GAO-12-494R Coast Guard Recovery Planning

United States Government Accountability Office

Washington, DC 20548

April 6, 2012

The Honorable John D. Rockefeller, IV

Chairman

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable John L. Mica

Chairman

Committee on Transportation and Infrastructure 

House of Representatives

The Honorable Frank A. LoBiondo

Chairman, Subcommittee on Coast Guard and Maritime Transportation

Committee on Transportation and Infrastructure 

House of Representatives

Subject: Maritime Security: Coast Guard Efforts to Address Port Recovery and Salvage 

Response

According to the Department of Homeland Security (DHS), ports, waterways, and vessels 

are part of an economic engine handling more than $700 billion in merchandise annually, 

and a major disruption to this system could have a widespread impact on global shipping, 

international trade, and the global economy. As the lead federal agency for the Marine 

Transportation System (MTS), the U.S. Coast Guard is responsible for facilitating the 

recovery of the MTS following a significant transportation disruption, such as a security 

incident or natural disaster, and working with maritime stakeholders for the expeditious 

resumption of trade.1 Area Maritime Security (AMS) Plans, which are developed by the 

Coast Guard with input from applicable governmental and private entities, serve as the 

primary means to identify and coordinate Coast Guard procedures related to prevention, 

protection, and security response, as well as facilitation of MTS recovery. In the aftermath of 

Hurricane Katrina, the Coast Guard conducted efforts to identify additional recovery-related 

elements and incorporate them within its AMS Plans to help ensure a consistent approach 

to MTS recovery and trade resumption. In addition, the Security and Accountability for Every 

Port Act of 2006 (SAFE Port Act) required that AMS Plans include a Salvage Response 

Plan to ensure that waterways are cleared and port commerce is reestablished as efficiently 

and quickly as possible following a transportation security incident (TSI), among other 

things.2

 

1 The MTS is a network of maritime operations interfacing with shoreside operations at intermodal connections 

and is part of global supply chains or domestic commercial operations. The various operations within the MTS 

network have components that include vessels; port facilities; waterways and waterway infrastructure; railroads; 

bridges; highways; tunnels; intermodal physical, cyber, and human connections; and users.

These additional recovery and salvage elements were to be included within the 

2 Pub. L. No. 109-347, § 101, 120 Stat. 1184, 1187-88 (2006) (codified at 46 U.S.C. § 70103(b)(2)(G)). A TSI is a 

security incident resulting in a significant loss of life, environmental damage, transportation system disruption, or 

economic disruption in a particular area. 46 U.S.C. § 70101(6).
Page 2 GAO-12-494R Coast Guard Recovery Planning

2009 updates of the AMS Plans. Further, the Coast Guard Authorization Act of 2010 called 

for AMS Plans to establish response and recovery protocols to prepare for, respond to, 

mitigate against, and recover from a TSI.

3 To facilitate these updates, the Coast Guard 

revised available planning guidance, which includes a template for use in developing 

applicable recovery and salvage response content.

Given the importance of ensuring that the Coast Guard has incorporated these recoveryrelated elements as directed, you asked us to determine the extent to which the Coast 

Guard has revised AMS plans to facilitate recovery of the MTS as called for by legislation 

and Coast Guard guidance. In addition, as discussed with your offices, we are also 

continuing to assess the extent to which federal entities are working with maritime 

stakeholders to enhance the resiliency of port-related infrastructure. We anticipate reporting 

the results of this work in the summer of 2012.

To address our audit objective for this report, we reviewed the seven Coast Guard AMS 

Plans for the DHS-designated Group I port areas—those determined to be the highest risk—

to assess whether they included provisions regarding recovery and salvage as required by 

law.4 Further, we compared the recovery and salvage sections of those plans with guidance 

and criteria issued by Coast Guard headquarters to determine the extent to which this 

guidance was reflected in the AMS Plans. We selected these locations because their status 

as Group I port areas heightens the likelihood of a TSI and importance of planning for 

recovery of the MTS after a transportation disruption.5 We also obtained additional 

information regarding the Coast Guard’s plan review and approval process to determine the 

extent to which all AMS plans were reported to include applicable recovery and salvage 

response components.6 To determine the key recovery-related elements for summarizing 

our plan review, we reviewed available Coast Guard planning guidance and applicable 

Commandant Instructions for discussion of principal recovery entities and operational 

processes.7

 

3 Pub. L No. 111-281, § 826, 124 Stat. 2905, 3004 (2010) (codified at 46 U.S.C. § 70103(b)(2)(E)). The plans are 

to be consistent with the National Maritime Transportation Security Plan and the protocols for the resumption of 

trade required by the SAFE Port Act.

Our characterization of these elements was further corroborated through 

interviews with Coast Guard headquarters officials. 

