Disaster Response
Criteria for Developing and Validating Effective Response Plans Gao ID: GAO-10-969T September 22, 2010Among the lessons learned from the aftermath of Hurricane Katrina was that effective disaster response requires planning followed by the execution of training and exercises to validate those plans. The Federal Emergency Management Agency (FEMA) is responsible for disaster response planning. This testimony focuses on (1) criteria for effective disaster response planning established in FEMA's National Response Framework, (2) additional guidance for disaster planning, (3) the status of disaster planning efforts, and (4) special circumstances in planning for oil spills. This testimony is based on prior GAO work on emergency planning and response, including GAO's April 2009 report on the FEMA efforts to lead the development of a national preparedness system. GAO reviewed the policies and plans that form the basis of the preparedness system. GAO did not assess any criteria used or the operational planning for the Deepwater Horizon response.
FEMA's National Response Framework identifies criteria for effective response and response planning, including (1) acceptability (meets the requirement of anticipated scenarios and is consistent with applicable laws); (2) adequacy (complies with applicable planning guidance); (3) completeness (incorporates major actions, objectives, and tasks); (4) consistency and standardization of products (consistent with other related documents); (5) feasibility (tasks accomplished with resources available); (6) flexibility (accommodating all hazards and contingencies); and (7) interoperability and collaboration (identifies stakeholders and integrates plans). In addition to the National Response Framework, FEMA has developed standards that call for validation, review, and testing of emergency operations plans. According to FEMA, exercises offer the best way, short of emergencies, to determine if such plans are understood and work. FEMA's guidance also suggests that officials use functional and full-scale emergency management exercises to evaluate plans. Other national standards reflect these practices as well. For example, the Emergency Management Accreditation Program standards call for a program of regularly scheduled drills, exercises, and appropriate follow-through activities, as a critical component of a state, territorial, tribal, or local emergency management program. GAO reported in April 2009 that FEMA lacked a comprehensive approach to managing the development of emergency preparedness policies and plans. Specifically, GAO reported that FEMA had completed many policy and planning documents, but a number of others were not yet completed. In February 2010, the Department of Homeland Security's (DHS) Office of Inspector General reviewed the status of these planning efforts and reported that the full set of plans for any single scenario had not yet been completed partly because of the time required to develop and implement the Integrated Planning System. The Integrated Planning System, required by Annex 1 to Homeland Security Presidential Directive 8 (December 2007), is intended to be a standard and comprehensive approach to national planning. Oil spills are a special case with regard to response. The National Response Framework has 15 functional annexes that provide the structure for coordinating federal interagency support for a federal response to an incident. Emergency Support Function #10--Oil and Hazardous Materials Response Annex--governs oil spills. Under this function, the Environmental Protection Agency is the lead for incidents in the inland zone, and the U.S. Coast Guard, within DHS, is the lead for incidents in the coastal zone. This difference underscores the importance of including clear roles, responsibilities, and legal authorities in developing operational response plans. GAO is not making any new recommendations in this testimony but has made recommendations to FEMA in previous reports to strengthen disaster response planning, including the development of a management plan to ensure the completion of key national policies and planning documents. FEMA concurred and is currently working to address this recommendation.
GAO-10-969T, Disaster Response: Criteria for Developing and Validating Effective Response Plans
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Testimony:
Before the Committee on Homeland Security, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Wednesday, September 22, 2010:
Disaster Response:
Criteria for Developing and Validating Effective Response Plans:
Statement of William O. Jenkins, Jr., Director:
Homeland Security and Justice Issues:
GAO-10-969T:
GAO Highlights:
Highlights of GAO-10-969T, a testimony before the Committee on
Homeland Security, House of Representatives.
