HOMELAND 

DEFENSE AND 

WEAPONS OF MASS 

DESTRUCTION

Additional Steps 

Could Enhance the 

Effectiveness of the 

National Guard’s LifeSaving Response 

Forces

Report to Congressional Requesters

December 2011

GAO-12-114

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-114, a 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

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 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.

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. 

View GAO-12-114 or key components.

For more information, contact Janet St. 

Laurent at (202) 512-4300 or 

stlaurentj@gao.gov. 
Page i GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Letter 1 

Background 5

CERFPs Face Personnel, Training, and Equipment Requirements 

Challenges, and Readiness Is Not Comprehensively Reported 12

Opportunities Exist to Enhance Coordination with Other Response 

Organizations 28

A Command and Control Framework Is in Place, but Several 

Factors May Inhibit CERFPs’ Operational Effectiveness 38

Conclusions 49

Recommendations for Executive Action 51

Agency Comments and Our Evaluation 52

Appendix I Scope and Methodology 56

Appendix II CERFP Interagency Training, 2008-2010 60

Appendix III Comments from the Department of Defense 64

Appendix IV GAO Contact and Staff Acknowledgments 68

Related GAO Products 69

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 15

Table 2: Number of CERFPs That Had Authorized Quantities of 

Equipment as of October 2010 22

Figures

Figure 1: States That Have CERFPs within the 10 FEMA Regions 7

Contents
Page ii GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 2: Approximate Time Frames within Which Some DOD 

CBRNE Consequence Management Forces Are Expected 

to Deploy after an Incident 8

Figure 3: CERFPs Are Formed from the State’s National Guard 9

Figure 4: States That Will Host CERFPs and Homeland Response 

Forces by September 2012 12

Figure 5: Adjutants General Responses on CERFP Interaction with 

Local, State, Regional, and Federal Response 

Organizations 30

Figure 6: Command and Control Structure for State Active Duty 

and Title 32 CERFP Response Operations 41

Figure 7: Potential CERFP Incident Site Response Partners and 

Communications Pathways 44

Figure 8: CERFP Joint Field Training with Select Potential 

Response Partners, 2008-2010 61

Figure 9: CERFP Joint Field Training with Emergency Management 

Agencies from States with CERFPs, 2008-2010 62

Figure 10: CERFP Joint Field Training with Emergency 

Management Agencies from States without CERFPs, 2008-

2010 62

Figure 11: CERFP Joint Field Training with State National Guards 

from States without CERFPs, 2008-2010 63

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

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.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 general2

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 

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.

 

1 White House, National Security Strategy (Washington, D.C.: May 2010).

2 The adjutant general is the highest-ranking guardsman in each state.

 
 

Page 2 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.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.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.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.6

 

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).

DOD 

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, GAO-06-498 (Washington, D.C.: May 31, 

2006).
 

Page 3 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 brigadesized 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.7 Further, the 2010 Quadrennial Defense Review initiated 

changes to the existing structure of DOD’s consequence management 

response efforts. 8

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.

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.

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 

 

7 GAO, Homeland Defense: Planning, Resourcing, and Training Issues Challenge DOD’s 

Response to Domestic Chemical, Biological, Radiological, Nuclear and High-Yield 

Explosive Incidents, GAO-10-123, (Washington, D.C.: Oct. 7, 2009). 

8 Department of Defense, Quadrennial Defense Review Report, (Washington D.C.: Feb. 

1, 2010).
 

Page 4 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.9

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.

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.

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.

 

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. 
 

Page 5 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.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).11

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:

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.

• National Guard CSTs, which are comprised of 22 full-time personnel, 

with at least one team located in each state, the District of Columbia, 

 

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). 

Background
 

Page 6 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 fig. 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.
 

Page 7 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 1: States That Have CERFPs within the 10 FEMA Regions

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.
 

Page 8 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 2: Approximate Time Frames within Which Some DOD CBRNE Consequence 

Management Forces Are Expected to Deploy after an Incident

As National Guard units, CERFP personnel may operate in Title 10 

status, Title 32 status or state active duty status.12

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.

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.

 

12 Title 10 and Title 32 refer to titles of the United States Code.
 

Page 9 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 3: CERFPs Are Formed from the State’s National Guard

a

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 elements are usually geographically separated within the host state, and occasionally 

across multiple states 
 

Page 10 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.13

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.

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.

14

 

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. 
 

Page 11 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.15

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 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.

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.

 

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. 
 

