Department of Homeland Security 

Office of Inspector General 

FEMA's Progress in All-Hazards Mitigation 
 

OIG-10-03 October 2009 
 

Office of Inspector General 

U.S. Department of Homeland Security

Washington, DC 20528 

 October 19, 2009 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the Federal Emergency Management Agency’s progress in leading 

the Nation’s efforts to mitigate the risks of natural disasters, acts of terrorism, and other 

manmade disasters, as mandated by the Post Katrina Emergency Management Reform 

Act of 2006. It is based on interviews with employees and officials of relevant agencies 

and institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust that this report will result in more effective, efficient, and economical operations. 

We express our appreciation to all of those who contributed to the preparation of this 

report. 

Richard L. Skinner 
 

Inspector General 
 

 


 


 

Table of Contents/Abbreviations 

Executive Summary.............................................................................................................1
 

Background..........................................................................................................................2 

Results of Audit ...................................................................................................................5 

DHS Efforts to Advance All-Hazards Mitigation............................................................5 

Recommendations..........................................................................................................13 

Management Comments and OIG Analysis ..................................................................14
 

Coordinating an All-Hazards Mitigation Strategy.........................................................16 

Recommendations..........................................................................................................20 

Management Comments and OIG Analysis ..................................................................21
 

Implementing an All-Hazards Mitigation Approach .....................................................22 

Recommendations..........................................................................................................28 

Management Comments and OIG Analysis ..................................................................29 

Appendixes 

Appendix A: Purpose, Scope, and Methodology..............................................................30 

Appendix B: Management Comments to the Draft Report ..............................................31 

Appendix C: FEMA Risk Management Series Publications ............................................36 

Appendix D: National Planning Scenarios outlined in the National Response 

Framework ..................................................................................................38 

Appendix E: Hazards Identified in Local Hazard Mitigation Plans for the State of 

California, October 2007.............................................................................39 

Appendix F: Major Contributors to this Report................................................................40 

Appendix G: Report Distribution......................................................................................41 

Abbreviations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 
 

OIG
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Federal Emergency Management Agency’s Mitigation 

Directorate has made progress promoting multi-hazard mitigation 

planning and publishing building design guidance for mitigating 

multi-hazard events. Other Department of Homeland Security 

components are advancing mitigation measures to reduce or 

eliminate risks to critical infrastructure and key resources 

throughout the Nation, but a coordinated risk-based, all-hazards 

mitigation strategy mandated by the Post Katrina Emergency 

Management Reform Act of 2006 has yet to be developed. 

The Mitigation Directorate is well positioned to coordinate an allhazards mitigation strategy because of its extensive network of 

mitigation partners and stakeholders at the federal, state, tribal, and 

local levels. However, its ability to advance structural mitigation 

projects beyond those that address natural hazards is limited 

because (1) the Robert T. Stafford Disaster Relief and Emergency 

Assistance Act does not require or incentivize state, tribal, and 

local jurisdictions to prepare and implement hazard mitigation 

plans that address technological or manmade hazards, although it 

requires mitigation plans for natural hazards as a condition of 

receiving federal mitigation assistance; and (2) the Federal 

Emergency Management Agency’s Mitigation Directorate has only 

one program, the National Dam Safety Program, to address a 

technological hazard proactively, and none solely dedicated to 

address manmade hazards proactively. 

We are offering seven recommendations to advance the 

development and implementation of a risk-based, all-hazards 

mitigation strategy, along with a matter for congressional 

consideration that, if enacted, would authorize FEMA’s Mitigation 

Directorate to fund mitigation projects that proactively address 

technological or manmade hazards and further incentivize state, 

tribal, and local governments to prepare a hazard mitigation plan 

that addresses all hazards inherent to their jurisdictions. 

FEMA’s Progress in All-Hazards Mitigation 

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Background 

The primary mission of the Federal Emergency Management 

Agency (FEMA) is to reduce the loss of life and property and to 

protect the Nation from all hazards by leading and supporting a 

risk-based, comprehensive emergency management system. 

Mitigation, considered the cornerstone of emergency management, 

attempts to prevent hazards from developing into disasters 

altogether or reduce the effects of disasters when they occur. The 

mitigation phase differs from the other phases of emergency 

management in that it focuses on long-term actions to reduce or 

eliminate risk from hazards and their effects. Figure 1 is a graphic 

representation of the four phases in emergency management. 

Figure 1. The Four Phases of Emergency Management 

Hazards typically fall into three broad categories: natural, 

technological, and manmade. Natural hazards are generally 

associated with weather and geological events, such as a flood, 

hurricane, tornado, or earthquake. Technological hazards refer to 

human activities such as dam and levee construction or the 

manufacture, transportation, storage, and use of hazardous 

materials. Manmade hazards are typically associated with a 

criminal or terrorist attack using weapons such as an explosive, 

biological, or chemical agent. However, natural disasters can also 

be compounded by manmade and technological hazards to the 

extent that disaster losses could be prevented through mitigation. 

For example, Hurricane Katrina was both a natural and 

technological disaster because it involved the development of 

urban areas in naturally hazardous areas below sea level, 

compensated only partially by the construction of levees. 

FEMA’s Progress in All-Hazards Mitigation 

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Principal federal statutes guiding disaster mitigation at the state 

and local levels are the National Flood Insurance Act of 1968 (42 

U.S.C. 4001 et seq.), the Robert T. Stafford Disaster Relief and 

Emergency Assistance Act of 1988 (Stafford Act) (P.L. 100-707), 

and the Disaster Mitigation Act of 2000 (P.L. 106-390). The 

National Flood Insurance Act established the National Flood 

Insurance Program, which encourages local governments to 

mitigate flood risks through local regulation and financial 

incentives. The Stafford Act is the basic disaster relief law of the 

country and authorizes disaster programs implemented by FEMA. 

The Disaster Mitigation Act is the most important federal hazard 

mitigation law because it requires local governments to prepare 

hazard mitigation as a precondition for receipt of federal hazard 

mitigation project funds. 

Mitigating a hazard can involve both structural and nonstructural 

measures. Structural mitigation measures are generally 

technology-based solutions such as building flood levees and 

designing new or retrofitting existing buildings to make them more 

resistant to hazards. Nonstructural mitigation includes policybased measures such as enacting land use ordinances that prohibit 

residential development in flood-prone areas or requiring hazard 

insurance for structures susceptible to hurricanes. 

A study conducted by the Multi-hazard Mitigation Council1

 of the 

National Institute of Building Sciences determined that each dollar 

spent on natural hazard mitigation saves society an average of 4 

dollars. It concluded that mitigation is most effective when carried 

out on a comprehensive, community-wide, long-term basis; and 

that implementing coordinated mitigation activities over time is the 

best way to ensure that communities will be physically, socially, 

and economically resilient to future hazard impacts. 

FEMA’s Mitigation Directorate, established in November 1993, 

leads the agency’s mitigation efforts and manages a range of 

programs designed to reduce future losses to homes, businesses, 

schools, public buildings, and critical facilities from natural 

disasters. It also provides building design guidance for mitigating 

multi-hazard events and promotes multi-hazard mitigation 

planning at the state and local levels. 

1 The purpose of the Multi-hazard Mitigation Council is to reduce the total costs associated with natural and other 

related hazards to buildings by fostering and promoting consistent and improved multi-hazard risk mitigation strategies, 

guidelines, practices, and related efforts. 

