical element;
Incident Commander and staff and CERFP Incident Commander Liaison
Officer;
Incident Commander and staff and local, state, and federal responders;
CERFP Search and Extraction element and other on-site extraction teams;
CERFP Fatality Search and Recovery Team and other on-site recovery
teams.
Source: GAO analysis of NGB information.
[End of figure]
To mitigate communications limitations, CERFPs may be able to access
equipment with the aforementioned key capabilities from other state
National Guard organizations. According to National Guard guidance and
the CERFP concept of operations, CERFPs may access this equipment
through either their state's National Guard headquarters or state CST,
if the latter is tasked to support the CERFP. However, while officials
from nine CERFPs that told us their state could provide such
equipment, officials from seven of these nine also stated that there
are no specific agreements for accessing state-owned communications
equipment--such as the Joint Incident Site Communications
Capability.[Footnote 44] As a result, CERFP access could be limited by
competing requests from other entities during a large-scale incident.
Similarly, CERFPs' access to the CST's Unified Command Suite is also
dependent on the availability of these systems and whether a CERFP
operates within close proximity to the CST at an incident site.
[Footnote 45]
NGB officials said that they believe that state National Guards would
provide CERFPs with the communications equipment necessary to
accomplish the mission. Nevertheless, these officials also stated that
NGB recognizes that the CERFPs face a communications equipment gap
related to interoperability and reach-back access, among other things.
NGB has initiated a study to determine interoperability and reach-back
requirements for CERFP communications equipment and has begun to
explore potential equipment options--one of which would entail the
reassignment of state National Guard Joint Incident Site
Communications Capability systems to each CERFP command and control
element. These same officials also noted, however, that there are
challenges related to states having insufficient numbers of personnel
to operate and maintain this equipment. During a working group session
focused on communications shortfalls, several CERFP representatives
echoed these concerns, stating that the CERFPs do not have the
manpower to maintain such equipment or the training time necessary to
sustain operational proficiency. Because the absence of interoperable
communications equipment with long-range and reach-back capabilities
may impede the timely, continuous flow of critical information about
site hazards and response requirements between CERFPs and other
response entities--particularly the Joint Force Headquarters and
Incident Commander--the collective ability of all responders to
maintain situational awareness and coordinate movements may be
diminished.
Some CERFPs Do Not Have Agreements with Their Out-of-State Elements:
According to the CERFP concept of operations, CERFPs are comprised of
individual units from the host state if the state has the required
structure. When a state lacks the force structure necessary to support
all of the CERFP mission capabilities, units from another state may
provide the capability. If elements of a CERFP are from more than one
state, NGB guidance states that memorandums of agreement, laying out a
clear chain of command and activation authority, must be established.
The number of states that rely on units from other states to compose
their CERFPs may ebb and flow over time as a result of force
allocation challenges--such as the overseas deployment of CERFP
personnel--that may affect a state's ability to support the entire
CERFP mission. For example, we found that there were nine CERFPs whose
Fatality, Search, and Recovery Teams were sourced outside of the CERFP
host state.[Footnote 46] Officials from these CERFPs told us that they
had not established the required formal agreements with their out-of-
state Fatality, Search, and Recovery Team components, although
officials from two of the nine CERFPs told us that they had agreements
that were in draft form, one of which was awaiting approval from NGB.
According to NGB officials, NGB has not had a role in facilitating the
development of these agreements, nor has it attached consequences to
noncompliance with requirements to establish the agreements. In the
absence of such agreements, NGB has no assurance that CERFPs with out-
of-state elements, such as Fatality, Search, and Recovery Teams, will
deploy and operate as unified forces.
Opportunities to Exercise and Evaluate Command and Control in a
Realistic Response Environment Are Limited:
Because CERFPs must support the goals and objectives of a civilian
incident commander while adhering to the military chain of command,
practicing command and control relationships is critical to ensuring
operational effectiveness. Some of the training and exercise issues we
previously noted, such as the gaps in exercise participation by
critical CERFP elements and potential interagency and DOD response
partners, produce command and control challenges and directly affect
the level of assurance that all response partners have about the
viability of command and control relationships. For example, the
limited opportunities that CERFPs have had to train with their
Fatality, Search, and Recovery Team elements, and in some cases, their
medical elements, limits the ability of the CERFP to practice critical
command and control mechanisms in advance of an actual event.
As we have previously stated, despite guidance emphasizing the
importance of training with interagency partners, CERFPs have trained
to a limited extent in interagency environments, creating few
opportunities for CERFPs to exercise and evaluate certain command and
control structures--such as those that would be in place during a
large-scale incident under federal control. For example, according to
the results of our four surveys, in each of the last 3 years, three or
fewer CERFPs had trained with DOD's federal CBRNE Consequence
Management Response Forces or Marine Corps Chemical, Biological,
Incident Response Force, and only around half trained with U.S.
Northern Command. Limited interagency participation in CERFP training
events increases the risk that command and control mechanisms between
CERFPs and other military and nonmilitary partners will not function
effectively during an actual incident. For additional information
regarding interagency participation in CERFP training events, see
appendix II. As previously mentioned in our discussion of training
challenges, NGB neither comprehensively tracks the CERFPs'
participation in interagency exercises nor provides specific
participation goals that could be used to measure progress. As a
result, NGB has little assurance that all CERFPs, which are considered
regional and national assets, have opportunities to practice command
and control in an interagency environment.
Moreover, formal evaluations of CERFP command and control do not
provide realistic testing of command and control relationships because
they occur in controlled environments that typically do not include
interagency response partners. According to the 2008 Joint Training
Plan, external evaluations should preferably be conducted during
regional exercises focused on performing tasks in an interagency
environment under the command and control of the state National Guard
Joint Force Headquarters or Joint Task Force-State. However, in two of
the three formal evaluations that we attended, interagency
organizations observed these exercises but played no active role. At
the third evaluation, one organization participated to a limited
extent by conducting an initial assessment of the incident scene at
the onset of the evaluation. We also found that during these events,
key players--such as the civilian Incident Commander and National
Guard Joint Force Headquarters--are often simulated by evaluators.
According to several exercise officials, NGB prefers to simulate these
roles since the evaluators are familiar with CERFP operations and
therefore can more efficiently provide orders and control the pace of
the exercise. Officials we spoke with from two CERFPs provided a
contrasting view, noting that such conditions contribute to a
fabricated environment that ultimately fails to stress the command and
control system. One of the after-action reports we reviewed for an
exercise that included interagency partners similarly noted that it
was vital to have interagency participation, not just simulation, to
achieve the goals of the exercise.
As indicated previously in our discussion of training challenges, NGB
officials have recognized the need to improve aspects of CERFP field
training and exercises by, for example, including in its annual
training guidance, issued in March 2011, collective training goals
related to exercising with local, state, and federal responders.