Page 12 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 4: States That Will Host CERFPs and Homeland Response Forces by September 2012

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 

CERFPs Face 

Personnel, Training, 

and Equipment 

Requirements 

Challenges, and 

Readiness Is Not 

Comprehensively 

Reported
 

Page 13 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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 parttime. But NGB also provides some full-time staff to carry out the day-today 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.

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.17

Also, the Marine Corps’ Chemical Biological Incident Response Force, 

 

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. 

CERFPs Are Challenged in 

Maintaining Adequate 

Numbers of Personnel to 

Execute the CERFP 

Mission
 

Page 14 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.18

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.

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 fulltime personnel would be sufficient to perform the CERFP’s daily planning 

and operating requirements.

 

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.
 

Page 15 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 

All of the 

time

Less than all of 

the time

Perform command and control of CERFP operations 13 4 

Perform intended mission 8 9 

Perform hazardous materials operations 8 9 

Perform search and rescue operations 8 9 

Source: GAO Survey of CERFP State Adjutants General.

Note: These numbers are based on a total of 17 CERFPs. 

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 heatrelated 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.
 

Page 16 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

• 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 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.

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
 

Page 17 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.19

 

19 External evaluations are field training exercises in which CERFPs are assessed by 

external evaluators against collective tasks outlined in CERFP training guidance.

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 
 

Page 18 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.20 NGB 

has not provided specific guidance for participation in interagency field 

exercises (including the frequency of that participation) beyond 2009.21

 

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. 
 

Page 19 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.22

 

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). 

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 
 

Page 20 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.23

• working to demonstrate interoperability with other CERFPs and other 

National Guard CBRNE organizations;

Specifically, 

fiscal year 2011 training goals include

• 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.

 

23 National Guard Bureau, CBRNE Enhanced Response Force Package, Training Year 

2011, Yearly Training Guidance (Mar. 3, 2011).
 

Page 21 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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.

CERFPs Generally Have 

Their Authorized 

Equipment, but Additional 

Equipment May Be Needed 

to Adequately Perform 

Mission
 

Page 22 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Table 2: Number of CERFPs That Had Authorized Quantities of Equipment as of 

October 2010

CERFPs had the authorized levels of equipment 

needed to

All of the 

time

Most of 

the time

Some of 

the time

Conduct mass casualty decontamination 12 5 0 

Extract victims from contaminated environments 10 7 0 

Provide emergency medical triage services 11 6 0 

Perform command and control 12 4 1 

Source: GAO survey of State Adjutants General.

Note: Numbers are based on a total of 17 CERFPs. 

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.24

State Adjutants General and CERFP officials told us that because

authorized quantities of equipment are not always adequate to 

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.

 

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. 
 

Page 23 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 guidance states that integrated working groups will be 

established to annually review and validate CERFP personnel, training, 

and equipment.25

 

25 Army National Guard Regulation 500-4/Air National Guard Instruction 10-2504 (Oct. 16, 

2009). 

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.

National Guard Has Not 

Established an Annual 

Requirement Review and 

Validation Process
 

Page 24 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.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.27

 

26 GAO, Reserve Forces: Actions Needed to Identify National Guard Domestic Equipment 

Requirements and Readiness, 

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, 

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.

CERFP Readiness Data Is 

Not Transparent or 

Complete and Cannot Be 

Efficiently Disseminated to 

Other DOD Response 

Partners
 

Page 25 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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,28

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.

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.

29

 

28 Army National Guard Regulation 500-4/Air National Guard Instruction 10-2504 (Oct. 16, 

2009). 

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

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. 
 

Page 26 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.30

 

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. 

NGB also has plans to increase state National Guards’ 
 

Page 27 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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,31

• 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.

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.

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.

 

31 Department of Defense, Directive 5105.83, National Guard Joint Force HeadquartersState (NG JFHQs-State) (Jan. 5, 2011).
 

Page 28 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 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 

Opportunities Exist to 

Enhance 

Coordination with 

Other Response 

Organizations

CERFPs Achieved Varying 

Levels of Success in 

Coordinating with Some of 

Their Potential Response 

Partners
 

Page 29 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.
 

Page 30 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 5: Adjutants General Responses on CERFP Interaction with Local, State, Regional, and Federal Response 

Organizations

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 
 

Page 31 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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 

Insufficient Coordination 

Guidance, Limited 

Awareness of Guidance, 

and Other Challenges 

Inhibit Coordination 

Efforts
 

Page 32 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 
 

Page 33 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.
 