FEMA’s Progress in All-Hazards Mitigation 

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The Post Katrina Emergency Management Reform Act of 2006 

(P.L. 109-295), enacted to address shortcomings identified in the 

preparation for and response to Hurricane Katrina, enhanced 

FEMA’s authority and gave it primary responsibility for the four 

phases of comprehensive emergency management: preparedness, 

response, recovery, and mitigation. FEMA’s activities include: 

•	 Lead the Nation’s efforts to prepare for, protect against, 

respond to, recover from, and mitigate against the risk of 

natural disasters, acts of terrorism, and other manmade 

disasters, including catastrophic incidents; 

•	 Coordinate the implementation of a risk-based, all-hazards 

strategy that builds those common capabilities necessary to 

prepare for, protect against, respond to, recover from, or 

mitigate against natural disasters, acts of terrorism, and other 

manmade disasters; 

•	 Integrate the agency’s emergency preparedness, protection, 

response, recovery, and mitigation responsibilities to confront 

effectively the challenges of a natural disaster, act of terrorism, 

or other manmade disaster; 

•	 Build the unique capabilities necessary to prepare for, protect 

against, respond to, recover from, or mitigate against the risks 

of specific types of incidents that pose the greatest risk to the 

Nation; and, 

•	 Partner with state, local, and tribal governments and emergency 

response providers, with other federal agencies, with the 

private sector, and with nongovernmental organizations to 

build a national system of emergency management that can 

effectively and efficiently utilize the full measure of the 

Nation’s resources to respond to natural disasters, acts of 

terrorism, and other manmade disasters, including catastrophic 

incidents. 

FEMA’s Progress in All-Hazards Mitigation 

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Results of Audit 

DHS Efforts to Advance All-Hazards Mitigation 

FEMA’s Mitigation Directorate recently published guidance on 

implementing mitigation planning regulations that encourage the inclusion 

of technological and manmade hazards in state, tribal, and local mitigation 

plans. It also published a series of disaster publications called the Risk 

Management Series that promotes the adoption of measures that will reduce 

casualties and the physical damage to buildings and infrastructure from the 

impact of conventional bombs; chemical, biological, and radiological 

agents; earthquakes; floods; and high winds. Several other Department of 

Homeland Security (DHS) components are advancing mitigation measures 

as well to reduce or eliminate risks to assets primarily associated with the 18 

critical infrastructure and key resource sectors.2 Collaboration among DHS 

components that have a role in mitigation will facilitate the development 

and implementation of a risk-based, all-hazards mitigation strategy, and 

help identify resources within DHS that can be used to mitigate all hazards 

identified in state, tribal, and local mitigation plans. 

Multi-hazard Mitigation Planning 

In July 2008, FEMA’s Assistant Administrator for Mitigation 

issued Local Multi-Hazard Mitigation Planning Guidance, which 

became effective on October 1, 2008, for all local mitigation plans 

approved by FEMA.3 The purpose of the local mitigation plan is 

codified in FEMA regulations, 44 CFR 201.6: 

“The local mitigation plan is the representation of the 

jurisdiction’s commitment to reduce risks from natural hazards, 

serving as a guide for decision makers as they commit resources 

to reducing the effects of natural hazards. Local plans will also 

serve as the basis for the State to provide technical assistance 

and to prioritize project funding.” 

2

 The 18 critical infrastructure and key resource sectors are Agriculture and Food; Banking and Finance;
 

Chemical; Commercial Facilities; Communications; Critical Manufacturing; Dams; Defense Industrial 

Base; Emergency Services; Energy; Government Facilities; Healthcare and Public Health; Information
 

Technology; National Monuments and Icons; Nuclear Reactors; Materials and Waste; Postal and Shipping; 

Transportation Systems; and Water. 

3

 This guidance was one of three issued on the requirements of mitigation planning under Code of Federal
 

Regulations, Title 44, Part 201. Separate planning guidance was issued for state multi-hazard mitigation 

planning and tribal multi-hazard mitigation. 

FEMA’s Progress in All-Hazards Mitigation 

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It is important to note that although FEMA regulations and the 

local multi-hazard guidance focus on mitigation planning for 

natural hazards, FEMA supports jurisdictions that choose to 

consider technological and manmade hazards as part of a 

comprehensive mitigation strategy and developed guidance in 

2003 on how jurisdictions can integrate technological and 

manmade hazards into mitigation plans.4 FEMA also underscores 

in guidance that mitigation plans should identify and assess 

vulnerability of buildings, infrastructure, and critical facilities or 

structures located within an identified hazard area, including 

critical facilities essential to the health and welfare of the 

population such as hospitals and emergency operations centers; 

transportation systems such as airports, bridges, and tunnels; 

lifeline utility systems such as potable water, oil, natural gas, and 

electric lines; communication systems such as radio stations, 

repeater sites, and base stations; and hazardous material facilities 

that house explosives and toxins. 

According to FEMA regulations, the purpose of mitigation 

planning is for state, tribal, and local governments to identify the 

natural hazards that impact them, to identify actions and activities 

to reduce any losses from those hazards, and to establish a 

coordinated process to implement the plan, taking advantage of a 

wide range of resources.5 Hazard mitigation planning is the 

process of identifying risk and vulnerabilities to hazards, followed 

by a strategy that will reduce or prevent the effects of a hazard 

from developing into a disaster. The final product is a mitigation 

plan that provides the framework for implementing mitigation 

projects that can also attract federal mitigation assistance and 

grants to mitigate the hazard. The following process for hazard 

mitigation planning is the same for natural, technological, and 

manmade hazards: 

•	 Identify and organize resources (create a planning team with 

representatives from the public and private sectors, citizen 

groups, higher education institutions, and nonprofits); 

•	 Assess risk (identify hazards and assess losses); 

•	 Develop a mitigation plan (identify mitigation actions that will 

reduce the effects of the hazard and create a strategy to 

prioritize them); 

4 Integrating Manmade Hazards into Mitigation Planning (FEMA 386-7). 5

 Code of Federal Regulations, Title 44, Part 201, §201.1, Purpose. 

FEMA’s Progress in All-Hazards Mitigation 

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•	 Implement mitigation actions, evaluate results, and update the 

mitigation plan accordingly. 

FEMA reported in March 2009 that all 50 states, 6 territories, and 33 

tribal governments have approved mitigation plans, and 18,000 local 

jurisdictions have approved local mitigation plans, covering 

approximately 77% of the Nation’s population. Figure 2 illustrates 

the status of mitigation plans as of January 2009. 

Figure 2. Mitigation Plans 

FEMA Mitigation Directorate’s Risk Management Series 

FEMA’s Risk Management Series is a series of disaster 

publications developed to protect the Nation’s building inventory 

and its occupants. The objective of the series is to reduce physical 

damage to structural and nonstructural components of buildings 

and related infrastructure, and to reduce casualties from impact by 

FEMA’s Progress in All-Hazards Mitigation 

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conventional bombs; chemical, biological, and radiological agents; 

earthquakes; floods; and high winds. The intended audience 

includes architects and engineers, building owners, operators, and 

managers, as well as state and local government officials working 

in the building sciences community. Most of the mitigation 

measures in the series are discretionary or voluntary actions that 

individuals, businesses, and local governments can take to reduce 

loss of life and property caused by multiple hazards. A list of 

FEMA’s Risk Management Series publications is in appendix C. 

Nine publications from the Risk Management Series focus on 

manmade hazards. Several of the publications address multiple 

threats and hazards. For example, FEMA publication 426, 

Reference Manual to Mitigate Potential Terrorist Attacks Against 

Buildings, explains that seismic standards for building components 

are beneficial against the explosive blast of conventional bombs 

and that landscaping can be used to mitigate the effects of wildfires 

as well as improve detection of placed devices. FEMA 

publications 424, Design Guide for Improving School Safety in 

Earthquakes, Floods, and High Winds, and 577, Design Guide for 

Improving Hospital Safety in Earthquakes, Floods, and High 

Winds, highlight the pros and cons of designing new and 

retrofitting existing hospitals and schools to withstand earthquakes, 

floods, and high winds such as those from hurricanes. 

Collectively, the Risk Management Series provides insight on how 

to mitigate hazards associated with 10 of the 15 national planning 

scenarios. The national planning scenarios represent a minimum 

number of credible scenarios depicting the range of potential 

terrorist attacks and natural disasters and related impacts facing our 

Nation. They form a basis for coordinated federal planning, 

training, and exercises. The scenarios covered include: explosive 

attack, nuclear detonation, radiological attack, anthrax attack, 

blister agent, toxic industrial chemicals, nerve agent, chlorine tank 

explosion, earthquake, and hurricane. The five not covered are 

plague, food contamination, foreign animal disease, cyber attack, 

and pandemic influenza. Appendix D lists the eight key scenario 

sets and 15 national planning scenarios presented in the National 

Response Framework6

 in January 2008. 