However, as noted, it is unclear whether units will be able to meet
collective training goals and participate in proposed exercises, as
challenges related to the CERFPs' part-time status and funding have
limited the CERFPs' participation in training in the past. Without a
strategy to ensure that such opportunities to practice and evaluate
command and control are provided across the program, the CERFPs are at
risk of decreased effectiveness when they operate in diverse response
environments that include the full range of local, state, and federal
response organizations.
The Introduction of New Homeland Response Forces Will Affect Command
and Control of CBRNE Capabilities:
The advent of HRFs will materially affect the command and control
framework for CERFPs by altering how CERFPs interact with other
response partners. The first two HRFs and the replacement CERFPs are
scheduled to become operational by the end of fiscal year 2011. When
deployed in response to an incident, NGB officials told us that the
HRFs are supposed to establish a regional command and control
structure to synchronize State Active Duty and Title 32 National Guard
CBRNE response forces--including CERFPs--and prepare for follow-on
forces. In this capacity, HRFs may command and control multiple CERFPs
during large-scale consequence management operations and thereby
affect both the nature and extent of the CERFPs' interactions with
military and civilian command structures. For example, when operating
under the HRFs, CERFPs may coordinate directly with the HRF instead of
the state National Guard Joint Force Headquarters. Similarly, while
NGB officials told us that the HRF will not act as a communication
layer between the CERFP and Incident Commander during such incidents,
NGB has not issued guidance delineating command and control
relationships for joint HRF-CERFP operations, making it unclear
whether the CERFPs will continue to coordinate directly with the
civilian Incident Commander, or if that coordination will become the
duty of the HRF.
According to NGB officials, NGB has postponed its initial plans to
update existing CERFP guidance by late summer 2011 to reflect the new
command and control relationships associated with the HRF construct.
These officials told us that they now plan to concomitantly update and
develop existing CERFP and new HRF guidance to create an overarching
guidance manual. This approach will delay issuance by approximately 6
months. The delay, according to NGB, is acceptable given the expected
benefits of combining the guidance. However, because NGB does not plan
to update its CERFP command and control guidance before the first two
HRFs become operational at the end of fiscal year 2011, CERFPs will
likely face a range of operational ambiguities during joint HRF-CERFP
operations that could limit prospects for the seamless integration of
military and civilian response operations. For example, without new
guidance, CERFPs may not have a clear understanding of how they are to
interact with the state National Guard Joint Force Headquarters and
the civilian Incident Commander during joint HRF-CERFP operations,
resulting in confusion and inefficiencies that could lead to reduced
operational effectiveness.
Conclusions:
CERFPs are considered a critical component--within DOD's overall CBRNE
response strategy--to support local and state responders during a
significant or catastrophic CBRNE-related incident. The fact that
CERFPs are staffed by National Guard soldiers and airmen who do not
train and prepare for the mission on a full-time basis adds to the
challenge to be fully ready to rapidly respond anywhere within the
United States and its territories within hours and be capable of
integrating with other response partners--including other CERFPs and
DOD's other CBRNE response capabilities. Gaps that we identified in
NGB's CERFP management efforts--gaps that include (1) evaluating the
resources and capabilities necessary for the CERFP mission; (2)
providing guidance for CERFP participation in key training and
exercises; and (3) capturing and reporting CERFP readiness data--
represent further challenges to the long-term success of the program.
Now that the CERFP program has gained some maturity, a more
comprehensive approach to address these gaps can build on efforts DOD
and NGB already have under way to better ensure that CERFPs can
provide an effective emergency response.
A successful response to a large-scale domestic CBRNE incident
requires the synchronization of response efforts across local, state,
and federal-level response organizations, including DOD. This
integration, in turn, requires extensive pre-incident coordination. As
state and regional assets, CERFPs are uniquely positioned to
coordinate their efforts with civilian and military response
organizations at various levels of government. Likewise, the NGB--as
manager of the CERFP program and a key channel of communication
between DOD and the states--is well positioned to guide CERFP
coordination practice and to facilitate interstate planning for the
use of CERFPs across state lines. Addressing the challenges that have
led to sporadic coordination efforts between CERFPs and other
potential response partners--challenges such as gaps in the areas of
(1) existing guidance that specifies direction for CERFP coordination
efforts; (2) awareness and understanding of that guidance by the
CERFPs; (3) standards that would allow NGB and DOD to assess the
effectiveness of CERFP coordination with military and civilian
response partners; and (4) agreements between states regarding
interstate CERFP deployments--all represent opportunities for DOD,
NGB, and the individual CERFPs to improve their existing coordination
efforts and thereby further solidify the concept of a unified national
response that is at the heart of the nation's emergency planning.
To effectively respond to incidents of varying scale in support of
civil authorities, it is crucial that CERFPs be able to seamlessly
integrate with civilian and military command structures as well as
response organizations at the local, state, and federal levels. Gaps
in the areas of (1) communications and interoperability; (2)
agreements between CERFPs and other states that host a team's
Fatality, Search, and Recovery component; and (3) practicing and
evaluating key command and control relationships could each inhibit
the ability of CERFPs to operate effectively in interagency
environments. The advent of HRFs amplifies such challenges by
introducing a new set of relationships and procedures that will affect
the framework of integration for military and civilian response
operations. Without an updated command and control framework that
clearly delineates relationships related to the HRFs, CERFPs are
likely to experience confusion and inefficiencies during joint
operations that could lead to reduced operational effectiveness and
weaken the overall national response structure.
Recommendations for Executive Action:
To address these issues, we recommend that the Secretary of Defense
take the following three actions:
(1) To increase assurance that CERFPs can effectively conduct CBRNE
consequence management in support of civil authorities, we recommend
that the Secretary of Defense direct the Chief of the National Guard
Bureau, in coordination with the Secretaries of the Army and Air
Force, the state Adjutants General, and the Under Secretary of Defense
for Personnel and Readiness, as appropriate, to:
* implement a well-defined process to systematically examine and
validate total resources and capabilities necessary to successfully
conduct the CERFP mission including personnel, training, and equipment
requirements;
* develop a training strategy linked to specified goals to guide
CERFPs' participation in the range of field collective training
exercises and systematically track progress that CERFPs are making in
achieving the specified training goals; and:
* develop and implement a plan--with timelines--to complete the
implementation of the standardized mechanism for capturing and
reporting readiness data within DOD's centralized readiness reporting
system.
(2) To enhance regional CBRNE preparedness and facilitate the CERFPs'
ability to respond to regional events, we recommend that the Secretary
of Defense direct the Chief of the National Guard Bureau in concert
with the Secretaries of the Army and Air Force and the state Adjutants
General, where appropriate, to:
* strengthen existing guidance related to interagency coordination by
specifying, for example, the key types of response organizations with
which CERFPs should coordinate in their geographical areas of
responsibility;
* increase awareness and understanding of coordination guidance within
the CERFPs;
* establish agreed-upon coordination evaluation standards by
incorporating updated coordination guidance in the Standardization,
Evaluation, and Assistance Team checklist(s) or another coordination
evaluation tool; and:
* take steps to encourage states to develop state-to-state compacts
regarding CERFP interstate deployment and coordination to supplement
EMAC.