4 To promote a regional approach to port security, DHS aggregates individual ports into “port areas” for grant 

funding purposes. DHS determines the level of risk faced by U.S. port areas and then assigns those port areas 

to one of three groups based on that risk. There are seven Group I port areas in the United States—Delaware 

Bay (which includes Philadelphia, Pennsylvania; Trenton, New Jersey; Wilmington, Delaware; and other ports in 

the region); Houston-Galveston, Texas; Los Angeles-Long Beach, California; New Orleans, Louisiana (which 

includes Baton Rouge and other ports); New York, New York and New Jersey; Puget Sound (which includes 

Seattle, Olympia, Tacoma, and other ports in Washington); and San Francisco Bay, California (which also 

includes Oakland and other ports in California). 

5 The term ‘‘transportation disruption’’ indicates any significant delay, interruption, or stoppage in the flow of trade 

caused by a natural disaster, heightened threat level, an act of terrorism, as well as any TSI. 6 U.S.C § 901(16). 6 AMS Plans are developed for each of the 43 individual Captain of the Port zones—specific port areas 

geographically defined in 33 C.F.R. part 3. The Captain of the Port is the Coast Guard officer designated by the 

Coast Guard Commandant to enforce, within his or her respective area, port safety, security, and maritime 

environmental protection regulations, including, without limitation, regulations for the protection and security of 

vessels, harbors, and waterfront facilities. These port zones generally correspond to the 35 Coast Guard Sectors 

(field-based operational units responsible for executing the agency’s missions within their areas of responsibility). 

However, separate AMS plans have also been developed for six Marine Safety Units—which represent distinct 

areas (zones) within those sectors—as well as the Gulf of Mexico, and the Commonwealth of the Northern 

Mariana Islands.

7 Coast Guard, Commandant Instruction 16000.28, Recovery of the Marine Transportation System for 

Resumption of Commerce (Feb. 18, 2008); Navigation and Vessel Inspection Circular 09-02, Change 3, 

Guidelines for Development of Area Maritime Security Committees and Area Maritime Security Plans Required 

for U.S. Ports (Apr. 29, 2008); and Commandant Instruction 16601.28, Area Maritime Security Plan Development 
Page 3 GAO-12-494R Coast Guard Recovery Planning

We supplemented our plan review by conducting interviews with Coast Guard officials from 

each of the seven sectors responsible for the Group I port areas to discuss their process for 

developing and updating AMS Plans, as well as coordination of recovery planning with 

industry stakeholders. We also interviewed additional maritime stakeholders (e.g., port 

officials, vessel and facility operators, and marine exchanges) in two selected Group I ports 

to determine their roles in working with the Coast Guard to plan for recovery of the MTS 

following a transportation disruption. We selected these two ports, in part, because they 

represent varied coastal environments and waterways, a range of potential natural 

disasters, and are overseen by two different Coast Guard command entities. Though these 

stakeholders’ views do not represent all key maritime stakeholders in these or other ports, 

they provide valuable insights into collaborative port recovery efforts. 

We conducted this performance audit from August 2011 to April 2012 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.

Results in Brief

Each of the seven Coast Guard AMS Plans that we reviewed has incorporated key recovery 

and salvage response planning elements as called for by legislation and Coast Guard 

guidance. Using a template provided by Coast Guard headquarters to help guide AMS Plan 

development, each AMS Plan included an applicable section addressing procedures to 

facilitate recovery of the MTS following a TSI. While some variation exists regarding the 

level of detail provided and the inclusion of additional recovery-related appendices, each of 

the seven plans identified key recovery components and applicable operational processes 

as called for by Coast Guard guidance documents. These components include procedures 

for establishing a Marine Transportation System Recovery Unit (MTSRU) to work with 

stakeholders and provide guidance to the Incident Command;8 procedures for gathering and 

updating Essential Elements of Information (EEIs) to provide status updates on key port 

assets and operations; and identification of general recovery priorities to help guide decision

making. In addition, each AMS Plan also included a Salvage Response Plan to provide a 

coordination framework for salvage activities and identify available equipment and other 

resources that may be necessary to support the clearing of waterways to enable resumption 

of port commerce. Although our plan review was limited to seven high-risk port areas, the 

Coast Guard provided documentation indicating that all 43 AMS Plans have been approved 

as meeting all applicable content requirements, including recovery and salvage response 

elements. 

 

Process (Apr. 29, 2008). According to headquarters officials, the Coast Guard is in the process of updating policy 

directives and guidance to align with the evolution of national recovery and resiliency policy. These revisions are 

expected to be completed within the year; however, officials do not expect this policy alignment to necessitate 

significant changes in the MTS recovery regime at the field level.

8 The Incident Command System is a standardized, all-hazards, incident management approach used at all 

levels of government to help ensure a coordinated response among various jurisdictions and functional agencies, 

both public and private. The Coast Guard Captain of the Port would normally serve as the Incident Commander 

during a localized port incident within his/her area of responsibility. 
Page 4 GAO-12-494R Coast Guard Recovery Planning

Background

Much of today’s current port security framework was set in place by the Maritime 

Transportation Security Act (MTSA) of 2002.