6

 The National Response Framework is intended to present the guiding principles that enable all response 

partners to prepare for and provide a unified national response to disasters and emergencies, from the 

smallest incident to the largest catastrophe. 

FEMA’s Progress in All-Hazards Mitigation 

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New York City used FEMA’s Risk Management Series to 

facilitate the development of a hazard mitigation plan for the 

financial district when it was identified as a likely target for 

terrorism after the terrorist attacks in September 2001. The plan 

recognized that the real challenge for the financial district was not 

only providing security, but preserving a psychology of openness. 

Therefore, the mitigation strategy included both structural and 

nonstructural measures: (1) dispersing the necessary protection 

among streetscape elements such as specially designed perimeter 

barriers and controlling vehicle access by rotating road barriers and 

turntables; and (2) changing traffic patterns and rezoning the 

financial district to enhance public space and create well-used 

pedestrian plazas conducive to commerce. Figure 3 illustrates the 

mitigation measures undertaken in the financial district. 

Figure 3. Mitigation Measures in New York City’s Financial District 

FEMA and state mitigation officials told us they view the Risk 

Management Series as a valuable but underutilized all-hazards 

mitigation resource for two primary reasons: (1) attention to 

mitigating manmade hazards has waned since the terrorist attacks 

on September 11, 2001; and (2) there is no federal funding source 

to incentivize building designers, engineers, and architects to 

implement the proposed mitigation measures. They suggest that 

FEMA encourage the adoption of the Risk Management Series by 

providing direct technical assistance to state and local mitigation 

officials, in addition to identifying all federal funding sources that 

can be used to adopt the mitigation measures advocated in the 

publications. According to FEMA’s guidance on Integrating 

Manmade Hazards into Mitigation Planning, mitigating 

technological and manmade hazards will require creative funding 

strategies that incorporate a variety of nontraditional sources 

because little federal funding is earmarked for state and local use 

in mitigating manmade hazards. 

FEMA’s Progress in All-Hazards Mitigation 

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Other DHS Components Advancing All-Hazards Mitigation 

A number of other DHS components have a role in advancing 

hazard mitigation. FEMA’s Grant Programs Directorate 

administers the Buffer Zone Protection Program, which provides 

financial assistance to jurisdictions for mitigating threats and 

vulnerabilities to critical infrastructure. The National Preparedness 

Directorate uses the Citizen Corps program and the Emergency 

Management Institute7 to educate the public and emergency 

management professionals about mitigation. DHS’ Science and 

Technology Directorate researches and develops new technology 

to identify and mitigate vulnerabilities associated with the critical 

infrastructure and key resource sectors. DHS’ National Protection 

and Programs Directorate leads and coordinates a national program 

to reduce risks to the Nation’s critical infrastructure and key 

resource sectors. According to DHS’ Future Years Homeland 

Security Program – Fiscal Years 2009–2013, $3.45 billion and 528 

full-time equivalent employees have been dedicated to mitigation 

in FY 2009. 

FEMA’s Grant Programs Directorate administers 52 grant 

programs; of these, it is programmatically responsible for 19. The 

other 33 are programmatically managed by DHS components, such 

as the Buffer Zone Protection program managed by the National 

Protection and Programs Directorate. The Buffer Zone Protection 

program supports planning, equipment, training, and exercise 

requirements that help jurisdictions mitigate threats and 

vulnerabilities to critical infrastructure. The 19 programs 

administered and managed by the Grant Programs Directorate are 

generally oriented toward prevention, protection, response, and 

recovery. 

FEMA’s National Preparedness Directorate oversees the 

coordination and development of the capabilities and tools 

necessary to prepare for terrorist incidents and natural disasters. It 

provides strategy, policy, and planning guidance to build 

prevention, protection, response, and recovery capabilities among 

all levels of government. Two components within the directorate, 

the National Integration Center and the Community Preparedness 

Division, include mitigation as an objective. The National 

Integration Center is responsible for developing, managing, and 

7

 The Emergency Management Institute is the national focal point for the development and delivery of 

emergency management training to enhance the capabilities of federal, state, local, and tribal governments. 

FEMA’s Progress in All-Hazards Mitigation 

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coordinating homeland security training, education, exercise, and 

lessons learned programs to ensure that the Nation is prepared for 

all hazards. The Community Preparedness Division uses its 

Citizen Corps program to engage, educate, and train Americans on 

all-hazards emergency preparedness, planning, mitigation, 

response, and recovery. 

The National Preparedness Directorate is also responsible for 

managing and implementing the target capabilities list initiative, 

which contains 37 core capabilities jurisdictions need to be 

prepared for disasters. The purpose of the target capabilities list 

initiative is to establish a baseline to measure the Nation’s 

preparedness for all hazards, including the 15 national planning 

scenarios. Currently, the target capabilities list address four 

homeland security mission areas: prevention, protection, response, 

and recovery. FEMA anticipates a second phase will be released 

in the future that will include a hazard mitigation capability. A 

draft version of mitigation capabilities for the target capabilities 

list has been developed. It is important that mitigation be included 

because it is the only phase of emergency management that focuses 

on long-term actions for reducing or eliminating risk from hazards 

and their effects. 

The Science and Technology Directorate, DHS’ primary research 

and development arm, focuses on innovative ways to use advanced 

technology to support homeland security efforts. It is composed of 

six divisions, three of which have an explicit mitigation objective: 

the Explosives Division; the Human Factors Behavioral Sciences 

Division; and the Infrastructure and Geophysical Division. The 

Explosives Division develops the technical capabilities to detect, 

interdict, and lessen the impacts of non-nuclear explosives used in 

terrorist attacks against mass transit, civil aviation, and critical 

infrastructure. The Human Factors Behavioral Sciences Division 

applies the social and behavioral sciences to improve detection, 

analysis, and understanding of homeland security threats. The 

Infrastructure and Geophysical Division focuses on identifying and 

mitigating the vulnerabilities of the critical infrastructure and key 

assets essential to our society. 

The National Protection and Programs Directorate is responsible 

for advancing DHS’ risk reduction mission, and its Office of 

Infrastructure Protection is responsible for leading and 

coordinating a national program to reduce risks to the Nation’s 

critical infrastructure and key resources posed by acts of terrorism, 

FEMA’s Progress in All-Hazards Mitigation 

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and to strengthen national preparedness, timely response, and rapid 

recovery in the event of an attack, natural disaster, or other 

emergency. According to the National Infrastructure Protection 

Plan,8

 a sector-specific federal agency is to lead a collaborative 

process for infrastructure protection for each of the 18 critical 

infrastructure and key resource sectors. Within these 18 sectors, 

DHS has designated more than 2,000 Tier I and Tier II critical 

infrastructure/key resource assets. Tier I assets or systems are those 

that if attacked could trigger major national or regional impacts 

similar to those experienced during Hurricane Katrina. Tier II 

assets are other highly consequential assets with potential national 

or regional impacts if attacked.9 

FEMA and other DHS component staff told us that developing and 

implementing a risk-based, all-hazards mitigation strategy could be 

facilitated through a more collaborative working relationship 

among all DHS components and other federal agencies that have a 

role in hazard mitigation. They explained that FEMA has done a 

good job integrating an all-hazards approach to disaster 

preparedness, but integrating an all-hazards approach to hazard 

mitigation has been a challenge because FEMA’s Mitigation 

Directorate has traditionally focused on mitigating natural hazards, 

while other DHS components focus primarily on mitigating risk 

and vulnerabilities associated with terrorism. Because the 

expertise of personnel working in DHS components involved with 

mitigation is also often specific to either natural hazard mitigation 

or infrastructure protection from terrorism; it has been difficult for 

management and staff to embrace an all-hazards approach to 

mitigation. 

8

 The National Infrastructure Protection Plan provides the unifying structure for the integration of a wide 

range of efforts for the enhanced protection and resiliency of the Nation’s critical infrastructure and key 

resources into a single national program.