(3) To ensure the effective command and control of consequence
management operations involving CERFPs and to make certain that CERFPs
are able to integrate effectively with military and civilian response
partners, we recommend that the Secretary of Defense direct the Chief
of the National Guard Bureau, in concert with the Secretaries of the
Army and Air Force and the state Adjutants General, where appropriate,
to:
* formalize an interim solution--as NGB conducts it long-term review--
to ensure that CERFPs responding to an event will have access to
equipment providing key communications capabilities--including
interoperability with military and first responder equipment, long-
range connectivity, and technical reach-back;
* foster the development of memorandums of agreement between states
that host CERFPs and states that provide out-of-state elements such as
Fatality, Search, and Recovery teams;
* develop a strategy to ensure that all CERFPs are able to practice
and be evaluated on command and control relationships within realistic
environments that include the range of interagency partners that
CERFPs are likely to encounter; and:
* issue interim guidance to clarify the new command and control
relationships resulting from the changes to DOD's consequence
management strategy:
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD concurred with the
recommendations. DOD also provided technical comments, which we have
incorporated into the report where appropriate.
DOD provided additional comments with respect to the first and third
recommendations that addressed CERFP training and exercises. DOD
stated that US Northern Command and NGB are provided resources for
approximately eight full-scale exercise opportunities per year that
allow National Guard units (CERFPs or other units) to train with
military and interagency partners and that additional funding and
dedicated National Guard "man-days" would be required to exercise all
17 CERFPs and 10 HRFs each year or each time a new force assumes the
mission. Further, DOD stated that given the large amount of training
(for individuals, units, and with interagency partners) for the
complex mission, stabilization of the assigned CBRNE consequence
management forces for 3 years or more is needed. We agree that
expanding the scope of the exercise program for CERFPs (and other
CBRNE units) to encompass full-scale interagency exercises for each
unit every year would tax the existing structure and resources for
CBRNE consequence management exercises. We continue to believe that if
DOD implements our recommendations to develop strategies to (1) guide
CERFP participation in the range of field exercises and tracking
progress in participating in such exercises and (2) ensure that all
CERFPs are able to practice and be evaluated on command and control
relationships within realistic environments and with a range of
interagency partners, the CERFPs will benefit from improved standards
and goals to increase the effectiveness of their exercises. In some
cases, this may mean increased frequency of exercises. However, the
current fiscal environment is not likely to allow dramatic increases
in both the frequency and scope of major exercises. Successful
development and implementation of the strategies we recommend would
allow NGB to better utilize existing resources to more evenly
distribute training opportunities--and thereby better ensure a
consistent level of preparedness--across the CERFP program.
We also agree that providing some stability to the CERFPs in terms of
the units assigned for a period similar to the 3 years or more, as DOD
suggested in response to our third recommendation, would help improve
the effectiveness of existing and planned training and exercises, as
it will allow a unit as a whole to benefit from that experience for
longer than is now the case.
DOD's comments are reproduced in their entirety in appendix III.
We are distributing this report to the appropriate congressional
committees, the Secretary of Defense, and other interested parties. In
addition, the report will be available at no charge on GAO's Web site
at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-4300 or stlaurentj@gao.gov. Contact
information for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. Key contributors
to this report are listed in appendix IV.
Signed by:
Janet A. St. Laurent:
Managing Director Defense Capabilities and Management:
List of Requesters:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Adam Smith:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable W. "Mac" Thornberry:
Chairman:
The Honorable James R. Langevin:
Ranking Member:
Subcommittee on Emerging Threats and Capabilities:
Committee on Armed Services:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To address our objectives, we held discussions with the Office of the
Assistant Secretary of Defense, Reserve Affairs, and the Assistant
Secretary of Defense, Homeland Defense and Americas' Security Affairs,
the Joint Chiefs of Staff, and NGB operations, training, and readiness
officials and reviewed regulations, studies, briefings and memoranda
to gain perspectives on the status of the CERFP program. We compared
the current status of the program with the requirements set forth in
DOD and NGB guidance, such as NGB's CERFP Concept of Operations,
[Footnote 47] NGB's CERFP Management regulation,[Footnote 48] NGB's
CERFP training guidance,[Footnote 49] and the Army's final draft of
CERFP operations doctrine.[Footnote 50] We reviewed NGB's future plans
related to the implementation of its Standardization Evaluation and
Assistance Team Program to determine NGB's planned framework for
providing oversight of the CERFP program, and reviewed future plans
that affect the CERFPs' role in DOD's restructured plan for providing
CBRNE response capabilities, including those related to the Homeland
Response Forces. We also conducted five site visits to observe a total
of six CERFPs conducting training during various types of field
exercises, including three field exercise where CERFPs were preparing
for, and being evaluated on, their mission proficiency. We attended
the other two field training exercises to observe CERFPs training with
some of their potential response partners, such as local fire chiefs
and fire departments, sheriff departments, state level rescue
organizations, FEMA search and rescue teams, other National Guard
response capabilities, and the Marine Corps' Chemical Biological
Incident Response Force. We held discussions with exercise
participants and exercise evaluators that were part of, or working in
support of, the NGB's Joint Interagency Training and Education Center,
which provides training support to CERFPs. These exercises were
conducted in Colorado, Florida, Ohio, Virginia and Wisconsin.
To gain the perspectives of both the state National Guard and state-
level emergency management officials who would be involved in planning
or executing a CBRNE emergency response, we designed and implemented
separate web-based surveys of (1) state Adjutants General from all 17
states that host CERFPs (2) state Adjutants General from 10 states
that do not host CERFPs, (3) state-level emergency managers from all
17 states that host CERFPs, and (4) state-level emergency managers
from 10 states that do not host CERFPs. For states that do not host
CERFPs, one state or territory was non-randomly selected from each of
the ten FEMA regions to reflect different geographical and population
characteristics. The ten additional states that were selected were
Alabama, Alaska, Arizona, Connecticut, Kansas, Maryland, Michigan,
Montana, New Mexico, and Puerto Rico.[Footnote 51] In total, 51
surveys were sent via email invitation across 27 states (17 CERFP host
states and 10 non-host states) and were conducted between September
and October 2010. Contact information for each state Adjutant General
was provided by the National Guard Bureau and verified against contact
information available on state National Guard Web sites. Contact
information for each state emergency management official was provided
by the National Emergency Management Association and verified against
state emergency management Web sites. We took steps to minimize
nonsampling errors by pretesting the survey instruments in July and
August 2010 with officials from eight of the states eventually
surveyed. The surveys addressed CERFP planning, coordination, command
and control, and collective training, and the new DOD CBRNE
consequence management strategy articulated by the 2010 Quadrennial
Defense Review. Additionally, the survey given to state Adjutants
General in states that host CERFPs also addressed CERFP preparedness.