Legal Framework

9 Among other requirements, MTSA directed 

the Coast Guard to develop Area Maritime Security Plans—to be updated every 5 years—

for ports throughout the nation.10 These plans are to, among other things, describe the area 

and infrastructure covered by the plan and how the plan is integrated with other area 

maritime security plans.11 MTSA also called for development of the National Maritime

Transportation Security Plan that included procedures for restoration of domestic cargo flow 

following a TSI.

The importance of recovery planning was reiterated in Homeland Security Presidential 

Directive-13, which called for the development of a National Strategy for Maritime Security to 

include a Maritime Infrastructure Recovery Plan (MIRP). In response to this directive, DHS 

released the MIRP—one of eight implementation plans designed to support the National 

Strategy for Maritime Security—in April 2006 to establish a comprehensive approach for 

recovery from a TSI.12 The MIRP contains recommendations for MTS recovery management 

and provides mechanisms for national, regional, and local decision makers to set priorities 

for redirecting commerce, a primary means of restoring domestic cargo flow. Among other 

things, the MIRP also provided guidance to inform the development of recovery aspects of 

Coast Guard AMS Plans. 

The nation’s port security framework was further refined through the enactment of the SAFE 

Port Act in October 2006.13 The SAFE Port Act created and codified certain port security 

programs and initiatives, and amended some of the original provisions of MTSA. In the area 

of Coast Guard port recovery planning efforts, the SAFE Port act required the development 

of protocols for resumption of trade following a TSI,14 as well as Salvage Response Plans to 

be developed and incorporated within AMS plans.15 These Salvage Response Plans are to 

identify salvage equipment capable of restoring operational trade capacity, and to ensure 

that waterways are cleared and the flow of commerce through U.S. ports is reestablished as 

efficiently and quickly as possible after a maritime TSI. The Coast Guard Authorization Act 

of 2010 further reinforced the need for recovery planning and required AMS Plans to 

establish response and recovery protocols to prepare for, respond to, mitigate against, and 

recover from a TSI.16 (See encl. I for a summary timeline of key legislative provisions and 

Coast Guard documents developed to address recovery of the MTS).

In response to legislative requirements and applicable DHS guidance, the Coast Guard—in 

partnership with maritime stakeholders—has prepared AMS Plans for each of its 43 

AMS Plans and Committees

 

9 Pub. L. No. 107-295, 116 Stat. 2064 (2002). 10 46 U.S.C. § 70103(b). 11 46 U.S.C. § 70103(b)(2)(B), (C). 12 The National Strategy for Maritime Security and its eight underlying plans were developed to meet the 

requirements set forth in HSPD-13 as well as the National Maritime Transportation Security Plan called for in 

MTSA. See 46 U.S.C. § 70103(a).

13 Pub. L. No. 109-347, 120 Stat. 1884 (2006). 14 6 U.S.C. § 942. 15 46 U.S.C. § 70103(b)(2)(G). 16 46 U.S.C. § 70103(b)(2)(E). The plans are to be consistent with the National Maritime Transportation Security 

Plan and the protocols for the resumption of trade required by the SAFE Port Act.
Page 5 GAO-12-494R Coast Guard Recovery Planning

designated Captain of the Port zones.17 Coast Guard guidance states that AMS Plans 

provide “coordinated security measures and procedures to deter and/or respond to TSIs and 

other security events.” They are also to serve as coordinating plans for joint deterrence 

within the AMS community and provide linkages to other emergency response plans. As of 

April 2008, AMS Plans are also to provide for facilitation of the recovery of the MTS from 

TSIs, and must include a salvage response component. To assist field staff in preparing and 

maintaining their individual AMS Plans, Coast Guard headquarters developed a plan 

template to promote standardization between plans and help ensure that required sections 

can be easily located. All AMS Plans are subject to review and approval through the Coast 

Guard chain of command, which includes verification of plan content requirements using a 

detailed checklist. Coast Guard guidance denotes that the template is intended to ensure 

that AMS Plans meet all MTSA and SAFE Port Act requirements. However, the guidance 

allows for individual plan variation and discretionary use of appendices to address the 

unique characteristics of each Captain of the Port zone, as well as the development of more 

specific information outside the scope of the AMS Plan. 