9

 Government Accountability Office testimony, DHS Improved its Risk-Based Grant Programs’ Allocation 

and Management Methods, But Measuring Programs’ Impact on National Capabilities Remains a 

Challenge (GAO-08-488T), March 11, 2008. 

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Conclusion 

State and local mitigation officials say they would benefit from 

FEMA technical assistance and enhanced training on how to fund 

and implement mitigation measures proposed in the publications. 

Mitigation needs to be included in the target capabilities list to 

ensure consideration of long-term measures that reduce or 

eliminate hazard risk for all hazards. FEMA’s Mitigation 

Directorate has developed guidance that promotes mitigation 

measures to reduce the risk and effect of natural, technological, 

and manmade hazards. Other DHS components are advancing 

mitigation measures that protect our Nation’s critical infrastructure 

and key resources. However, collaboration among all DHS 

components with a mitigation role is important for three primary 

reasons: (1) to further the development and implementation of a 

risk-based, all-hazards mitigation strategy; (2) to identify resources 

and expertise that can be used to mitigate all-hazards identified in 

state, tribal, and local mitigation plans; and (3) to ensure that the 

$3.45 billion in DHS funds dedicated to mitigation in FY 2009 and 

in the future are used efficiently and effectively. 

Recommendations 

We recommend that the Assistant Administrator, Mitigation 

Directorate: 

Recommendation #1: Dedicate resources to provide technical 

assistance and training to state, tribal, and local mitigation officials 

about the Risk Management Series to further promote mitigation 

measures that reduce or eliminate loss of life and property. 

Recommendation #2: Update FEMA 386-7, Integrating 

Manmade Hazards into Mitigation Planning, to include all federal 

funding sources that can be used to implement mitigation measures 

that address technological and manmade hazards. 

Recommendation #3: Include mitigation in the next phase of the 

target capabilities list to ascertain whether communities are 

considering what capabilities are needed to implement long-term 

measures for reducing or eliminating risk from hazards and their 

effects. 

FEMA’s Progress in All-Hazards Mitigation 

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Recommendation #4: Establish and coordinate a formal network 

of representatives from the Grant Programs Directorate, the 

National Preparedness Directorate, the Science and Technology 

Directorate, the National Protection and Programs Directorate, and 

other federal agencies involved in hazard mitigation to identify 

opportunities, resources, and expertise that can be leveraged to 

implement mitigation projects that address all hazards identified by 

state and local governments. 

Management Comments and OIG Analysis 

Recommendation #1: The Office of Policy and Program Analysis 

generally concurred with this recommendation and will ensure that 

the Risk Management Series is promoted through technical 

assistance and training to state, tribal, and local mitigation 

officials. We consider this recommendation resolved because 

initial steps are being taken to implement it; however, it will 

remain open until FEMA provides evidence that it has been fully 

implemented. 

Recommendation #2: The Office of Policy and Program Analysis 

did not concur with our recommendation to update FEMA 386-7 to 

include all federal funding sources that can be used to implement 

technological and manmade mitigation measures for two primary 

reasons: (1) many resources to implement mitigation measures 

that address technological and manmade hazards are outside of 

FEMA; and (2) it would not be appropriate given the purpose of 

this planning document. 

The Office of Policy and Program Analysis explained in their 

response to our draft report that mitigation planning is focused on 

encouraging communities to make and enforce better land use 

planning decisions to ensure that future development is at less risk 

from hazards. Furthermore, FEMA’s primary audience is land use 

planners, floodplain managers, and building code officials. Actual 

implementation of identified mitigation measures goes beyond the 

scope and purpose of the planning effort. FEMA does emphasize 

that communities should not limit mitigation strategies to those 

eligible for particular federal programs, but should have 

comprehensive planning appropriate to its risks. For a community 

interested in federal funding, sources of funding mitigation 

measures that address technological and manmade hazards can be 

found in the Catalog of Federal Domestic Assistance. 

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We fully recognize the importance of comprehensive mitigation 

planning, but a mitigation plan that has not been implemented is of 

little use when a disaster strikes. According to the Post Katrina 

Emergency Management Reform Act of 2006, FEMA is to “lead 

the Nation’s efforts to prepare for, protect against, respond to, 

recover from, and mitigate against the risk of natural disasters, acts 

of terrorism, and other man-made disasters.” Providing a list of 

federal resources that can be used to implement technological and 

manmade mitigation measures in FEMA’s guidance on Integrating 

Man-Made Hazards into Mitigation Planning would demonstrate 

leadership and help state, tribal and local mitigation professionals 

plan for and implement measures that support FEMA’s mission of 

protecting the Nation from all hazards. This is particularly 

relevant since FEMA’s Office of Policy and Program Analysis 

acknowledges that there are programs within FEMA and DHS to 

address such hazards. We consider this recommendation 

unresolved and open. 

Recommendation #3: The Office of Policy and Program Analysis 

concurred with this recommendation and FEMA will include 

mitigation in the target capabilities list. We consider this 

recommendation resolved because steps are being taken to 

implement it; however, it will remain open until FEMA provides 

evidence that it has been fully implemented. 

Recommendation #4: The Office of Policy and Program Analysis 

concurred with this recommendation and FEMA will establish and 

coordinate a formal network of representative within DHS and 

other federal agencies to identify opportunities, resources, and 

expertise that can be leveraged to implement mitigation projects 

that address all hazards. We believe the FEMA Mitigation 

Directorate is well positioned to lead this collaborative effort 

because of its extensive network of mitigation partners and its 

focus on long-term solutions to address hazards. We consider this 

recommendation resolved because steps are being taken to 

implement it; however, it will remain open until FEMA provides 

evidence that it has been fully implemented. 

FEMA’s Progress in All-Hazards Mitigation 

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Coordinating an All-Hazards Mitigation Strategy 

FEMA’s Mitigation Directorate is well positioned to coordinate a riskbased, all-hazards mitigation strategy because of its extensive network of 

mitigation partners and its focus on long-term solutions to address 

hazards. To develop this strategy, input from state, tribal, and local 

governments about all risks and vulnerabilities inherent to their 

jurisdictions is essential. Mitigation plans for state, tribal, and local 

governments are not statutorily required for technological or manmade 

hazards. However, FEMA-approved mitigation plans for natural hazards 

are statutorily required and incentivized by linking federal mitigation 

assistance to the plans. Thus, most mitigation plans focus on natural 

hazards to satisfy statutory requirements and to qualify for disaster 

assistance and hazard mitigation grants. 

FEMA’s Network of Mitigation Partners 

FEMA’s Mitigation Directorate has developed an extensive 

network of mitigation partners, including federal, state, local, and 

tribal governments, the private sector, professional associations, 

nongovernmental groups involved in public policy and 

administration, the insurance industry, higher education, the 

building sciences community, and urban planning practitioners. It 

has more than 200 full-time employees at its headquarters in 

Washington, DC, and approximately 40 employees in 10 regional 

offices who support its mitigation mission. FEMA regional office 

mitigation personnel, along with contractors, provide the bulk of 

direct technical assistance and planning guidance to jurisdictions 

that plan and implement hazard mitigation projects. 

The Mitigation Directorate collaborates with numerous federal 

agencies to implement both the National Hurricane program10 and 

the National Earthquake Hazard Reduction program.11 The 

National Hurricane program, which supports communities and 

residents at risk from hurricane hazards through various projects, 

received $5.86 million in funding for FY 2008. The National 

Earthquake Hazard Reduction program aims to reduce the risks to 

10 The National Hurricane program is a multi-agency partnership involving FEMA, the National Oceanic 

and Atmospheric Administration, the National Weather Service, the U.S. Department of Transportation, 

and the U.S. Army Corps of Engineers. 11 The National Earthquake Hazard Reduction program is a collaborative effort among FEMA, the National 

Institute of Standards and Technology, the National Science Foundation, and the United States Geological 

Survey. 

FEMA’s Progress in All-Hazards Mitigation 

Page 16 
 

 

 

 


 

life and property from future earthquakes. It received $121.5 

million in funding for FY 2008. 