To maximize our response rate, we sent reminder emails and contacted
non-respondents by telephone. In total, we obtained responses from 47
of the 51 survey recipients (92 percent). We received responses from
all 17 Adjutants General from states that host CERFPs and from all 10
Adjutants Generals from the states we selected that do not host
CERFPs. We received responses from 13 of the 15 state-level emergency
managers from states that host CERFPs and from 7 of the 9 emergency
managers from the states we selected that do not host CERFPs.[Footnote
52] Despite repeated inquiries, emergency management officials from
Maryland, New Mexico, Texas, and Washington did not respond to the
surveys.
We supplemented our survey results with semi-structured telephone
interviews of key representatives from each of the 17 CERFPs. These
interviews consisted of both standardized and variable questions to
capture tactical-level perspectives on a range of issues related to
CERFP readiness; coordination; collective planning and training; and
DOD's new CBRNE consequence management strategy. We performed content
analysis of the interview responses to identify recurring themes and
perspectives.
To identify the extent to which the CERFPs are prepared to execute
their mission in terms of required equipment, staffing, training, and
funding, we reviewed readiness data within the National Guard's CERFP-
specific spreadsheet-based readiness system dated from October 2006
through January 2011and data from the Defense Readiness Reporting
System (DRRS) dated January 2011 to determine the mechanisms for and
the processes involved in CERFP readiness reporting. We also reviewed
our prior work on National Guard readiness and DRRS to supplement our
work.[Footnote 53] We reviewed CERFP-specific readiness briefings and
CERFP specific-readiness spreadsheets to determine the extent that
readiness data is being reported to NGB. Additionally, we used the
Army Readiness Management System to review Army unit reported
readiness data. The Army reports its readiness data through DRRS-Army,
which is one of the interconnected systems within DRRS. We reviewed
this data in order to determine whether units that were identified by
the National Guard as having the CERFP mission could be seen as
reporting their readiness for that mission as part of their unit
readiness reports. We used the Army's system because typically at
least two of the four CERFP elements come from Army National Guard
units. To the extent that CERFP readiness data was found in the Army
unit reported readiness data, we compared this data to the type of
data found in NGB's readiness spreadsheets. We also interviewed
readiness and program officials to determine their plans for
integrating CERFP data from the stand-alone spreadsheets into DRRS. We
assessed the reliability of the DRRS data and determined that the data
is sufficiently reliable for the purpose of assessing the consistency
of the implementation of the current readiness reporting policies and
discussing the findings in this report.
To determine the extent to which (1) existing coordination mechanisms
facilitate future CERFP operations, and the effectiveness of CERFP-led
coordination activities is evaluated, and (2) NGB has established an
effective framework to command and control the CERFPs during
consequence management operations, we reviewed and analyzed an array
of relevant program and issue area documentation, law, and literature;
interviewed military stakeholders; conducted site visits to observe
CERFP field training; attended CERFP working group sessions; and
collected and analyzed information from our four surveys. We examined
CERFP-related documents, including DOD and NGB guidance; briefings;
training materials and after action reports; and memorandums regarding
the status of the CERFP program. We also reviewed law relevant to
disaster response and the domestic employment of National Guard
troops, including the Stafford Act and certain provisions of Titles 32
and 10 of the United States Code. We examined an array of
documentation related to DOD's other CBRNE consequence management
assets, including DOD reports, testimonies, and initial plans related
to DOD's CBRNE enterprise restructuring efforts. We also examined
national-level policy pertaining to response coordination and
planning, such as the National Response Framework and National
Incident Management System, and reviewed relevant literature related
to response operations, the Emergency Management Assistance Compact,
and state-to-state mutual aid.
We conducted this performance audit from December 2009 to December
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: CERFP Interagency Training, 2008-2010:
NGB's training guidance covering 2008-2010 encouraged CERFPs to
include potential response partners in collective team training
exercises and to participate in at least one regional training event
in fiscal year 2008 or fiscal year 2009 that focused on performing
collective tasks in an interagency environment including local, state,
federal, or other DOD response partners.[Footnote 54] Figures 8, 9,
10, and 11 illustrate the results of our surveys of state Adjutants
General and state-level emergency managers regarding the extent to
which CERFPs have trained with various potential response partners in
2008, 2009, and 2010.
Our surveys show that most CERFPs have trained with some key response
partners over the last 3 years, but have had limited opportunities to
train with other key response partners, such as DOD response
organizations and state emergency management agencies. For example, in
each of the last 3 years, three or fewer CERFPs had trained with DOD's
federal CBRNE Consequence Management Response Forces or Marine Corps
Chemical Biological Incident Response Force, and only around half
trained with U.S. Northern Command--DOD's federal response lead for
most domestic CBRNE incidents. Additionally, the state-level emergency
managers we surveyed reported high levels of training with CSTs, but
only about half or less from those states with CERFPs had trained with
a CERFP in each of the last 3 years and only one from a state without
a CERFP had trained with a CERFP in 2009 and 2010.
Figure 8: CERFP Joint Field Training with Select Potential Response
Partners, 2008-2010:
[Refer to PDF for image: vertical bar graph]
Survey response:
Exercise: Other CERFPs;
2008, Yes: 6;
2008, No: 11;
2009, Yes: 10;
2009, No: 7;
2010, Yes: 12;
2010, No: 5.
Exercise: Civil Support Teams;
2008, Yes: 15;
2008, No: 2;
2009, Yes: 12;
2009, No: 5;
2010, Yes: 14;
2010, No: 3.
Exercise: CBRNE Consequence Management Response Force;
2008, Yes: 1;
2008, No: 16;
2009, Yes: 2;
2009, No: 15;
2010, Yes: 3;
2010, No: 14.
Exercise: Chemical Biological Incident Response Force;
2008, Yes: 1;
2008, No: 16;
2009, Yes: 2;
2009, No: 15;
2010, Yes: 3;
2010, No: 14.
Exercise: U.S. Northern Command;
2008, Yes: 9;
2008, No: 8;
2009, Yes: 9;
2009, No: 8;
2010, Yes: 8;
2010, No: 9.
Exercise: Federal Emergency Management Agency;
2008, Yes: 10;
2008, No: 7;
2009, Yes: 10;
2009, No: 7;
2010, Yes: 7;
2010, No: 10.
Exercise: Other federal partners;
2008, Yes: 10;
2008, No: 7;
2009, Yes: 9;
2009, No: 8;
2010, Yes: 12;
2010, No: 5.
Exercise: Local agencies;
2008, Yes: 14;
2008, No: 3;
2009, Yes: 14;
2009, No: 3;
2010, Yes: 15;
2010, No: 2.
Source: GAO Survey of CERFP State Adjutants General on State CBRNE
Response Capabilities.