In addition to the AMS Plans, each Captain of the Port is responsible for establishing and 

maintaining an AMS Committee that is to advise on the development of these AMS Plans, 

among other responsibilities. AMS Committees are also tasked with planning and 

coordinating security procedures and providing subject matter expertise to the Captain of 

the Port, and are required to meet at least annually or when requested by a majority of 

members. Coast Guard guidance states that AMS Committees are to contain a number of 

different port stakeholders and governmental entities charged with regulation and 

enforcement of the MTS. A combination of federal (e.g., Coast Guard, Army Corps of 

Engineers, Customs and Border Protection), state, local, territorial, and tribal (e.g., law 

enforcement, transportation, and environmental agencies), as well as private sector entities 

(e.g., vessel agents, terminal operators, and marine exchanges) may be represented within 

each port’s AMS Committee. 

All Coast Guard AMS Plans Reviewed Include Elements to Address Recovery of the 

Marine Transportation System

Overall, each of the AMS Plans that we reviewed addresses recovery and salvage 

response, as required by law, and incorporates the specific recovery and salvage response 

elements, as described in Coast Guard planning guidance. These plan elements include 

discussion of the roles and responsibilities related to the establishment of the MTSRU in 

preparing for, responding to, and recovering from a TSI; gathering of EEIs from industry 

partners regarding the status of key maritime assets and operations, such as bridges and 

waterfront facilities; identification of recovery priorities; and plans for salvage of assets 

following a TSI. Although we limited the scope of our plan review to seven high-risk port 

areas, the Coast Guard provided documentation indicating that all 43 AMS Plans were 

updated to include applicable recovery and salvage response elements. 

Among the plans we reviewed, six of the seven plans incorporate recovery elements as a 

separate Recovery Annex, with varying levels of detail also incorporated into the main body 

of the AMS Plan. The remaining plan (New York/New Jersey) uses the recovery section of 

the AMS Plan as its main source of recovery information, with its Recovery Annex serving to 

 

17 Although the law requires AMS Plans to specifically address potential TSIs, officials at Coast Guard 

headquarters noted that the AMS plans are compatible with efforts to address all-hazards. 
Page 6 GAO-12-494R Coast Guard Recovery Planning

exclusively discuss gathering of the EEIs identified. See table 1 for a summary of key 

recovery elements addressed in selected AMS Plans. 

Table 1: Summary of Recovery Elements Contained Within Area Maritime Security (AMS) 

Plans for Selected Port Areas

Elements of recovery

Present in all 

AMS Plans? Additional/notable information provided

Marine Transportation System Recovery 

Unit (MTSRU) Information:

• Procedures for establishing unit

• Roles in information gathering and 

providing guidance to the Incident 

Command

• Communication with stakeholders

• Two plans provide particularly robust 

details regarding topics such as conducting 

post-incident assessments, identifying port 

area needs, and checklists for key items 

needed to support MTSRU functions.

• Two port areas leverage existing 

collaborative bodies to support MTSRU 

information-sharing functions during a TSI.

Procedures for gathering Essential 

Elements of Information (EEI):

• Discuss importance of developing 

pre-incident baseline data

• Obtaining and updating data during a 

TSI 

• Providing guidance for EEI 

development and/or references to 

other guidance

• Five plans provide a template or 

instructions for determining applicable EEIs 

to gather, in some cases providing details 

on specific EEIs within the port area.

• All plans provided guidance or references 

to external guidance to be used in EEI 

development. 

a

Recovery Priorities:

• General priorities for port area 

recovery

• Five plans include slight modifications to 

Coast Guard HQ-defined priorities to reflect 

unique conditions in their port areas.

Salvage Response Plans:

• Defining the roles and responsibilities 

of federal, state, and local partners

• Defining recovery-specific tasks to 

identify salvage response needs

• Identifying local marine salvage 

providers for use when needed

• Details were generally very consistent 

between individual plans.

• One plan outlines specific tasks for the 

senior salvage officer following a TSI.

Source: GAO analysis of selected Coast Guard AMS Plans. a Of the other two plans, one provides guidance on the roles and responsibilities of an EEI work group for 

developing and cataloging EEIs in their data system. The other plan states that EEIs are kept and maintained 

separately within the Coast Guard and made available when needed following an incident.

MTSRU Information

Each of the seven AMS Plans we reviewed discusses the role and importance of a MTSRU 

as suggested by Coast Guard guidance. A MTSRU is a collection of personnel—typically led 

by the Coast Guard and augmented by federal, state, local, and private maritime industry 

partners—established during a TSI to provide support to the Incident Command. Coast 

Guard guidance states that the complex nature of simultaneous response and MTS 

recovery actions following a TSI requires assistance from specially qualified Coast Guard 

and external personnel, hence the MTSRU concept. The MTSRU function is responsible for 

tracking and reporting on the status of the MTS, understanding critical recovery pathways, 

recommending courses of action, providing stakeholders with a venue for input to the local 

response organization, and providing the Incident Command with recommended priorities 

for MTS recovery.18

 

18 The MTSRU is activated within the planning section of the Incident Command System. 

AMS Plan guidance stresses the need to establish a MTSRU as quickly 
Page 7 GAO-12-494R Coast Guard Recovery Planning

as possible during a TSI. Coast Guard guidance recommends that AMS Plans address and 

contain procedures for the following items related to MTSRUs:

• establishing a MTSRU as soon as possible after a TSI;

• gathering information and providing recovery recommendations to the Incident 

Command; and

• addressing the importance of communication and coordination with key stakeholders 

(other governmental entities and industry partners) during a TSI.