State and tribal hazard mitigation officials play a critical role in 

advancing FEMA’s mitigation efforts, and their positions are often 

funded in part by FEMA’s emergency management performance 

grant program. These officials are primarily responsible for 

administering federal mitigation grants programs, and coordinating 

mitigation and planning activities with their local counterparts to 

prepare mitigation grant applications that are submitted to FEMA 

regional office staff for review and approval. Local hazard 

mitigation officials are responsible for identifying local hazards, 

assessing risks, and implementing mitigation projects. They are 

also responsible for making the public aware of hazards; adopting, 

administering, and enforcing land use regulations; conducting 

mitigation project inspections; and ensuring compliance with 

hazard mitigation laws. 

FEMA’s Mitigation Directorate relies on the private sector to 

underwrite and administer flood insurance policies that are backed 

by the National Flood Insurance Fund. Private sector contractors 

also provide local hazard mitigation officials technical expertise 

and management support to plan and implement mitigation 

projects. A Midwest state mitigation official told us that 

approximately 40% of the jurisdictions in her state relied on 

private sector contractors for mitigation planning, preparing 

mitigation grant applications, and implementing mitigation 

projects. 

FEMA’s Mitigation Directorate interacts with professional 

associations such as the National Emergency Management 

Association12 to solicit ideas that help advance its mitigation 

mission. The association develops policy white papers and 

recommendations for FEMA and other government and private 

sector decision makers. A recent white paper underscored the 

importance of developing a national all-hazards mitigation strategy 

to counter social, political, and economic realities that drive public 

choice away from mitigation investments. The white paper noted 

that a national mitigation strategy should be based on several 

strategic themes: broader, collaborative partnerships; total hazard 

12 The National Emergency Management Association is composed of emergency management directors 

from all 50 states, 8 territories, and the District of Columbia. The primary purpose of the association is to 

provide support and expertise for emergency management professionals at all levels of government and the 

private sector. 

FEMA’s Progress in All-Hazards Mitigation 

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awareness at the community level; and a pull approach to 

mitigation initiated by communities rather than a federally driven 

push-down approach. It recommended five steps for developing 

and institutionalizing a national mitigation strategy: (1) form a 

national mitigation collaborative consortium; (2) foster innovative 

grassroots participation; (3) build a national mitigation knowledge 

repository; (4) connect mitigation to other programs; and (5) focus 

policies on incentives rather than disincentives to participate. 

Educational institutions through DHS’ Homeland Security Centers 

of Excellence support FEMA’s mitigation efforts by conducting 

research and development on a wide range of mitigation-related 

topics such as biological risk assessment, terrorism 

countermeasures, decontamination procedures, and port security. 

The Homeland Security Centers of Excellence are authorized by 

Congress and chosen through a competitive process. Each center 

is led by a university in collaboration with partners from other 

institutions, agencies, laboratories, think tanks, and the private 

sector. 

FEMA’s Mitigation Directorate also works with the building 

sciences community and nongovernmental organizations such as 

the National Institute of Building Sciences, which brings together 

representatives of government, industry, labor, and consumer 

interests to serve as an authoritative source on building safety and 

technologies that mitigate natural, manmade, and technological 

hazards. For example, the National Institute of Building Sciences 

works on developing barrier technologies, sustainable building 

materials, and blast guard window film. 

Advancing an All-Hazards Strategy and Local Planning 

State, tribal, and local mitigation officials are the frontline 

implementers of hazard mitigation projects and are most familiar 

with the risks and vulnerabilities inherent to their jurisdictions. To 

develop a national risk-based, all-hazards mitigation strategy that 

builds capabilities to mitigate natural, technological, and manmade 

hazards, FEMA will need input from the frontline implementers. 

Garnering this input, however, will be challenging without further 

incentivizing the inclusion of all hazards confronting the 

jurisdiction into a local hazard mitigation plan. 

The Stafford Act and the Disaster Mitigation Act require state, 

tribal, and local mitigation plans for natural hazards, and 

FEMA’s Progress in All-Hazards Mitigation 

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incentivize the development of these plans through the offer of 

federal mitigation grants. The Disaster Mitigation Act, which 

amended the Stafford Act to require local governments to prepare 

natural hazard mitigation plans as a condition of receiving federal 

mitigation grants,13 was enacted to address the growing volume 

and severity of preventable, repetitive losses from natural disasters 

in the 1990s aggravated by poorly planned local development. 

Major disasters such as the 1993 floods along the Missouri and 

Mississippi Rivers, the Northridge Earthquake of 1994, and the 

increase in wilderness-urban interface fires convinced Congress of 

the need for natural hazard mitigation planning. 

The enactment of the Disaster Mitigation Act combined with the 

Stafford Act represents a trend in the past decade toward a more 

systematic approach to natural hazard mitigation planning and 

implementation at all levels of government. However, developing 

state, tribal, and local mitigation plans that address all hazards 

inherent to their jurisdictions remains a challenge. Many state and 

local hazard mitigation officials told us that despite FEMA’s 

encouragement, all-hazards mitigation planning has not been 

widely adopted for four primary reasons: (1) All-hazards 

mitigation planning that includes technological and manmade 

hazards is not statutorily required; (2) local jurisdictions often rely 

on contractors to develop mitigation plans, and the scope of the 

contracts is limited to hazards that qualify for federal grant 

assistance; (3) natural hazard mitigation planning and projects 

demand much of their attention and are frequently a state priority; 

and (4) demonstrating cost-effectiveness for mitigating manmade 

and technological hazards is too complex and time-consuming. 

It is important to note that while all-hazards mitigation planning 

has not been widely adopted, some states and local governments 

have included technological and manmade hazards in their plans. 

California’s mitigation plan, developed in 2007, is a good example 

of a comprehensive plan. It represents a culmination of input from 

local hazard mitigation plans that identifies 57 natural, 

technological, and manmade hazards. California mitigation 

officials told us they prepared a comprehensive plan beyond what 

is required to obtain FEMA mitigation grants to demonstrate the 

state’s commitment to reduce or eliminate the impact of disasters, 

regardless of cause. For example, the plan identifies specific 

mitigation actions to address hazards associated with climate 

13 The Stafford Act already required state hazard mitigation plans. 

FEMA’s Progress in All-Hazards Mitigation 

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change, such as regulating emissions and adopting mandatory 

reporting rules for significant sources of greenhouse gases. 

Projected impacts of climate change include more severe storms 

and flooding, food and water shortages, increases in the range of 

insect pests and diseases presently found in tropical areas, and 

desertification of presently temperate regions.14 Appendix E lists 

the hazards identified in local hazard mitigation plans for 

California. 

Conclusion 

FEMA’s Mitigation Directorate has an extensive network of 

mitigation partners, and because it focuses on long-term solutions 

to address hazards, it is well positioned to coordinate a risk-based, 

all-hazards mitigation strategy. Input from state, tribal, and local 

mitigation officials who know the risks and vulnerabilities inherent 

to their jurisdictions is essential to develop and implement an 

effective strategy. However, most mitigation plans focus on 

natural hazards to meet statutory requirements and to qualify for 

disaster assistance and hazard mitigation grants. Local 

jurisdictions are not statutorily required to have mitigation plans 

that address technological and manmade hazards, but they are 

required to have them for natural hazards and as a condition of 

receiving federal mitigation grants. A similar incentive for 

jurisdictions to prepare mitigation plans for all applicable hazards 

would facilitate the development of a risk-based, all-hazards 

mitigation strategy. 

Recommendations 

We recommend that the Assistant Administrator, Mitigation 

Directorate: 

Recommendation #5: Use the established network of mitigation 

partners along with enhanced collaboration with DHS components, 

other federal agencies, and private sector stakeholders to develop 

and implement a risk-based, all-hazards mitigation strategy that 

identifies all hazards inherent to local jurisdictions and establishes 

a national framework to mitigate these hazards using structural and 

nonstructural measures. 

14 Intergovernmental Panel on Climate Change, Climate Change 2007: Impacts of Climate Change – 

Impacts, Adaptation and Vulnerability – Summary for Policymakers, Working Group II Report, April 2007. 