[End of figure]
Figure 9: CERFP Joint Field Training with Emergency Management
Agencies from States with CERFPs, 2008-2010:
[Refer to PDF for image: 3 pie-charts]
2008:
Not checked: 23%;
No: 38%;
Yes: 38%.
2009:
Not checked: 15%;
No: 31%;
Yes: 54%.
2010:
Not checked: 15%;
No: 46%;
Yes: 38%.
Source: GAO of CERFP State Emergency Managers on State CBRNE Response
Capabilities.
Note: Numbers may not add to 100 percent due to rounding.
[End of figure]
Figure 10: CERFP Joint Field Training with Emergency Management
Agencies from States without CERFPs, 2008-2010:
[Refer to PDF for image]
2008:
Not checked: 29%;
No: 71%;
Yes: 0.
2009:
Not checked: 14%;
No: 71%;
Yes: 14%.
2010:
Not checked: 14%;
No: 71%;
Yes: 14%.
Source: GAO Survey of CERFP State Emergency Managers on State CBRNE
Response Capabilities.
Note: Numbers may not add to 100 percent due to rounding.
[End of figure]
Figure 11: CERFP Joint Field Training with State National Guards from
States without CERFPs, 2008-2010:
[Refer to PDF for image: 3 pie-charts]
2008:
No: 70%;
Yes: 30%.
2009:
No: 60%;
Yes: 40%.
2010:
No: 40%;
Yes: 60%.
Source: GAO of CERFP State Adjutants General on State CBRNE Response
Capabilities.
[End of figure]
Appendix III: Comments from the Department of Defense:
Office of The Assistant Secretary Of Defense:
Reserve Affairs:
1500 Defense Pentagon:
Washington, DC 20301-1500:
November 15, 2011:
Memorandum For: Mr. Joseph Kirschbaum Assistant Director, Defense
Capabilities and Management, U.S. Government Accountability Office.
Subject: GAO draft report, GAO-12-1148, Homeland Defense and Weapons
of Mass Destruction.
Thank you for the opportunity to coordinate on the Department of
Defense {DOD) response to the GAO draft report, GAO-12-114, Homeland
Defense and Weapons of Mass Destruction: Additional Steps Could
Enhance the Effectiveness of the National Guard's Life-Saving Response
Forces, dated November 2011 (GAO Code 351401).
The DoD concurs with the recommendations. Detailed responses to each
recommendation are attached. Additionally, we reviewed the entire
report for accuracy and clarity of content. The attachment also
provides recommended editorial changes. The point of contact for this
matter is Col. John M. Fruge at 571-256-4579 or e-mail john.fruge@osd.
Signed by:
Paul Patrick, for:
David L. McGinnis:
Acting:
[End of letter]
GAO Draft Report Dated November 2011:
GAO-12-114 (GAO Code 351401):
"Homeland Defense and Weapons of Mass Destruction: Additional Steps
Could Enhance The Effectiveness of The National Guard's Life-Saving
Response Forces"
Department Of Defense Comments To The GAO Recommendations And Report:
DOD Comments To The Recommendations:
Recommendation 1: To increase assurance that CERFPs can effectively
conduct CBRNE consequence management in support of civil authorities,
we recommend that the Secretary of Defense direct the National Guard
Bureau, in coordination with the Secretaries of the military services,
the states' Adjutants General, and the Under Secretary of Defense for
Personnel and Readiness, as appropriate, to:
* Implement a well-defined process to systematically examine and
validate total resources and capabilities necessary to successfully
conduct the CERFP mission including personnel, training, and equipment
requirements;
* Develop a training strategy linked to specified goals to guide
CERFPs participation in the range of field collective training
exercises and systematically track progress that CERFPs are making in
achieving the specified training goals: and;
* Develop and implement a plan-with timelines-to complete the
implementation of the standardized mechanism for capturing and
reporting readiness data within DOD's centralized readiness reporting
system.
DoD Response: Concur with comment. NORTHCOM and NGB are resourced for
and provide approximately 8 full-scale exercise opportunities per year
which allow National Guard CBRN units to train with the full spectrum
of military and inter-agency partners. (4 VIGILANT GUARD REGIONAL
exercises, NORTHCOM's ARDENT SENTRY, VIGILANT SHIELD and VIBRANT
RESPONSE, and NGB's PATRIOT exercise).
Additional resources in the form of National Guard Man-days,
transportation and funding for exercise support (Trainers, facility
use, simulation and consumables) are required to exercise the 17
CERF-P's and 10 HRF's each year or each time a new force assumes the
mission.
With these additional resources, the 8 existing exercises can
accommodate additional CBRN units participation, training and
evaluation. In order to provide such an opportunity for every unit, at
the above frequency, additional exercises would have to be established.
Given the large amount of individual, collective, unit (C2 and
sustainment) and interagency training required for this complex
mission, stabilization of the assigned CBRN forces for a period 3
years or more is needed and most cost effective.
Recommendation 2: To enhance regional CBRNE preparedness and
facilitate the CERFPs' ability to respond to regional events, we
recommend that the Secretary of Defense direct the Chief of NGB, in
concert with the Secretaries of the Army and Air Force and the state
Adjutants General, where appropriate, to:
* Strengthen existing guidance related to interagency coordination by
specifying, for example, the key types of response organizations that
CERFPs should coordinate with in their geographical areas of
responsibility;
* Increase awareness and understanding of coordination guidance within
the CERFPs;
* Establish agreed-upon coordination evaluation standards by
incorporating updated coordination guidance in the Standardization,
Evaluation, and Assistance Team checklist(s) or another coordination
evaluation tool;
* Take steps to encourage states to develop state-to-state compacts
regarding CERFP interstate deployment and coordination to supplement
EMAC.
DoD Response: Concur.
Recommendation 3: To ensure the effective command and control of
consequence management operations involving CERFPs and to make certain
that CERFPs are able to integrate effectively with military and
civilian response partners, we recommend that the Secretary of Defense
direct the Chief of the National Guard Bureau, in concert with the
Secretaries of the Army and Air Force and the state Adjutants
General, where appropriate to:
* Formalize an interim solutions-as NGB conducts it long-term review-
to ensure that CERFPs responding to an event will have access to
equipment providing key communications capabilities-including
interoperability with military and first responder equipment, long-
range connectivity, and technical reach back;
* Foster the development of memoranda of agreement between states that
host CERFPs and states that provide out-of-state elements such as
Fatality, Search, and Recovery terms;
* Develop a strategy to ensure that all CERFPs are able to practice
and be evaluated on command control relationships within realistic
environments that include the range of interagency partners that
CERFPs are likely to encounter; and;
* Issue interim guidance to clarify the new command and control
relationships resulting from the changes to DOD's consequence
management strategy prior to the operationalization of the HRFs and
the new CERFPs.