Page 34 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.32 We further reported that reporting on these 

activities can provide program officials with the data necessary to improve 

coordination policy and practice. 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.34

 

32 GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, 

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 

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, 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. 

NGB’s Tool for Evaluating 

the CERFPs’ Coordination 

Efforts Is Limited by 

Current Guidance
 

Page 35 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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,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.

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.36

 

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 nationallevel organizations. 

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.

36 GAO, Emergency Management Assistance Compact: Enhancing EMAC’s Collaborative 

and Administrative Capacity Should Improve National Disaster Response, GAO-07-854

(Washington, D.C.: June 29, 2007). 

Additional State-to-State 

Compacts Could Enhance 

Regional CBRNE 

Coordination through 

Planning
 

Page 36 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.37

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 

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.

 

37 Army National Guard Regulation 500-4/Air National Guard Instruction 10-2504 (Oct. 16, 

2009). 
 

Page 37 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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. 38

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.

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.

 

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. 
 

Page 38 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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.39

 

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. 

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 outof-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 

A Command and 

Control Framework Is 

in Place, but Several 

Factors May Inhibit 

CERFPs’ Operational 

Effectiveness
 

Page 39 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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.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.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.42

 

40 Army National Guard Regulation 500-4/Air National Guard Instruction 10-2504 (Oct. 16, 

2009). 

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 

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. 

NGB Has Established a 

Command and Control 

Framework for CERFP 

Operations
 

Page 40 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.
 

Page 41 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 6: Command and Control Structure for State Active Duty and Title 32 CERFP 

Response Operations

a

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 

 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 
 

Page 42 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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 longrange communications capability for CERFPs and states that dedicated 

communications equipment is essential to establishing “technical reachback” capability for the CERFP.43

 

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. 

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 

Inadequate 

Communications 

Capabilities May Hamper 

the Command and Control 

of Operations Involving 

CERFPs
 

Page 43 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.
 

Page 44 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 7: Potential CERFP Incident Site Response Partners and Communications Pathways

To mitigate communications limitations, CERFPs may be able to access 

equipment with the aforementioned key capabilities from other state 
 

Page 45 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.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.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 

 

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. 
 

Page 46 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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.46

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.

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.

 

46NGB officials stated that they have subsequently realigned the Fatality, Search, and 

Recovery Teams geographically, reducing the number of CERFPs aligned with out-ofstate teams from 9 CERFPs to 2 CERFPs. 

Some CERFPs Do Not 

Have Agreements with 

Their Out-of-State 

Elements
 

Page 47 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 

Opportunities to Exercise 

and Evaluate Command 

and Control in a Realistic 

Response Environment 

Are Limited
 

Page 48 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 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 

The Introduction of New 

Homeland Response 

Forces Will Affect 

Command and Control of 

CBRNE Capabilities
 

Page 49 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

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 

Conclusions
 

Page 50 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 
 

Page 51 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

operations that could lead to reduced operational effectiveness and 

weaken the overall national response structure.

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

Recommendations for 

Executive Action
 

Page 52 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

• 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

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 

Agency Comments 

and Our Evaluation
 

Page 53 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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 

http://www.gao.gov. 
 

Page 54 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.

Janet A. St. Laurent

Managing Director

Defense Capabilities and Management
 

Page 55 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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
Appendix I: Scope and Methodology

Page 56 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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,

1 NGB’s 

CERFP Management regulation,

2 NGB’s CERFP training guidance,3 and 

the Army’s final draft of CERFP operations doctrine.4

 

1 National Guard Bureau. National Guard Chemical Biological, Radiological Nuclear and 

High Yield Explosive, Enhanced Response Force Package, Concept of Operations (July 

7, 2009). 

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 

2 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). 

3 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). 

4 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). 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 57 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.5

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.

In total, 51 surveys were sent 

via email invitation across 27 states (17 CERFP host states and 10 nonhost 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.

 

5 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. 
Appendix I: Scope and Methodology

Page 58 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.6

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.

Despite 

repeated inquiries, emergency management officials from Maryland, New 

Mexico, Texas, and Washington did not respond to the surveys.

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.7

 

6 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. 