FEMA’s Progress in All-Hazards Mitigation 

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Matter for Congressional Consideration: Authorize FEMA’s 

Mitigation Directorate to fund mitigation projects that directly 

address technological or manmade hazards and further incentivize 

state, tribal, and local governments to identify and prepare a hazard 

mitigation plan that addresses all-hazards inherent to their 

jurisdictions. 

Management Comments and OIG Analysis 

Recommendation #5: The Office of Policy and Program Analysis 

concurred with this recommendation and FEMA will develop and 

implement a risk-based, all hazards mitigation strategy. The full 

implementation of this recommendation is vital and mandated in 

section 503 of the Post Katrina Emergency Management Reform 

Act of 2006: “(b) ALL-HAZARDS APPROACH.—In carrying 

out the responsibilities under this section, the Administrator shall 

coordinate the implementation of a risk-based, all-hazards strategy 

that builds those common capabilities necessary to prepare for, 

protect against, respond to, recover from, or mitigate against 

natural disasters, acts of terrorism, and other man-made disasters, 

while also building the unique capabilities necessary to prepare for, 

protect against, respond to, recover from, or mitigate against the 

risks of specific types of incidents that pose the greatest risk to the 

Nation.’’ We consider this recommendation resolved because 

steps are being taken to implement it; however, it will remain open 

until FEMA provides evidence that it has been fully implemented. 

FEMA’s Progress in All-Hazards Mitigation 

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Implementing an All-Hazards Mitigation Approach 

FEMA’s Mitigation Directorate has 13 statutorily authorized programs, 

including 5 mitigation grant programs that all focus on natural hazards. It 

has one program, the National Dam Safety program, that proactively 

addresses a technological hazard, and none solely dedicated to address 

manmade hazards identified in its Risk Management Series or in state, 

tribal, and local mitigation plans. Natural disasters historically represent 

the greatest loss of life and property, but local mitigation measures that 

address technological and manmade hazards are important to further 

reduce our Nation’s risk and vulnerability. 

Statutorily Authorized Programs Focus on Natural Hazards 

FEMA’s Mitigation Directorate has five hazard mitigation grant 

programs that focus primarily on natural hazards: 

1. Hazard Mitigation Grant program 

2. Pre-disaster Mitigation program 

3. Flood Mitigation Assistance program 

4. Severe Repetitive Loss program 

5. Repetitive Flood Claims program 

The Flood Mitigation Assistance program, the Severe Repetitive 

Loss program, and the Repetitive Flood Claims program focus 

solely on flooding. The Hazard Mitigation Grant and Pre-disaster 

Mitigation programs can be used only under certain circumstances 

to help state, tribal, and local mitigation officials implement 

projects that address technological and manmade hazards. 

The Hazard Mitigation Grant program, authorized under Section 

404 of the Stafford Act, was created to reduce the loss of life and 

property caused by natural disasters and is employed only after a 

major Presidential disaster declaration. This program can be used 

to address natural, technological, and manmade hazards following 

a disaster that the President believes has caused damage of such 

severity that it is beyond the combined capabilities of state and 

local governments to respond. For example, the President’s 

disaster declaration for the State of New York following the 

September 11, 2001, terrorist attacks on the World Trade Center 

authorized the use of the Hazard Mitigation Grant program to aid 

New York City’s recovery. 

FEMA’s Progress in All-Hazards Mitigation 

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The Pre-disaster Mitigation program, in contrast, is intended to 

fund mitigation planning and projects before a disaster. However, 

FEMA FY 2009 guidance for the Pre-disaster Mitigation program 

stipulates that projects that solely address a manmade hazard are 

ineligible. Yet, it points out that although Pre-disaster Mitigation 

funds must be used primarily to support projects that address 

natural hazards, projects and plans also may address hazards 

caused by manmade events. The guidance, however, does not 

demonstrate how program funds can be used to primarily address 

natural hazards in addition to hazards caused by manmade events. 

Specific examples of how this can be accomplished would help 

mitigation officials prepare grant applications that address 

manmade hazards. 

State mitigation officials told us they are reluctant to include 

manmade or technological hazards in their applications for the Predisaster Mitigation program because it is a competitive program, 

and it is difficult to perform the required cost-benefit analysis for 

these hazards. According to FEMA’s Hazard Mitigation Grant 

program guidance, “Project subapplications that propose ineligible 

activities will be removed from consideration. FEMA will not 

separate eligible activities from ineligible project subapplications 

for funding consideration.” Mitigation officials also said that the 

amount of funding available from the Pre-disaster Mitigation 

program is limited and often earmarked by Congress for specific 

projects. The Pre-disaster Mitigation program was appropriated 

$114 million in FY 2008 and $90 million in 2009, and earmarks 

accounted for a total of 37.4% of these funds. 

The Office of Management and Budget recommends and FEMA 

requires a benefit-cost analysis for most FEMA mitigation grant 

programs to promote the efficient allocation of federal dollars.15 

The objective of the benefit-cost analysis is to compare the net 

present value of project benefits with project costs, and express 

this comparison in a ratio of annualized benefits over costs. 

FEMA requires a positive benefit-cost ratio (i.e., the measurable 

benefits are greater than the measurable costs) before it approves a 

mitigation grant application. The benefit-cost analysis, however, is 

not required for homeland security grants. Instead, FEMA’s Grant 

Programs Directorate uses a risk-based methodology that is driven 

90% by risk and 10% by the effectiveness demonstrated in the 

application. State mitigation officials told us that it is difficult to 

15 Office of Management and Budget, Circular A-94. 

FEMA’s Progress in All-Hazards Mitigation 

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perform a cost-benefit analysis on manmade and technological 

hazards because, unlike hazards such as floods, occurrence is 

difficult to predict. Thus, mitigation planning for manmade or 

technological hazards is often deferred to state homeland security 

personnel, and applications submitted to FEMA include only 

natural hazard mitigation measures. 

The National Dam Safety program is the Mitigation Directorate’s 

only program that proactively addresses a technological hazard. 

Congress appropriated this program $7.1 million in FY 2008. 

However, communities frequently have other technological 

hazards that DHS does not consider to be critical infrastructure or 

key resource assets, but that nonetheless represent a concern for 

the community. For example, the mitigation plan for California 

alone identifies 6,000 miles of hazardous liquid pipelines, 21 

refineries, 100 oil and natural gas terminals, and 2,500 “high risk” 

chemical facilities. 

FEMA’s Mitigation Directorate has no mitigation grant program 

dedicated to proactively address manmade hazards identified in its 

Risk Management Series or in state, tribal, and local hazard 

mitigation plans. For example, a mitigation measure introduced in 

the Risk Management Series to reduce the potential for hazardous 

materials entering a building from a ground-level outdoor release 

is to elevate the building’s fresh air intakes and cover them with 

screens to make it more difficult to insert a container of hazardous 

material directly into the building’s heating, ventilating, and air 

conditioning system. Figure 4 illustrates this mitigation measure. 

Figure 4. Preventing Hazardous Material From Entering a Building 

FEMA’s Progress in All-Hazards Mitigation 

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Figure 5. Placing Air Intake High on a Building 

Placing a building’s heating, 

ventilating, and air conditioning 

system intakes at the highest 

practical level protects against 

malicious acts and mitigates the risk 

that contaminants released near the 

ground will enter the building 

(figure 5). Many existing buildings 

have air intakes that are at or below 

ground level. For those that have 

below-grade intakes close to the 

building, the intakes can be 

elevated by constructing a plenum 

or external shaft over the intakes. 

An extension height of 12 feet will 

place the intake out of reach of 

individuals without some 

assistance. 

The mitigation measure described above is one of many identified 

in the Risk Management Series that mitigation officials need to 

consider to counter manmade hazards. The implementation of this 

mitigation measure, and others like it, is dependent upon funding. 

State and local mitigation officials told us it is difficult to obtain 

federal funding for mitigation measures that address technological 

and manmade hazards for buildings not considered critical 

infrastructure. Yet the importance of mitigating the risk posed to 

ground-level intake systems was underscored during the trial of 

Nidal Ayyad for the 1993 World Trade Center bombing. Ayyad, a 

naturalized U.S. citizen who worked for a New Jersey chemical 

company, used his position to procure chemicals to manufacture 

the explosive used in the attack. During his trial, it was revealed 

that Ayyad and his associates had stolen cyanide and were 

planning to release it in office-building ventilation systems. 