Each of the seven AMS Plans addresses the procedures listed above. For example, all 

plans present information on the role of MTSRU participants in reaching out to port 

stakeholders to gather critical information on the status of port operations. The plans we 

reviewed incorporate these elements in varying degrees of detail. Two plans, for example, 

provided particularly robust details covering efforts such as conducting post-incident 

assessments and identifying port area needs, and contained checklists for items needed to 

support MTSRU functions. For example, the Recovery Annex to the Delaware Bay AMS 

Plan discusses the general roles of the MTSRU at a high level, such as MTSRU 

responsibilities in working with stakeholders to conduct a post-incident assessment, 

identifying post-incident needs related to national security, critical infrastructure and key 

resources, and the economy, as well as information needed to support a recovery 

assessment, among other elements. Additionally, the Delaware Bay Recovery Annex 

contains a separate appendix entitled “MTSRU Guidelines.” This document provides 

detailed information divided into the following topics:

• Major Accomplishments (key deliverables for which the MTSRU is responsible); 

• Responsibilities; 

• References; 

• Go-Kit Materials (suggested supplies/materials for the MTSRU to function for 24-48 

hours); 

• Composition of the MTSRU (suggested federal, state, local, and industry 

representation); 

• Interrelationships (how key participants of the MTSRU will need to interact with other 

partners, what they will need to obtain and share); and

• Sequence of Activities (helpful details, information on the types of reports/products 

that will need to be prepared, and information on demobilizing the MTSRU).

In practice, the specific roles and responsibilities of a MTSRU can vary by port area, as 

some port areas are able to leverage the information-sharing abilities of established 

collaborative bodies to support decision making. For instance, the Houston plan provides for 

establishing a MTSRU as more of a coordinating body of Coast Guard personnel that serve 

primarily to gather and disseminate information, such as EEIs, within the Coast Guard. The 

MTSRU, in this case, would work closely with a Port Coordination Team of industry 

stakeholders, while the Port Coordination Team acts as an advisory group to the Incident 

Command and “performs many of the functions normally associated with the MTSRU in 

other ports.” According to port security specialists in Sector Houston, the Port Coordination 

Team is a long-established unit that works together during transportation disruptions (such 

as hurricanes or port closures due to heavy fog) to provide recommendations for action to 

the Captain of the Port. Sector New Orleans has adopted a very similar approach. Sector 

New Orleans officials report that their Port Coordination Team has allowed the Coast Guard 

to form successful relationships with federal, state, local, and private industry port 

stakeholders. Officials from Coast Guard headquarters added that in response to a 
Page 8 GAO-12-494R Coast Guard Recovery Planning

transportation disruption, the concept of collaboration and information sharing with port 

stakeholders is of key importance, and using such established mechanisms for gathering 

and sharing information—in conjunction with the MTSRU’s role in information sharing—can 

be an effective approach. Industry partners that we spoke with in the New Orleans area 

confirmed that they have established a collaborative relationship with the Coast Guard 

Sector through the Port Coordination Team construct, as well as through AMS Committee 

meetings.

Essential Elements of Information (EEIs)

Each of the seven AMS Plans we reviewed contains information on the need to gather EEIs 

to inform recovery and restoration activities in accordance with Coast Guard guidance, in 

varying degrees of detail. AMS Plan guidance highlights the importance of gathering and 

disseminating EEIs. EEIs consist of quantitative and objective information used by the Coast 

Guard to complete status reports during a TSI. EEIs can include specific information about 

assets and waterways within a port area, such as the location of aids to navigation and 

bridges, waterway depths, and key products handled by waterfront facilities. The Coast 

Guard develops EEI baseline information to provide sectors and districts with pre-incident 

information on MTS critical infrastructure and interdependencies.19

• importance of developing pre-incident baseline data in preparation for a TSI;

Post-incident EEI 

reporting allows the Coast Guard to monitor the status of the MTS and provides information 

to better facilitate MTS recovery and commerce resumption. Coast Guard guidance stresses 

that the following items should be addressed in AMS Plans:

• obtaining and updating current EEI data to inform decision making during a TSI; and

• guidance for developing specific EEIs and/or references to other EEI-related 

guidance.