Why GAO Did This Study:
Among the lessons learned from the aftermath of Hurricane Katrina was
that effective disaster response requires planning followed by the
execution of training and exercises to validate those plans. The
Federal Emergency Management Agency (FEMA) is responsible for disaster
response planning. This testimony focuses on (1) criteria for
effective disaster response planning established in FEMA‘s National
Response Framework, (2) additional guidance for disaster planning,
(3) the status of disaster planning efforts, and (4) special
circumstances in planning for oil spills. This testimony is based on
prior GAO work on emergency planning and response, including GAO‘s
April 2009 report on the FEMA efforts to lead the development of a
national preparedness system. GAO reviewed the policies and plans that
form the basis of the preparedness system. GAO did not assess any
criteria used or the operational planning for the Deepwater Horizon
response.
What GAO Found:
FEMA‘s National Response Framework identifies criteria for effective
response and response planning, including (1) acceptability (meets the
requirement of anticipated scenarios and is consistent with applicable
laws); (2) adequacy (complies with applicable planning guidance); (3)
completeness (incorporates major actions, objectives, and tasks); (4)
consistency and standardization of products (consistent with other
related documents); (5) feasibility (tasks accomplished with resources
available); (6) flexibility (accommodating all hazards and
contingencies); and (7) interoperability and collaboration (identifies
stakeholders and integrates plans).
In addition to the National Response Framework, FEMA has developed
standards that call for validation, review, and testing of emergency
operations plans. According to FEMA, exercises offer the best way,
short of emergencies, to determine if such plans are understood and
work. FEMA‘s guidance also suggests that officials use functional and
full-scale emergency management exercises to evaluate plans. Other
national standards reflect these practices as well. For example, the
Emergency Management Accreditation Program standards call for a
program of regularly scheduled drills, exercises, and appropriate
follow-through activities, as a critical component of a state,
territorial, tribal, or local emergency management program.
GAO reported in April 2009 that FEMA lacked a comprehensive approach
to managing the development of emergency preparedness policies and
plans. Specifically, GAO reported that FEMA had completed many policy
and planning documents, but a number of others were not yet completed.
In February 2010, the Department of Homeland Security‘s (DHS) Office
of Inspector General reviewed the status of these planning efforts and
reported that the full set of plans for any single scenario had not
yet been completed partly because of the time required to develop and
implement the Integrated Planning System. The Integrated Planning
System, required by Annex 1 to Homeland Security Presidential
Directive 8 (December 2007), is intended to be a standard and
comprehensive approach to national planning.
Oil spills are a special case with regard to response. The National
Response Framework has 15 functional annexes that provide the
structure for coordinating federal interagency support for a federal
response to an incident. Emergency Support Function #10”Oil and
Hazardous Materials Response Annex”governs oil spills. Under this
function, the Environmental Protection Agency is the lead for
incidents in the inland zone, and the U.S. Coast Guard, within DHS, is
the lead for incidents in the coastal zone. This difference
underscores the importance of including clear roles, responsibilities,
and legal authorities in developing operational response plans.
What GAO Recommends:
GAO is not making any new recommendations in this testimony but has
made recommendations to FEMA in previous reports to strengthen
disaster response planning, including the development of a management
plan to ensure the completion of key national policies and planning
documents. FEMA concurred and is currently working to address this
recommendation.
View [hyperlink, http://www.gao.gov/products/GAO-10-969T] or key
components. For more information, contact William O. Jenkins, Jr. at
(202) 512-8757 or JenkinsWO@gao.gov.