The risks to public and private buildings from manmade hazards 

are a tremendous challenge for mitigation officials because of the 

sheer number of places Americans congregate daily. The U.S. 

Department of Education reported in 2006 that there were 136,819 

public, private, and postsecondary schools throughout the country; 

the U.S. Census Bureau recorded 6,713 hospitals in 2007; the 

International Council of Shopping Centers recorded 48,695 malls 

FEMA’s Progress in All-Hazards Mitigation 

Page 25 
 

 

 


 

and shopping centers in 2005; and the Department of Energy 

reported more than 4.5 million commercial buildings in 2003. 

To encourage the implementation of hazard mitigation measures 

that protect buildings and their occupants, DHS’ Science and 

Technology staff are promoting the integration of hazard 

mitigation with environmental and energy efficiency planning in a 

performance-based design approach. Building designers, owners, 

and operators can use this approach to link hazard mitigation with 

environmental and energy-saving measures to demonstrate the 

efficacy of performance-based projects. For example, blast guard 

window film can mitigate the risk of shattered glass caused by a 

bomb, hurricane-force wind, or earthquake, as well as reflect heat 

from the sun through reflective tinting that lowers energy costs for 

air conditioning and improves the building environment. 

Natural Hazards Are Predominant But Not the Only Hazards 

Natural disasters historically represent the greatest loss to life and 

property throughout the United States, as illustrated in figure 6. 

There were 75 major disaster declarations in 2008, nearly 70% of 

which involved flooding from severe storms. However, terrorism 

and hazardous material incidents are also apparent. The September 

11, 2001, attacks on New York City and Washington, DC, and the 

July 2001 hazardous material train derailment and fire in 

Baltimore, Maryland, demonstrate the risk of manmade and 

technological hazards. The 2001 anthrax attacks, the 1996 

bombing at the summer Olympics in Atlanta, the 1995 destruction 

of the Murrah Federal Building in Oklahoma City, and the 1993 

World Trade Center bombing all reinforce the need to plan and 

implement mitigation measures for manmade hazards. Protecting 

American communities from disasters, no matter what the source, 

depends on policymakers adopting an integrated, all-hazards 

approach to disaster risk reduction, drawing on existing knowledge 

from natural and accidental hazards combined with new 

information on risks associated with technological and terrorism 

events. 

FEMA’s Progress in All-Hazards Mitigation 

Page 26
 
 

 

 


 

Figure 6. Presidential Disaster Declarations 

The U.S. Department of Transportation reported that in the first 

quarter of 2009 alone there were 3,306 hazardous material incidents 

in the United States costing $7.5 million in damages.16 The three 

states with the most incidents were California (346), Texas (278), 

and Illinois (280). The Federal Bureau of Investigation reports 318 

terrorism events in the United States from 1980 to 2005.17 The most 

frequent attack methods were bombs (209) and arson (43), both of 

which are a concern for those charged with protecting the Nation’s 

building inventory and its occupants. 

16 Hazardous Materials Information System, U.S. Department of Transportation. 

17 U.S. Department of Justice, Federal Bureau of Investigation, Terrorism 2002–2005. 

FEMA’s Progress in All-Hazards Mitigation 

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Conclusion 

The grant programs administered by FEMA’s Mitigation 

Directorate all focus on natural hazards; only the Hazard 

Mitigation Grant and Pre-disaster Mitigation programs can be used 

under certain circumstances to address technological and manmade 

hazards. The Hazard Mitigation Grant program was used to aid 

New York City’s recovery following the Presidential disaster 

declaration regarding the September 11, 2001, terrorist attacks on 

the World Trade Center. The Pre-disaster Mitigation program can 

be used before a disaster occurs, but mitigation projects that solely 

address manmade hazards are ineligible for grant funds. However, 

the Pre-disaster Mitigation program can be used to address 

manmade hazards if grant funds primarily address natural hazards, 

but program guidance does not provide instruction or examples of 

how this can be accomplished. It does make clear that project 

subapplications that propose ineligible activities will be removed 

from consideration. State mitigation officials are reluctant to 

include technological or manmade hazards in their application for 

the Pre-disaster Mitigation program because it could make their 

application less competitive owing to the benefit-cost ratio 

requirement. Natural disasters are the predominant threat facing 

the United States and warrant great attention, but the threat posed 

by technological and manmade hazards is also apparent and 

reinforces the need for mitigation planning and measures that will 

eliminate or reduce their risk and effect. 

Recommendations 

We recommend that the Assistant Administrator, Mitigation 

Directorate: 

Recommendation #6: Provide guidance for the Pre-disaster 

Mitigation Grant program that offers instruction and examples of 

how mitigation officials should prepare grant applications for 

projects that primarily address natural hazards and also address 

hazards caused by manmade forces. 

Recommendation #7: Apply the risk-based methodology used by 

the Grant Programs Directorate for homeland security 

preparedness grants to technological and manmade hazard 

mitigation projects. 

FEMA’s Progress in All-Hazards Mitigation 

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Management Comments and OIG Analysis 

Recommendation #6: The Office of Policy and Program Analysis 

generally concurred with this recommendation and reaffirmed that 

the focus of the Pre-disaster Mitigation program is on addressing 

natural hazards and only cost-effective measures can be funded 

under the program. Furthermore, FEMA believes that it is not 

currently feasible to provide meaningful guidance on cost 

effectiveness for manmade and technological mitigation projects. 

It also responded that FEMA is prohibited by its authorities from 

funding projects that only address manmade hazards through its 

Hazard Mitigation Assistance programs. 

We recognize the imposed constraints relating to the Pre-disaster 

Mitigation program, but the need to employ mitigation measures 

that address technological and manmade hazards is also apparent. 

We believe providing guidance that demonstrates how grant 

applications can be prepared by mitigation officials to effectively 

address hazards beyond just natural hazards will help FEMA fulfill 

its mission of protecting the Nation from all hazards. We consider 

this recommendation resolved because initial steps are being taken 

to implement it; however, it will remain open until FEMA provides 

evidence that it has been fully implemented. 

Recommendation #7: The Office of Policy and Program Analysis 

generally concurred with this recommendation and the Mitigation 

Directorate is evaluating the methodology used by the Grant 

Programs Directorate to address manmade hazards. However, it 

also notes that project funding solely to address technological and 

manmade hazard risks is generally available under federal 

programs and authorities outside FEMA Mitigation Directorate’s 

Hazard Mitigation Assistance grant programs. 

We believe the methodology used by the FEMA Grant Programs 

Directorate for homeland security preparedness grants can be used 

by the Mitigation Directorate to evaluate the effectiveness of 

mitigation projects that address technological and manmade 

hazards. We therefore consider this recommendation resolved 

because initial steps are being taken to implement it; however, it 

will remain open until FEMA provides evidence that it has been 

fully implemented. 

FEMA’s Progress in All-Hazards Mitigation 

Page 29 
Appendix A: Purpose, Scope, and Methodolgy 

Appendix A 

Purpose, Scope, and Methodology 

The primary objective of our audit was to assess FEMA’s progress 

in coordinating the implementation of a risk-based strategy to 

reduce or eliminate long-term risks to people and property from all 

hazards, including technological and manmade hazards. We 

conducted 26 interviews with DHS headquarters and regional staff, 

state and local hazard mitigation officials, mitigation consultants, 

academic researchers, independent analysts, and other experts in 

the field of hazard identification and mitigation. We examined 

documentation relating to hazard mitigation, including authorizing 

legislation, rules and regulations, and FEMA hazard mitigation 

assistance program guidance. 

We reviewed DHS documents, including strategic and operational 

plans, correspondence, analyses, and reports. We reviewed 

mitigation plans from California, Illinois, New Jersey, New York, 

and Texas because each state has at least one DHS-designated Tier 

I urban area considered to be at high risk for manmade and 

technological hazards. We also reviewed reports on various 

aspects of manmade and technological hazard mitigation prepared 

by the Government Accountability Office, the Congressional 

Research Service, the Congressional Budget Office, and various 

public policy organizations. 