All plans contain details stemming from the guidance above, particularly regarding the role 

of the Coast Guard in gathering and updating EEI data, and/or references to other guidance 

available for preparing EEIs, while five of the plans include a template or instructions for EEI 

data gathering. The New York/New Jersey AMS Plan is one that contains many details in 

terms of EEI information; specifically, the plan includes a separate Recovery Annex that is 

focused on the gathering of EEIs. The annex discusses the MTSRU’s role in gathering EEIs, 

and provides instructions for completing the EEI templates. The plan then provides EEI 

templates and applicable instructions for completing them, including details in five EEI asset 

categories (waterways and navigation systems, port area-critical infrastructure, port areavessels, offshore energy, and monitoring systems).

In addition, the Delaware Bay Recovery Annex provides extensive EEI detail on assets in 

each of four categories (waterways and navigation systems; port area critical infrastructure; 

port area vessels; and monitoring systems). As an example, under Waterways and 

Navigation Systems: Aids to Navigation, the document provides baseline data on the 

number of these types of assets by geographic region throughout the area of responsibility. 

Then, for each of these assets, additional data are provided: name and location, position 

(longitude and latitude), characteristic, height, range, structure (description of appearance), 

and remarks. As another example, under Port Area Critical Infrastructure: Container Cargo 

Facilities, columns are provided for gathering information on facility name; waterway; 

 

19 Coast Guard districts are field-based commands that oversee sector operations. There are nine Coast Guard 

districts throughout the continental United States, Alaska, and Hawaii.
Page 9 GAO-12-494R Coast Guard Recovery Planning

location (latitude/longitude); average daily number of cargo containers off-loaded from 

vessels; average daily number of cargo containers loaded onto vessels; importance, 

criticality, or uniqueness of cargo; average number of daily vessel arrivals; and vessel/facility 

limitations. While this type of information can be helpful in ascertaining the condition of 

certain assets during a TSI, several Coast Guard Sector officials we spoke with identified 

limitations regarding the level of baseline data that can be developed. These limitations 

were attributed to the difficulty in gathering these data on an ongoing basis due to industry 

concerns over the sensitivity or proprietary nature of some data. For example, officials with 

Sector New Orleans stated that while industry partners are generally amenable to sharing 

such EEIs (e.g., backup capabilities in the event of a port shutdown) as a security incident 

unfolds, they have been hesitant to provide such information in advance. However, Coast 

Guard officials reiterated that they were not concerned about being unable to obtain data or 

industry being unwilling to provide data in conjunction with a TSI, given the cooperative 

information-sharing relationships established with industry partners. Port stakeholders that 

we interviewed in New Orleans, as well as Seattle, confirmed that the Coast Guard has 

worked to facilitate sharing of such critical information during a TSI.

Recovery Priorities

Each of the seven AMS Plans that we reviewed incorporates Coast Guard guidance on 

recovery priorities. AMS Plan guidance states that recovery of the MTS is to be coordinated 

between the Coast Guard Captain of the Port and other government and private entities. 

The guidance also provides general priorities for waterway/port area recovery, which are 

intended to be used as an initial planning guide and adjusted as needed for individual port 

areas, as follows:

1. major transportation routes needed for first response and emergency services 

including evacuation routes, tunnels, bridges, and key waterways;

2. main shipping channels critical for homeland security and homeland defense 

operations;

3. port areas and channels critical for military traffic or out-loads;

4. main shipping channels critical to major commercial operations;

5. other critical maritime infrastructure, operations, and structures critical to operation of 

the port/waterway identified by the AMS Assessment;

6. secondary bridges and tunnels;

7. secondary commercial waterways; and

8. public/recreational waterways.

Overall, each of the seven AMS Plans incorporates these priorities. Five of the plans 

adopted slight modifications of the priorities, as permitted in Coast Guard guidance. For 

example, one plan (New York/New Jersey) combines the second and third priorities from the 

guidance above and elevates them to the top priority, while also removing the fifth priority 

above. Coast Guard Sector officials stated that this change was made to reflect the unique 

characteristics and needs of the port area. Another plan (Houston-Galveston) merged the 

second and third priorities listed above and did not include the fifth. In addition, the 

Delaware Bay plan includes the eight priorities listed above and also added in a top priority 

that the Captain of the Port will support all federal, state, and local efforts to (1) eliminate 

immediate threats to life, public health, or safety; (2) eliminate immediate threats of 

significant damage to the MTS; and (3) ensure the economic recovery of the affected areas. 
Page 10 GAO-12-494R Coast Guard Recovery Planning

Each of the seven port areas we focused on have also supported the development of 

Portwide Risk Mitigation Plans—a requirement when applying for funding from FEMA’s Port 

Security Grant Program—that, in some cases, may facilitate the identification of recovery 

priorities within a port area.20 The primary goal of a Portwide Risk Mitigation Plan is to 

provide a mechanism to port stakeholders for considering an entire port system strategically 

as a whole, and to identify and execute a series of actions designed to effectively mitigate 

risks to the system’s maritime critical infrastructure.21 As one example, in April 2009, the 

AMS Committee in one port area issued a Strategic Risk Management / Mitigation and 

Trade Resumption / Resiliency Plan. This plan identified the key strategic functions provided 

by the port area’s maritime community, such as materials transportation and petroleum 

supply, among others. The plan also included an assessment of existing risk to those 

functions, ranked them by strategic priority, and identified initiatives intended to mitigate that 

risk.22 According to Coast Guard officials and port stakeholders, this process helped to 

inform the local maritime community of potential recovery priorities as well as risk mitigation 

opportunities. 