[End of section]
Mr. Chairman and Members of the Committee:
I am pleased to be here this morning to discuss the importance of
preparing, validating, and testing emergency operations plans for
disaster response. Among the lessons learned from the aftermath of
Hurricane Katrina was that effective disaster response requires
planning followed by the execution of training and exercises to
validate those plans. The development of detailed emergency operations
plans and the validation of those plans through testing and exercising
is a key component of effective disaster response planning. These
plans are part of a broader cycle of emergency preparedness that
includes policy development, planning and resource allocation,
exercising and testing operational plans, and assessment and
reporting.[Footnote 1]
To help guide federal emergency response planning, the Federal
Emergency Management Agency (FEMA) developed the National Response
Framework, in conjunction with a variety of stakeholders, as a
blueprint for how the nation conducts response to hazards of any type,
regardless of cause. The National Response Framework, which was issued
in January 2008, describes planning as the cornerstone of national
preparedness and a critical element for response to a disaster or
emergency. Response plans define the roles and responsibilities of all
those who will have a role in the response and the capabilities they
will contribute to the effort and provide a blueprint for how the
response will be directed, managed, and coordinated. In addition, in
June 2010, as part of its Voluntary Private Sector Preparedness
Accreditation and Certification Program, FEMA adopted three private
sector standards for use by U.S. companies in emergency planning and
response. These standards provide that organizations should test and
evaluate the appropriateness and efficacy of their emergency response
plans.[Footnote 2]
My comments are based on our previously issued work on emergency
planning and response over the last several years, including our April
2009 report on FEMA's efforts to lead the development of a national
preparedness system.[Footnote 3] Specifically, my testimony today
focuses on (1) the criteria for effective disaster response planning
established in FEMA's National Response Framework, (2) additional
guidance for disaster response planning, (3) the status of national
disaster response planning efforts, and (4) the special circumstances
related to operational response planning for oil spills.
To address these objectives, we reviewed the policies and plans that
form the basis of the preparedness system. These policies and plans
include, among others, the National Response Framework and National
Preparedness Guidelines, as well as the national integrated planning
system and preliminary versions of related guidance to develop and
integrate plans across federal, state, tribal, and local governments.
We also reviewed the Department of Homeland Security's (DHS) Office of
Inspector General report on the status of FEMA's disaster response
planning efforts. For the purposes of this testimony, we did not
assess any criteria used or the operational planning for the Deepwater
Horizon response. More detailed information about our scope and
methodology is included in our April 2009 report. We conducted this
work in accordance with generally accepted government auditing
standards.
National Response Framework's Criteria for Response Planning:
The National Response Framework discusses several elements of
effective response and response planning. The term response, as used
in the National Response Framework, includes the immediate actions to
save lives, protect property and the environment, and meet basic human
needs. Response also includes the execution of emergency plans and
actions to support short-term recovery. An effective, unified national
response--including the response to any large-scale incident--requires
layered, mutually supporting capabilities--governmental and
nongovernmental. Indispensable to effective response is an effective
unified command, which requires a clear understanding of the roles and
responsibilities of each participating organization.
The National Response Framework employs the following criteria to
measure key aspects of response planning:
* Acceptability. A plan is acceptable if it can meet the requirements
of anticipated scenarios, can be implemented within the costs and time
frames that senior officials and the public can support, and is
consistent with applicable laws.
* Adequacy. A plan is adequate if it complies with applicable planning
guidance, planning assumptions are valid and relevant, and the concept
of operations identifies and addresses critical tasks specific to the
plan's objectives.[Footnote 4]
* Completeness. A plan is complete if it incorporates major actions,
objectives, and tasks to be accomplished. The complete plan addresses
the personnel and resources required and sound concepts for how those
will be deployed, employed, sustained, and demobilized. It also
addresses timelines and criteria for measuring success in achieving
objectives and the desired end state. Including all those who could be
affected in the planning process can help ensure that a plan is
complete.
* Consistency and standardization of products. Standardized planning
processes and products foster consistency, interoperability, and
collaboration, therefore, emergency operations plans for disaster
response should be consistent with all other related planning
documents.
* Feasibility. A plan is considered feasible if the critical tasks can
be accomplished with the resources available internally or through
mutual aid, immediate need for additional resources from other sources
(in the case of a local plan, from state or federal partners) are
identified in detail and coordinated in advance, and procedures are in
place to integrate and employ resources effectively from all potential
providers.
* Flexibility. Flexibility and adaptability are promoted by
decentralized decisionmaking and by accommodating all hazards ranging
from smaller-scale incidents to wider national contingencies.
* Interoperability and collaboration. A plan is interoperable and
collaborative if it identifies other stakeholders in the planning
process with similar and complementary plans and objectives, and
supports regular collaboration focused on integrating with those
stakeholders' plans to optimize achievement of individual and
collective goals and objectives in an incident.