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 

7 GAO, Military Readiness: Army and Marine Corps Reporting Provides Additional Data, 

but Actions Needed to Improve Consistency GAO-11-526 (Washington, D.C.: June 3, 

2011); Military Readiness: DOD Needs to Strengthen Management and Oversight of the 

Defense Readiness Reporting System GAO-09-518 (Washington, D.C.: Sep. 25, 2009); 

and Reserve Forces: Actions Needed to Identify National Guard Domestic Equipment 

Requirements and Readiness GAO-07-60 (Washington, D.C.: Jan. 26, 2007). 
Appendix I: Scope and Methodology

Page 59 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.
Appendix II: CERFP Interagency Training, 

2008-2010 

Page 60 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

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.1

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.

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.

 

1 This guidance did not articulate specific interagency training goals for fiscal year 2010.

Appendix II: CERFP Interagency Training, 

2008-2010 
Appendix II: CERFP Interagency Training, 

2008-2010 

Page 61 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 8: CERFP Joint Field Training with Select Potential Response Partners, 2008-2010
Appendix II: CERFP Interagency Training, 

2008-2010 

Page 62 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 9: CERFP Joint Field Training with Emergency Management Agencies from 

States with CERFPs, 2008-2010

Note: Numbers may not add to 100 percent due to rounding 

Figure 10: CERFP Joint Field Training with Emergency Management Agencies from 

States without CERFPs, 2008-2010

Note: Numbers may not add to 100 percent due to rounding. 
Appendix II: CERFP Interagency Training, 

2008-2010 

Page 63 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Figure 11: CERFP Joint Field Training with State National Guards from States 

without CERFPs, 2008-2010
Appendix III: Comments from the Department 

of Defense

Page 64 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Appendix III: Comments from the 

Department of Defense
Appendix III: Comments from the Department 

of Defense

Page 65 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 
Appendix III: Comments from the Department 

of Defense

Page 66 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 
Appendix III: Comments from the Department 

of Defense

Page 67 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 68 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Janet A. St. Laurent, (202) 512-4300 or stlaurentj@gao.gov. 

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.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact:

Acknowledgments: 
Related GAO Products

Page 69 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Homeland Defense: DOD Needs to Take Actions to Enhance Interagency 

Coordination for Its Homeland Defense and Civil Support Missions. 

GAO-10-364. Washington, D.C.: Mar 30, 2010

Homeland Defense: DOD Can Enhance Efforts to Identify Capabilities to 

Support Civil Authorities during Disasters. 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. 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. 

GAO-09-369. Washington, D.C.: April 30, 2009.

Emergency Management: Observations on DHS’ Preparedness for 

Catastrophic Disasters. 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. 

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. 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. GAO-08-251. Washington, D.C.: April 16, 2008.

Continuity of Operations: Selected Agencies Tested Various Capabilities 

during 2006 Governmentwide Exercise. 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. 

GAO-07-1241T. Washington, D.C.: September 27, 2007.

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Page 70 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Homeland Security: Observations on DHS and FEMA Efforts to Prepare 

for and Respond to Major and Catastrophic Disasters and Address

Related Recommendations and Legislation. 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. GAO-07-696. Washington, D.C.: June 20, 2007.

Homeland Security: Preparing for and Responding to Disasters. 

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. 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. 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. GAO-06-643. 

Washington, D.C.: May 15, 2006.

Hurricane Katrina: GAO’s Preliminary Observations Regarding 

Preparedness, Response, and Recovery. GAO-06-442T. Washington, 

D.C.: March 8, 2006.

Emergency Preparedness and Response: Some Issues and Challenges 

Associated with major Emergency Incidents. GAO-06-467T. Washington, 

D.C.: February 23, 2006.

GAO’S Preliminary Observations Regarding Preparedness and Response 

to Hurricanes Katrina and Rita. GAO-06-365R. Washington, D.C.: 

February 1, 2006.

Homeland Security: DHS’ Efforts to Enhance First Responders’ AllHazards Capabilities Continue to Evolve. GAO-05-652. Washington, 

D.C.: July 11, 2005.
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Page 71 GAO-12-114 Homeland Defense and Weapon of Mass Destruction 

Homeland Security: Process for Reporting Lessons Learned from Seaport 

Exercises Needs Further Attention. GAO-05-170. Washington, D.C.: 

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Homeland Security: Federal Leadership and Intergovernmental 

Cooperation Required to Achieve First Responder Interoperable 

Communications. 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. GAO-03-670. Washington, D.C.: July 11, 

2003.

Combating Terrorism: Selected Challenges and Related 

Recommendations. GAO-01-822. Washington, D.C.: September 20, 

2001.

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