DoD Response: Concur with comment. NORTHCOM and NGB are resourced for
and provide approximately 8 full ”scale exercise opportunities per
year which allow National Guard CBRN units to train with the full
spectrum of military and inter-agency partners. (4 VIGILANT GUARD
REGIONAL exercises, NORTHCOM's ARDENT SENTRY, VIGILANT SHIELD and
VIBRANT RESPONSE, and NGB's PATRIOT exercise).
Additional resources in the form of National Guard Man-days,
transportation and funding for exercise support (Trainers, facility
use, simulation and consumables) are required to exercise the 17 CERF-
P's and 10 HRF's each year or each time a new force assumes the
mission.
With these additional resources, the 8 existing exercises can
accommodate additional CBRN units participation, training and
evaluation. In order to provide such an opportunity for every unit, at
the above frequency, additional exercises would have to be established.
Given the large amount of individual, collective, unit (C2 and
sustainment) and interagency training required for this complex
mission, stabilization of the assigned CBRN forces for a period 3
years or more is needed and most cost effective.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Janet A. St. Laurent, (202) 512-4300 or stlaurentj@gao.gov.
Acknowledgments:
In addition to the contact named above, Davi M. D'Agostino, Joseph
Kirschbaum (Assistant Director), Rodell Anderson, Yecenia Camarillo,
Jennifer Cheung, Grace Coleman, Ryan D'Amore, Pamela Davidson, Joanne
Landesman, Katherine Lenane, Katie Mauldin, K. Nicole Harms, and Amie
Steele made key contributions to this report.
[End of section]
Related GAO Products:
Homeland Defense: DOD Needs to Take Actions to Enhance Interagency
Coordination for Its Homeland Defense and Civil Support Missions.
[hyperlink, http://www.gao.gov/products/GAO-10-364]. Washington, D.C.:
Mar 30, 2010:
Homeland Defense: DOD Can Enhance Efforts to Identify Capabilities to
Support Civil Authorities during Disasters. [hyperlink,
http://www.gao.gov/products/GAO-10-386]. Washington, D.C.: Mar 30,
2010.
Homeland Defense: Planning, Resourcing, and Training Issues Challenge
DOD's Response to Domestic Chemical, Biological, Radiological, Nuclear
and High-Yield Explosive Incidents. [hyperlink,
http://www.gao.gov/products/GAO-10-123]. Washington, D.C.: October 7,
2009.
National Preparedness: FEMA Has Made Progress, but Needs to Complete
and Integrate Planning, Exercise, and Assessment Efforts. [hyperlink,
http://www.gao.gov/products/GAO-09-369]. Washington, D.C.: April 30,
2009.
Emergency Management: Observations on DHS' Preparedness for
Catastrophic Disasters. [hyperlink,
http://www.gao.gov/products/GAO-08-868T]. Washington, D.C.: June 11,
2008.
National Response Framework: FEMA Needs Policies and Procedures to
Better Integrate Non-Federal Stakeholders in the Revision Process.
[hyperlink, http://www.gao.gov/products/GAO-08-768]. Washington, D.C.:
June 11, 2008.
Homeland Defense: Steps Have Been Taken to Improve U.S. Northern
Command's Coordination with States and the National Guards Bureau, but
Gaps Remain. [hyperlink, http://www.gao.gov/products/GAO-08-252].
Washington, D.C.: April 16, 2008.
Homeland Defense: U.S. Northern Command Has Made Progress but Needs to
Address force Allocation, Readiness Tracking Gaps, and Other Issues.
[hyperlink, http://www.gao.gov/products/GAO-08-251]. Washington, D.C.:
April 16, 2008.
Continuity of Operations: Selected Agencies Tested Various
Capabilities during 2006 Governmentwide Exercise. [hyperlink,
http://www.gao.gov/products/GAO-08-185]. Washington, D.C.: November
19, 2007.
Homeland Security: Preliminary Information on Federal Action to
Address Challenges Faced by State and Local Information Fusion
Centers. [hyperlink, http://www.gao.gov/products/GAO-07-1241T].
Washington, D.C.: September 27, 2007.
Homeland Security: Observations on DHS and FEMA Efforts to Prepare for
and Respond to Major and Catastrophic Disasters and Address Related
Recommendations and Legislation. [hyperlink,
http://www.gao.gov/products/GAO-07-1142T]. Washington, D.C.: July 31,
2007.
Influenza Pandemic: DOD Combatant Commands' Preparedness Efforts Could
Benefit from More Clearly Defined Roles, Resources, and Risk
Mitigation. [hyperlink, http://www.gao.gov/products/GAO-07-696].
Washington, D.C.: June 20, 2007.
Homeland Security: Preparing for and Responding to Disasters.
[hyperlink, http://www.gao.gov/products/GAO-07-395T]. Washington,
D.C.: March 9, 2007.
Catastrophic Disasters: Enhanced Leadership, Capabilities, and
Accountability Controls Will Improve the Effectiveness of the Nation's
Preparedness, Response, and Recovery System. [hyperlink,
http://www.gao.gov/products/GAO-06-618]. Washington, D.C.: September
6, 2006.
Homeland Defense: National Guard Bureau Needs to Clarify Civil Support
Teams' Mission and Address Management Challenges. [hyperlink,
http://www.gao.gov/products/GAO-06-498]. Washington, D.C.: May 31,
2006.
Hurricane Katrina: Better Plans and Exercises Needed to Guide the
Military's Response to Catastrophic Natural Disasters. [hyperlink,
http://www.gao.gov/products/GAO-06-643]. Washington, D.C.: May 15,
2006.
Hurricane Katrina: GAO's Preliminary Observations Regarding
Preparedness, Response, and Recovery. [hyperlink,
http://www.gao.gov/products/GAO-06-442T]. Washington, D.C.: March 8,
2006.
Emergency Preparedness and Response: Some Issues and Challenges
Associated with major Emergency Incidents. [hyperlink,
http://www.gao.gov/products/GAO-06-467T]. Washington, D.C.: February
23, 2006.
GAO'S Preliminary Observations Regarding Preparedness and Response to
Hurricanes Katrina and Rita. [hyperlink,
http://www.gao.gov/products/GAO-06-365R]. Washington, D.C.: February
1, 2006.
Homeland Security: DHS' Efforts to Enhance First Responders' All-
Hazards Capabilities Continue to Evolve. [hyperlink,
http://www.gao.gov/products/GAO-05-652]. Washington, D.C.: July 11,
2005.
Homeland Security: Process for Reporting Lessons Learned from Seaport
Exercises Needs Further Attention. [hyperlink,
http://www.gao.gov/products/GAO-05-170]. Washington, D.C.: January 14,
2005.
Homeland Security: Federal Leadership and Intergovernmental
Cooperation Required to Achieve First Responder Interoperable
Communications. [hyperlink, http://www.gao.gov/products/GAO-04-740].
Washington, D.C.: July 20, 2004.