[End of section]
Additional Guidance and Policy regarding Operational Plans and Testing:
Under the Post-Katrina Emergency Management Reform Act, FEMA has
responsibility for leading the nation in developing a national
preparedness system.[Footnote 5] FEMA has developed standards--the
Comprehensive Preparedness Guide 101--that call for validation,
review, and testing of emergency operations plans (EOP).[Footnote 6]
According to the Comprehensive Preparedness Guide 101, plans should be
reviewed for conformity to applicable regulatory requirements and the
standards of federal or state agencies (as appropriate) and for their
usefulness in practice. Exercises offer the best way, short of
emergencies, to determine if an EOP is understood and "works."
Further, conducting a "tabletop" exercise involving the key
representatives of each tasked organization can serve as a practical
and useful means to help validate the plan. FEMA's guidance also
suggests that officials use functional and full-scale emergency
management exercises to evaluate EOPs. Plan reviews by stakeholders
also allow responsible agencies to suggest improvements in an EOP
based on their accumulated experience.[Footnote 7]
We also identified the need for validated operational planning in the
aftermath of Hurricane Katrina, noting that to be effective, national
response policies must be supported by robust operational plans. In
September 2006, we recommended, among other things, that DHS take the
lead in monitoring federal agencies' efforts to meet their
responsibilities under the National Response Plan (now the National
Response Framework) and the National Preparedness Goal (now the
National Preparedness Guidelines), including the development, testing,
and exercising of agency operational plans to implement their
responsibilities.[Footnote 8] DHS concurred with our recommendation.
The Post-Katrina Emergency Management Reform Act transferred
preparedness responsibilities to FEMA,[Footnote 9] and we recommended
in April 2009 that FEMA should improve its approach to developing
policies and plans that define roles and responsibilities and planning
processes by developing a program management plan, in coordination
with DHS and other federal entities, to ensure the completion of the
key national preparedness policies and plans called for in
legislation, presidential directives, and existing policy and
doctrine; to define roles and responsibilities and planning processes;
as well as to fully integrate such policies and plans into other
elements of the national preparedness system.[Footnote 10] FEMA
concurred with our recommendation and is currently working to address
this recommendation.
Other national standards reflect these practices as well. For example,
according to Emergency Management Accreditation Program (EMAP)
standards, the development, coordination and implementation of
operational plans and procedures are fundamental to effective disaster
response and recovery.[Footnote 11] EOPs should identify and assign
specific areas of responsibility for performing essential functions in
response to an emergency or disaster. Areas of responsibility to be
addressed in EOPs include such things as evacuation, mass care,
sheltering, needs and damage assessment, mutual aid, and military
support. EMAP standards call for a program of regularly scheduled
drills, exercises, and appropriate follow-through activities--designed
for assessment and evaluation of emergency plans and capabilities--as
a critical component of a state, territorial, tribal or local
emergency management program. The documented exercise program should
regularly test the skills, abilities, and experience of emergency
personnel as well as the plans, policies, procedures, equipment, and
facilities of the jurisdiction. The exercise program should be
tailored to the range of hazards that confronts the jurisdiction.
Status of National Disaster Planning Efforts:
We reported in April 2009 that FEMA lacked a comprehensive approach to
managing the development of emergency preparedness policies and
plans.[Footnote 12] Specifically, we reported that FEMA had completed
many policy and planning documents, but a number of others were not
yet completed. For example, while DHS, FEMA, and other federal
entities with a role in national preparedness have taken action to
develop and complete some plans that detail and operationalize roles
and responsibilities for federal and nonfederal entities, these
entities had not completed 68 percent of the plans required by
existing legislation, presidential directives, and policy documents as
of April 2009.