Salvage Response Plans

Each of the seven AMS Plans we reviewed contains a Salvage Response Plan as called for 

in the SAFE Port Act and the Coast Guard’s AMS Plan guidance. Specifically, the SAFE 

Port Act mandated that AMS Plans are to include salvage response plans to identify salvage 

equipment capable of restoring operational trade capacity and to ensure that the waterways 

are cleared and the flow of commerce through U.S. ports is reestablished as quickly and 

efficiently as possible after a maritime TSI.23 The Coast Guard developed guidance for its 

AMS Plans to ensure that these and other elements of salvage response are addressed. 

Overall, there is little variation among the Salvage Response Plans we reviewed, as they 

are all closely aligned with the Coast Guard guidance.

 

20 The Port Security Grant Program exists to provide funding to the nation’s highest risk port areas to support 

increased portwide risk management; to enhance domain awareness; to train and exercise; to expand port 

recovery and resiliency capabilities; and to further capabilities to prevent, detect, respond to, and recover from 

attacks involving improvised explosive devices and other nonconventional weapons. For more information on our 

recent review of DHS’s Port Security Grant Program, see GAO, Port Security Grant Program: Risk Model, Grant 

Management, and Effectiveness Measures Could Be Strengthened, GAO-12-47 (Washington, D.C.: Nov. 17, 

2011).

21 As such, the Portwide Risk Mitigation Plans can shed light on the overall resiliency—the ability to resist, 

absorb, recover from, or successfully adapt to adversity or a change in conditions—of the port areas in question. 22 Risk was determined using a standard risk-based decision-making model, with risk as a function of 

consequence, threat, and vulnerability. DHS defines consequence as the effect of an event, incident, or 

occurrence, reflecting the level, duration, and nature of the resulting loss; threat as a natural or man-made 

occurrence, individual, entity, or action that has or indicates the potential to harm life, information, operations, the 

environment, and/or property; and vulnerability as a physical feature or attribute that renders an entity open to 

exploitation or susceptible to a given hazard.

23 46 U.S.C. § 70103(b)(2)(G).
Page 11 GAO-12-494R Coast Guard Recovery Planning

The key stated objectives of the Salvage Response Plan in AMS Plan guidance are as 

follows:

1. To provide a coordinated salvage response framework to ensure that waterways are 

cleared and the ability of the MTS to support the resumption of the flow of commerce 

through U.S. ports is reestablished as efficiently and quickly as possible following a 

TSI or other transportation disruption.24

2. To identify locally available salvage equipment capable of supporting the restoration

of operational trade capacity within the MTS.

Some of key salvage response elements called for in AMS Plan guidance are:

• defining the roles and responsibilities of federal, state, and local partners;

• defining recovery-specific tasks to identify salvage response needs; and

• identifying local marine salvage providers for use when needed.

Overall, each of the seven AMS Plans reviewed has addressed the key provisions called for 

in Coast Guard guidance, as stated above. For example, each AMS Plan includes a 

separate Appendix to the Salvage Response Plan containing names and contact information 

for local salvage companies to be used. One Salvage Response Plan that we reviewed also 

contains additional detail outlining specific tasks for the Coast Guard senior salvage officer 

to perform in providing and obtaining information during a damage and impact assessment, 

to include:

• inventory of vessels and obstructions to be salvaged, 

• establishment of priorities for clearance, and

• determination of the general technique and type of equipment to be used.

Agency Comments

On March 29, 2012, DHS provided written comments on a draft version of this report, which 

are reproduced in full in enclosure II. DHS generally concurred with the findings contained in 

the report, noting the positive recognition of actions taken by the U.S. Coast Guard to 

facilitate recovery of the MTS. 

-------

We are sending copies of this report to the Secretary of Homeland Security, applicable 

congressional committees, and other interested parties. This report will also be available at 

no charge on GAO’s website at http://www.gao.gov. 

 

24 The U.S. Army Corps of Engineers holds the primary federal responsibility for maintaining the navigability of 

federal channels—such as ensuring removal of an obstruction creating a hazard to navigation—in domestic ports 

and waterways. In the event of threatened or actual pollution incidents in the coastal zone, this responsibility falls 

to the Coast Guard.
Page 12 GAO-12-494R Coast Guard Recovery Planning

If you or your staffs have any questions about this report, please contact me at (202) 512-

9610 or caldwells@gao.gov. Contact points for our Office of Congressional Relations and 

Public Affairs may be found on the last page of this report. John Mortin, Dawn Hoff, Ryan 

Lambert, Adam Couvillion, Jessica Orr, Tracey King, and Michele Fejfar made key 

contributions to this report.