Homeland Defense: DOD Needs to Assess the Structure of U.S. Forces for
Domestic Military Missions. [hyperlink,
http://www.gao.gov/products/GAO-03-670]. Washington, D.C.: July 11,
2003.
Combating Terrorism: Selected Challenges and Related Recommendations.
[hyperlink, http://www.gao.gov/products/GAO-01-822]. Washington, D.C.:
September 20, 2001.
[End of section]
Footnotes:
[1] White House, National Security Strategy (Washington, D.C.: May
2010).
[2] The adjutant general is the highest-ranking guardsman in each
state.
[3] National Defense Authorization Act for Fiscal Year 2006, Pub. L.
No. 109-163, § 412 (2006); H.R. Conf. Rep. No. 109-360, pg. 687 (2005).
[4] The NGB is a joint activity of DOD, and the Chief of the NGB
serves as the principal advisor to the Secretary of Defense through
the Chairman of the Joint Chiefs of Staff on matters involving non-
federalized National Guard forces. As directed by the Secretary of
Defense, the Secretary of the Army or the Secretary of the Air Force,
the Chief of the NGB also assists states in the organization,
maintenance, and operation of National Guard units to provide well-
trained and well-equipped units capable of augmenting the active
forces. DOD Directive 5105.77, National Guard Bureau (May 21, 2008).
[5] In some states, the adjutant general also serves as the lead state
emergency management official.
[6] GAO, Homeland Defense: National Guard Bureau Needs to Clarify
Civil Support Teams' Mission and Address Management Challenges,
[hyperlink, http://www.gao.gov/products/GAO-06-498] (Washington, D.C.:
May 31, 2006).
[7] GAO, Homeland Defense: Planning, Resourcing, and Training Issues
Challenge DOD's Response to Domestic Chemical, Biological,
Radiological, Nuclear and High-Yield Explosive Incidents, [hyperlink,
http://www.gao.gov/products/GAO-10-123], (Washington, D.C.: Oct. 7,
2009).
[8] Department of Defense, Quadrennial Defense Review Report,
(Washington D.C.: Feb. 1, 2010).
[9] In two of the seventeen states that host CERFPs and one of the ten
states that do not host CERFPs we surveyed, the Adjutant General also
serves as the lead emergency management official.
[10] Department of Homeland Security, National Response Framework
(Washington, D.C.: Jan. 2008). The National Response Framework--
previously known as the National Response Plan--is the plan that
guides how federal, state, local, and tribal governments, along with
nongovernmental and private sector entities, will collectively respond
to and recover from all hazards, including catastrophic disasters,
such as Hurricane Katrina.
[11] The Emergency Management Assistance Compact--a mutual aid
agreement among member states--provides form and structure to
interstate mutual aid by addressing a number of key issues. Congress
provided consent to this agreement in Pub. L. No. 104-321 (1996).
[12] Title 10 and Title 32 refer to titles of the United States Code.
[13] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504, National Guard Chemical Biological, Radiological
Nuclear and High Yield Explosive, Enhanced Response Force Package
Management (Oct. 16, 2009).
[14] Secretary of Defense Memorandum, Policy Implementation to
Establish Commander, USJFCOM (CDRUSJFCOM), as the Primary Joint Force
Provider (JFP) (June 25, 2004). The U.S. military organizes its global
presence into a series of geographic and functional combatant
commands. The geographic combatant commands--U.S. Central Command,
U.S. European Command, U.S. Northern Command, U.S. Pacific Command,
U.S. Southern Command, and U.S. Africa Command--have authority over
all U.S. military forces operating within a specified area of
operation and are directly responsible for the performance of missions
assigned to the command. The functional combatant commands--U.S.
Special Operations Command, U.S. Strategic Command, and U.S.
Transportation Command--possess worldwide functional responsibilities,
such as joint training, force provision, and global command and
control.
[15] Prior to the 2010 Quadrennial Defense Review, DOD planned to
establish three CCMRFs. Subsequently, DOD increased the capability of
one of the CCMRFs and restructured the other two CCMRFs as smaller
command and control CBRNE response organizations.
[16] On May 4, 2009, NGB issued a memorandum to the Operations
Directorate of the Joint Force Headquarters of the 17 States that host
CERFPs. The memo set out authorized levels of personnel and equipment
for CERFPs for the purpose of readiness reporting. According to the
memo, the authorized size of a CERFP--for purposes of personnel
reporting--is 186 personnel, not including the Fatality Search and
Recovery Team, the security element or other Joint Task Force
personnel that may be required during an event.
[17] Each state, the District of Columbia, and three territories have
at least one Civil Support Team (57 total) to support civil
authorities in the event of a domestic WMD event by identifying CBRNE
agents and substances used as WMD, assessing current and projected
consequences, and advising on response measures.
[18] The CBRNE response mission has immediacy, but officials from one
CERFP told us that part-time CERFP personnel cannot always respond
within the 6-hour timeframe because they may be unavailable for
reasons including being away from home on business or other reasons.
[19] External evaluations are field training exercises in which CERFPs
are assessed by external evaluators against collective tasks outlined
in CERFP training guidance.
[20] NGB issued the CERFP Joint Training Plan in January 2008. This
guidance was in place during the majority of our review. Collective
training is focused on preparing teams and units, whereas individual
training is focused on the proficiency of the single soldier.
[21] NGB sponsors special focus events--which are designed to address
specific training gaps. Vigilant Guard is an exercise program
sponsored by U.S. Northern Command in conjunction with the NGB. The
program provides states' National Guard an opportunity to improve
cooperation and relationships with civilian, federal, and military
partners in preparation for emergencies and catastrophic events.
[22] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504, National Guard Chemical Biological, Radiological
Nuclear and High Yield Explosive, Enhanced Response Force Package
Management (Oct. 16, 2009).
[23] National Guard Bureau, CBRNE Enhanced Response Force Package,
Training Year 2011, Yearly Training Guidance (Mar. 3, 2011).
[24] Personal protective equipment shields a person from the chemical,
physical, and thermal hazards that can be encountered at a hazardous
materials incident. Personal protective equipment includes both
personal protective clothing and respiratory protection. Adequate
personal protective equipment should protect the respiratory system,
skin, eyes, face, hands, feet, head, body, and hearing.
[25] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504 (Oct. 16, 2009).
[26] GAO, Reserve Forces: Actions Needed to Identify National Guard
Domestic Equipment Requirements and Readiness, [hyperlink,
http://www.gao.gov/products/GAO-07-60] (Washington, D.C.: Jan 26,
2007).