Specifically, of the 72 plans we identified, 20 had been completed (28
percent), 3 had been partially completed (that is, an interim or draft
plan has been produced--4 percent), and 49 (68 percent) had not been
completed. Among the plans that have been completed, FEMA published
the Pre-Scripted Mission Assignment Catalog in 2008, which defines
roles and responsibilities for 236 mission assignment activities to be
performed by federal government entities, at the direction of FEMA, to
aid state and local jurisdictions during a response to a major
disaster or an emergency. Among the 49 plans that had not been
completed were the National Response Framework incident annexes for
terrorism and cyberincidents as well as the National Response
Framework's incident annex supplements for catastrophic disasters and
mass evacuations. In addition, operational plans for responding to the
consolidated national planning scenarios, as called for in Homeland
Security Presidential Directive 8, Annex 1, remained outstanding.
In February 2010, DHS's Office of Inspector General reviewed the
status of these planning efforts and reported that the full set of
plans for any single scenario had not yet been completed partly
because of the time required to develop and implement the Integrated
Planning System.[Footnote 13] The Integrated Planning System, required
by Annex 1 to Homeland Security Presidential Directive 8 (December
2007), is intended to be a standard and comprehensive approach to
national planning. The Directive calls for the Secretary of Homeland
Security to lead the effort to develop, in coordination with the heads
of federal agencies with a role in homeland security, the Integrated
Planning System followed by a series of related planning documents for
each national planning scenario. The Homeland Security Council
compressed the 15 National Planning Scenarios into 8 key scenario sets
in October 2007 to integrate planning for like events and to conduct
crosscutting capability development. [Footnote 14] The redacted
version of the Inspector General's report noted that DHS had completed
integrated operations planning for 1 of the 8 consolidated national
planning scenarios[Footnote 15]--the terrorist use of explosives
scenario.[Footnote 16] FEMA officials reported earlier this month that
the agency's efforts to complete national preparedness planning will
be significantly impacted by the administration's pending revision to
Homeland Security Presidential Directive-8. Once the new directive is
issued, agency officials plan to conduct a comprehensive review and
update to FEMA's approach to national preparedness planning.
In addition to FEMA's planning efforts, FEMA has assessed the status
of catastrophic planning in all 50 States and the 75 largest urban
areas as part of its Nationwide Plan Review. The 2010 Nationwide Plan
Review was based on the 2006 Nationwide Plan Review, which responded
to the need both by Congress and the President to ascertain the status
of the nation's emergency preparedness planning in the aftermath of
Hurricane Katrina. The 2010 Nationwide Plan Review compares the
results of the 2006 review of states and urban areas' plans,
functional appendices and hazard-specific annexes, on the basis of:
* Consistency with Comprehensive Preparedness Guide 101,
* Date of last plan update,
* Date of last exercise, and:
* A self-evaluation of the jurisdiction's confidence in each planning
document's adequacy, feasibility and completeness to manage a
catastrophic event.
FEMA reported in July 2010 that more than 75 percent of states and
more than 80 percent of urban areas report confidence that their
overall basic emergency operations plans are well-suited to meet the
challenges presented during a large-scale or catastrophic event.
Operational Response Plans for Oil Spill Responses:
Oil spills are a special case with regard to response. For most major
disasters, such as floods or earthquakes, a major disaster declaration
activates federal response activities under the provisions of the
Robert T. Stafford Disaster Relief and Emergency Assistance Act.
[Footnote 17] However, for oil spills, federal agencies may have
direct authority to respond under specific statutes. Response to an
oil spill is generally carried out in accordance with the National Oil
and Hazardous Substances Pollution Contingency Plan.[Footnote 18] The
National Response Framework has 15 functional annexes, such as search
and rescue, which provide the structure for coordinating federal
interagency support for a federal response to an incident. Emergency
Support Function #10, the Oil and Hazardous Materials Response Annex,
governs oil spills. As described in Emergency Support Function #10, in
general, the Environmental Protection Agency is the lead for incidents
in the inland zone, and the U.S. Coast Guard, within DHS, is the lead
for incidents in the coastal zone. The difference in responding to oil
spills and the shared responsibility across multiple federal agencies
underscores the importance of including clear roles, responsibilities,
and legal authorities in developing operational response plans.