Stephen L. Caldwell

Director, Homeland Security and Justice

Enclosures – 2
Page 13 GAO-12-494R Coast Guard Recovery Planning

Enclosure I: Summary of Key Legislative Provisions and Associated Actions Related 

to Recovery of the Marine Transportation System 

The following table represents a summary timeline and description of relevant provisions in 

key legislation (in bold) related to recovery of the Marine Transportation System (MTS) and 

salvage response following a transportation security incident (TSI). Also included are 

applicable presidential directives and associated documents developed by the Coast Guard 

to address these provisions and other recovery-related efforts. 

Table 2: Summary Timeline and Description of Relevant Provisions in Key Legislation, 

Presidential Directives, and Associated Agency Documents.

Regulation/ Document Description

Maritime Transportation Security Act of 

2002

(November, 2002)

Required the development of Area Maritime Security (AMS) 

Plans and a National Maritime Transportation Security Plan 

that includes a plan for ensuring that the flow of cargo 

through U.S. ports is reestablished as efficiently and quickly 

as possible after a TSI.

Homeland Security Presidential Directive13 

(HSPD-13)

a

(December, 2004)

HSPD-13 called for development of a National Strategy for 

Maritime Security, which include component plans such as a 

Maritime Infrastructure Recovery Plan.

Maritime Infrastructure Recovery Plan 

(MIRP) 

(April, 2006)

The MIRP contains procedures for MTS recovery 

management and provides mechanisms for national, 

regional, and local decision makers to set priorities for 

redirecting commerce, a primary means of restoring 

domestic cargo flow. Among other things, the MIRP also 

provided guidance to be used in development of recovery 

aspects of Coast Guard AMS Plans.

Security and Accountability for Every 

Port Act (SAFE Port Act)

(October, 2006)

Required that AMS Plans include a salvage response plan 

to ensure resumption of commerce flow after a TSI and 

identify salvage equipment for restoring operational 

capacity.

Coast Guard Strategy for Maritime Safety, 

Security, and Stewardship

b

(January, 2007)

Establishes six strategic priorities for the Coast Guard, 

including “Developing a national capacity for MTS recovery.” 

In developing this capacity the Coast Guard will, among 

other things:

• Develop recovery policies, plans, and procedures at 

the national, regional, and local levels.

Recovery of the Marine Transportation 

System for Resumption of Commerce--

Commandant Instruction 16000.28

(February, 2008) 

Provides guidance to facilitate recovery on the MTS

following a significant disruption and defines Coast Guard 

roles and responsibilities for MTS recovery. 

• Established Coast Guard organizational elements to 

address MTS recovery.

• Describes procedures for communications with MTS 

stakeholders and to help ensure coordination between 

the Coast Guard, federal agencies and private sector 

for MTS recovery and trade resumption.

• Implements the MIRP for the Coast Guard and 

provides integrated planning for MTS recovery.
Page 14 GAO-12-494R Coast Guard Recovery Planning

Customs and Border Protection 

(CBP)/Coast Guard Joint Protocols for the 

Expeditious Recovery of Trade

(February, 2008)

Developed to establish national-level processes by which 

the Coast Guard, CBP, and other federal agencies will:

• Provide a forum for joint intergovernmental and private 

sector dialogues to identify and act on important issues 

to facilitate rapid MTS recovery and resumption of 

commerce.

• Assist senior-level decision makers by providing a 

process to collect and disseminate information to 

understand the status of the national MTS and to 

facilitate joint decision making.

• Assist senior-level decision makers by providing 

recommendations for national-level priorities for 

recovery of the MTS and trade resumption, including 

cargo/vessel priorities.

Guidelines for Development of AMS 

Committees and AMS Plans Required for 

U.S. Ports, Navigation and Vessel 

Inspection Circular (NVIC) 09-02, Change 3.

(April, 2008)

Revised AMS Plan template to include recovery and salvage 

response sections which include, among other things, the 

role and importance of essential elements of information and 

the Marine Transportation System Recovery Unit in recovery 

planning.

Coast Guard Authorization Act of 2010

(October, 2010)

Required AMS Plans to establish response and recovery 

protocols to prepare for, respond to, mitigate against, and 

recover from a TSI. 

Source: GAO.

c

Notes:

a 46 U.S.C. § 70103.

b 46 U.S.C. § 70103(b)(2)(G).

c 46 U.S.C. § 70103(b)(2)(E).
Page 15 GAO-12-494R Coast Guard Recovery Planning

Enclosure II: Comments from the Department of Homeland Security

(440993)
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