[27] In 1999, Congress directed the establishment of the Defense
Readiness Reporting System, and required that the system measure in an
objective, accurate and timely manner, capability of the armed forces
to carry out (1) the National Security Strategy prescribed by the
President, (2) the defense planning guidance provided by the Secretary
of Defense, and (3) the National Military Strategy prescribed by the
Chairman of the Joint Chiefs of Staff. DRRS provides Combatant
Commanders, Joint Task Force Commanders, Service Component Commanders,
Combat Support Agency Directors, and the National Guard Bureau with
relevant readiness data, in the form of capability assessments
supported by resource status, based upon whether they can perform
their assigned missions and associated mission essential tasks in a
joint, interagency, and multinational operational environment with the
forces provided.
[28] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504 (Oct. 16, 2009).
[29] CERFPs draw personnel to comprise the CBRNE elements from various
"parent" National Guard units that provide different response
capabilities. The parent unit is the usual reporting entity in the
Defense Readiness Reporting System.
[30] NGB officials stated that there are three total DRRS Centers of
Excellence, and that these centers were established to provide
guidance to all 54 states and territories as they transition to a DRRS
reporting standard.
[31] Department of Defense, Directive 5105.83, National Guard Joint
Force Headquarters-State (NG JFHQs-State) (Jan. 5, 2011).
[32] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21,
2005).
[33] GAO, Results-Oriented Government: Practices That Can Help Enhance
and Sustain Collaboration among Federal Agencies, [hyperlink,
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21,
2005).
[34] When fully implemented, the Standardization, Evaluation, and
Assistance Team program will conduct periodic field evaluations of the
17 CERFPs in order to assure Congress and DOD of program oversight;
assess the degree of compliance with law, policy and doctrine and
audit the disposition of allocated resources; assist states with the
CERFP mission to develop programs to establish and maintain
capabilities and compliance; and provide NGB with detailed information
for use in CERFP management decisions.
[35] According to NGB officials, the CERFP area of responsibility for
pre-incident coordination includes organizations within the CERFP's
FEMA region, as well as national-level organizations.
[36] GAO, Emergency Management Assistance Compact: Enhancing EMAC's
Collaborative and Administrative Capacity Should Improve National
Disaster Response, [hyperlink, http://www.gao.gov/products/GAO-07-854]
(Washington, D.C.: June 29, 2007).
[37] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504 (Oct. 16, 2009).
[38] Vigilant Guard is an exercise program sponsored by the U. S.
Northern Command in conjunction with NGB. The program provides state
National Guards an opportunity to improve cooperation and
relationships with civilian, federal, and military partners in
preparation for emergencies and catastrophic events.
[39] DOD defines command and control as the exercise of authority and
direction by a properly designated commander over assigned and
attached forces in the accomplishment of the mission. Command and
control functions are performed through an arrangement of personnel,
equipment, communications, facilities, and procedures employed by a
commander in planning, directing, coordinating, and controlling forces
and operations in the accomplishment of the mission. See Joint Chiefs
of Staff, Joint Pub. 1-02, Department of Defense Dictionary of
Military and Associated Terms (Nov. 8, 2010; as amended through Aug.
15, 2011), p. 61.
[40] Army National Guard Regulation 500-4/Air National Guard
Instruction 10-2504 (Oct. 16, 2009).
[41] The National Response Framework and National Incident Management
System comprise the national framework for domestic incident response,
providing the structure and mechanisms for national level policy of
incident response and a template for the management of incidents. See
also Joint Chiefs of Staff, Joint Pub. 3-28, Civil Support (Sept. 14,
2007) and Joint Pub. 3-41, Chemical, Biological, Radiological,
Nuclear, and High-Yield Explosives Consequence Management (Oct. 2,
2006).
[42] Local fire and rescue, law enforcement, and emergency medical
personnel constitute the first tier. If the extent of an 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.
[43] "Technical reach-back" is the capability to contact a technical
subject matter expert when an issue exceeds the expertise of on-site
personnel. Army Tactics, Techniques, and Procedures No. 3-11.47/Air
Force Tactics, Techniques and Procedures No. 3-2.79, Chemical,
Biological, Radiological, Nuclear, and High-Yield Explosives Enhanced
Response Force Package Operations is currently in draft form and has
not yet been published.
[44] The Joint Incident Site Communications Capability provides
interoperable communications and emergency satellite links to command
and control centers to share information and tools needed to support
collaboration with other federal, state, and local responders
including the Federal Emergency Management Agency, Department of
Homeland Security, and state emergency management agencies.
[45] The Unified Command Suite is a mobile communications system
employed in support of the Weapons of Mass Destruction Civil Support
Teams. The Unified Command Suite provides real-time voice, data, and
video connectivity among Civil Support Team members, local and state
emergency response agencies, lead federal agencies, and supporting
military activities.
[46] NGB officials stated that they have subsequently realigned the
Fatality, Search, and Recovery Teams geographically, reducing the
number of CERFPs aligned with out-of-state teams from 9 CERFPs to 2
CERFPs.
[47] National Guard Bureau. National Guard Chemical Biological,
Radiological Nuclear and High Yield Explosive, Enhanced Response Force
Package, Concept of Operations (July 7, 2009).
[48] National Guard Bureau, Army National Guard Regulation 500-4/Air
National Guard Instruction 10-2504, National Guard Chemical,
Biological, Radiological, Nuclear, and High-Yield Explosive Enhanced
Response Force Package Management (Oct. 16, 2009).
[49] National Guard Bureau, Joint Training Plan (Jan. 16, 2008) and
National Guard Bureau, CBRNE Enhanced Response Force Package and
Training Year 2011, Yearly Training Guidance (Mar. 3, 2011).
[50] Department of Army. Army Tactics, Techniques, and Procedures 3-
11.47/Air Force Tactics, Techniques, and Procedures 3-2.79, Final
Coordination Draft, National Guard Chemical Biological, Radiological
Nuclear and High Yield Explosive, Emergency Response Force Package
Operations (Washington, D.C.: January 2011).
[51] CERFPs' areas of responsibility include the 50 states, the
District of Columbia, Guam, Puerto Rico, and the U.S. Virgin Islands.
For purposes of our surveys, we treated all of these entities as
states.
[52] In total, three states we surveyed do not have separate state-
level emergency managers. In Hawaii and Nebraska, which host CERFPs,
and Kansas, which does not host a CERFP, the State Adjutant General
also serves as the lead emergency management official.
[53] GAO, Military Readiness: Army and Marine Corps Reporting Provides
Additional Data, but Actions Needed to Improve Consistency [hyperlink,
http://www.gao.gov/products/GAO-11-526] (Washington, D.C.: June 3,
2011); Military Readiness: DOD Needs to Strengthen Management and
Oversight of the Defense Readiness Reporting System [hyperlink,
http://www.gao.gov/products/GAO-09-518] (Washington, D.C.: Sept. 25,
2009); and Reserve Forces: Actions Needed to Identify National Guard
Domestic Equipment Requirements and Readiness [hyperlink,
http://www.gao.gov/products/GAO-07-60] (Washington, D.C.: Jan. 26,
2007).
[54] This guidance did not articulate specific interagency training
goals for fiscal year 2010.
[End of section]
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