In conclusion, Mr. Chairman, emergency preparedness is a never-ending
effort as threats evolve and the capabilities needed to respond to
those threats changes as well. Realistic, validated, and tested
operational response plans are key to the effective response to a
major disaster of whatever type. Conducting exercises of these plans
as realistically as possible is a key component of response
preparedness because exercises help to identify what "works"
(validates and tests) and what does not.
This concludes my statement. I will be pleased to respond to any
questions you or other members of the committee may have.
Contacts and Acknowledgments:
For further information on this statement, please contact William O.
Jenkins, Jr. at (202) 512-8757 or JenkinsWO@gao.gov. Contact points
for our Offices of Congressional Relations and Public Affairs may be
found on the last page of this statement.
Key contributors to this statement were Stephen Caldwell, Director,
Chris Keisling, Assistant Director, John Vocino, Analyst-In-Charge,
Linda Miller, Communications Analyst.
[End of section]
Footnotes:
[1] The elements of the emergency management framework are discussed
in detail in our April 2009 report on the Federal Emergency Management
Agency's efforts to lead the development of a national preparedness
system. See GAO, 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.: Apr. 30, 2009).
[2] American National Standards Institute, Organizational Resilience:
Security, Preparedness, and Continuity Management Systems-Requirements
with Guidance for Use ASIS SPC.1-2009 (Mar. 12, 2009).
[3] See for example, [hyperlink,
http://www.gao.gov/products/GAO-09-369], GAO Actions Taken to
Implement the Post-Katrina Emergency Management Reform Act of 2006
[hyperlink, http://www.gao.gov/products/GAO-09-95R] (Washington, D.C.:
Nov. 21, 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.), and 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.: Sept. 6, 2006).
[4] A concept plan describes how capabilities are integrated and
synchronized to accomplish critical tasks to meet objectives.
[5] Pub. L. No. 109-295, § 644, 120 Stat. 1355, 1425 (2006).
[6] Department of Homeland Security, Federal Emergency Management
Agency, Comprehensive Preparedness Guide (CPG) 101: Developing and
Maintaining State, Territorial, Tribal, and Local Government Emergency
Plans. Mar. 2009.
[7] For example, states may review local plans.
[8] GAO, 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.: Sept. 6,
2006).
[9] 6 U.S.C. § 315.
[10] [hyperlink, http://www.gao.gov/products/GAO-09-369].
[11] The EMAP standards are the voluntary national accreditation
process for state, territorial, tribal, and local emergency management
programs. Using collaboratively developed, recognized standards and
independent assessment, EMAP provides a means for strategic
improvement of emergency management programs, culminating in
accreditation.
[12] [hyperlink, http://www.gao.gov/products/GAO-09-369].
[13] Department of Homeland Security, Office of Inspector General,
DHS' Progress in Federal Incident Management Planning (Redacted), OIG-
10-58 (Washington, D.C., Feb. 22, 2010.)
[14] The eight scenarios are (1) explosives attack (terrorist use of
explosives); (2) nuclear attack (improvised nuclear device); (3)
biological attack (aerosol anthrax, plague, food contamination,
foreign animal disease); (4) radiological attack (radiological
dispersal devices); (5) chemical attack (blister agent, toxic
industrial chemicals, nerve agent, chlorine tank explosion); (6)
natural disaster (major earthquake, major hurricane); (7) cyberattack;
and (8) pandemic influenza.
[15] The DHS IG's report noted that DHS had completed five of the
eight strategic guidance statements and four strategic plans. See DHS
OIG-10-58.
[16] To align with Homeland Security Presidential Directive 19, in
July 2008 the improvised explosive device scenario was renamed the
Terrorist Use of Explosives scenario.
[17] 42 U.S.C. §§ 5121-5206.
[18] The National Oil and Hazardous Substances Pollution Contingency
Plan, more commonly called the National Contingency Plan or NCP, is
the federal government's blueprint for responding to both oil spills
and hazardous substance releases.
[End of section]
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