We acknowledge the cooperation and courtesies extended to our 

audit team during this audit. We conducted this performance audit 

between October 2008 and May 2009 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. 

FEMA’s Progress in All-Hazards Mitigation 

Page 30 
Appendix B

Management Comments to the Draft Report

SEP 1 7 2009

MEMORANDUM FOR:

J. Kaufìnan

Director

Office otPoliçyand Program Analysis

FEMA's Progress in All-Hazards Mitigation
Appendix B

Management Comments to the Draft Report

Page 2

. The draft report uses the concet of "phaes" of emergency management, leaving out the

"protecon" element, which is crtical to the discusson. Mitigation, Prearedess,

Protection, Response and Recover constitute the fuctions of the comprehenive emergency

management system, not "phases of the emergency management cycle." These fuctions

work collaboratively withn the system, as opposed to dicretely/inependetly in a time-

"phased' sequence of a cycle. Th fuctons are correctly represented on pages 10 an 11 of

the dra reprt.

. The drft reprt assumes tht Mitigation is the sole responsibilty of the Mitigation

Directorate, and all remmenatons are direced to th FEMA Assistat Administrr for

Mitigation. Ho~ever, the Grts Program Directorate adminter programs to protec fr

and mitigate against man-made and technologica hazds, whicn is in keeping with the

PKEMRA concept of all-haards mitigation.

Specific comments on DHS Efforts to Advance All-Hazards Mitigation:

. The explanation of the "thee broad categories" of hazds (p.2) is cotùg, and the

confuion is compouned by the example provided which contrdicts the terinology

explantion provided with the sae pargrph. Specificaly, if "man-made" hazs refer

to "crminal" events then Hurcae Katra is an example of a natu and technological

(not "man-made") disaster.

. The draf report makes the cae for terrrism mitigation as a priar focus for mitigation

grants rather th a secondar purse for mitigation projects. Terorism "mitigation" is

generally focused on protection and prevention (prevention is specficaly defined as

mitigation by PKEMRA). Proteve and prevention measures to mitigate man-made

hazs, such as act of terrism, are authorized and fuded by authorities separe and

distinct from meaes to mitigate against natul hazds.

. On Page 13, the draft report stte that the Deparent of Homeland Securty (OHS) has

$3.45 bilion offuds dedicated to Mitigation in FY 2009. Without fier clarfication, ths

number is misleading. The sour of ths amount is page 92 of V olume II of the DHS Futue

Year Homeland Securty Program (FYSP). A ver large poron of the amount

(approximately $2.826 bilion) is National Flood Insurce Progr Revenue that is required

to pay Flood Inurance claims and by law is not available to fud all-hazards mitigation. Of

the remaining $694 millon, $215.7 millon is available for Haz Mitigation Assistace

(HMA) grants. Ths amount does not include the Haz Mitigation Grant Program

allocation, as ths is allocated by disaste and is not a par of'the FYSP.

Specific comments on Coordinting an All-Hazards Mitigation Strategy:

. A crtical element of the Mitigation Directorate's mission is to assist sttes and locas in

deterining their mitigation priorities and FEMA's HMA progr is developed arund ths

concet. Section 322 of the Stafford Act specfically requires mitigation planng for natu

FEMA's Progress in All-Hazards Mitigation

Page 32
Appendix B 

Management Comments to the Draft Report 

Page 3
 

hazds. However, HMA grt gudance for plang does perit the inclusion of manmae an technologica hads in mitigation plan if the state, trbe or loca communty 

detees it is appropate. Whle one beneft of an approved Hazd Mitigation Plan is
 

avalabilty ofHM asistace, mitigation planng is a larger progr and is intended to 

assist state, trbes and loc counties in building a comprehenive mitigation prgr. 

. On page 15 it state that the National Hurcae Progr "received $5.86 milion in fuding 

for FY008." The Mitigation Direcrate only reeive an allocation of $1.706 milion for 

the National Hurcae Progr. 

Specific comments on Implementing an All-Hazrd Mitigation Approach: 

. The FEMA HM grant progrs present a crtica opportty tò reuce the risk to 

individuas and pr fr na hazds while simultaneously reducing reliance on
 

Feder disaste fuds. FEMA regnze tht ther may be sendar benefts when a 

projec fuded under the applicable Mitigation auorities has a sendar benefit of 

mitigatig agat a man-made or technological ha. Although FEMA is prolubited by its 

autrities frm fuding projec that only address man-made hazs thugh its HMA 

progrs, other FEMA and DHS progr are available to addrs such hazars. 

FEMA generally concu with six of the drft reprt's seen remmendations. Ou reonses for 

eah recmmention are as follows: 

Remmendaton #1: Dedcate resur to prvide techncal assistace and trg to state, trbal, 

and loca mitigation offcials about the Risk Maagement Seres to fier promote mitigaon 

measures that reduce or eliminate loss of life and prery. 

Response: Concur in par. The Rik Management Seres (RMS) is one of many tools for 

comprehenve techncal asistce and trinng that are available thougout the agency an ar 

avaible to stae, trbal and loca offcis. FEMA wil continue to ensu that the Risk
 

Management Seres, along with these other tools, is included in technca asistace and trg to
 

state, trbal, and local mitigation offcials to prmote mitigaon mea that reduce or elimiate 

loss of life and prope. 

Recommendation #2: Update FEMA 386-7, Integrating Man-Made Hazards into Mitigation 

Planning, to inlude all feder fuin sour tht ca be used to implement mitigation meaes
 

tht addrs teological and man-made hazds
 

Response: Nonconcur. Since many such resur ar outside of FEMA and given the pure of
 

ths Plang document, we do not believe ths is appropriate. Mitigation plang is focused on 

encourgig communties to make and enforce better land use planing decision to en that
 

futue development is at les risk frm hazds. Ou primar audience ar land us planer 

floodplai manager, and buildig code offcis. Actal implementation ofidentified mitigation
 

meaur goe beyond the scpe and purose of the planng effort. FEMA also emphasizes tht 

communties should not limit mitigation stategies to those eligible for parcuar feder progrs, 

FEMA's Progress in All-Hazards Mitigation 

Page 33
 
Appendix B 

Management Comments to the Draft Report 

Page 4 

but should have comprehenive plang appropriate to its risks. For a communty interested in 

federal fuding sour of fuding for mitigation meaures that addr technologica and man-


made hads ca be found in the Catalog of Federal Domestic Assistace.
 

Recommendation #3: lncludemitigation in the next phase of the taget capabilties list to asce 

whether communties are considerng what capabilties ar neeed to implement long-ter meaures 

for reducig or eliminatg risk from hazds an their effects. 

Response: Concu. Th work is curently in progr. 

Recmmendation #4: Estalish an coordinate a formal network of representatives from the Grats 

Program Directorate, the National Preparednes Directorate, the Science and Technology 

Dirtora the Nationa Protection and Progrs Directrate and other federal agenes involved in
 

ha mition to identify opportties, resurces, and expese tht can be leveraged to 

implement mitigaion projects that addrss all ha identified by state and local goverents.
 

Response: Concu. Ths work is in progress. 

Recommendation #5: Use the established netork of mitigation parer along with enance
 

collaboraon with DHS components, other federal agencies, and private sector staeholder to 

develop and implement a risk-based, all.hazds mitigation sttegy th identiñes all hiars
 

inert to locjunsdictions and establishes a nationa framework to mitigate these hazs usg 

strct and non-strct meaures.
 

Response: Concu. Much of ths has alreay bee accomplished. FEMAparcipates in the 

National Science and Technology Council Subcottee for Disater Reduction. Ths body is par
 

of the inergeny coordination proce to leverage prgr and capabilties acrss the Federal 

family. In adition, FEMA worked with the National Emergency Management Association to
 

deelop the Whte Paper, Recommendations for an Effective National Mitigation Effort. Building 

Stronger Partnership, Increased Resilience, and Disaster Resistance for a Safer Nation, which 

idenfies the nee for devloping broader collaborative parer.srnps to addres ail-haiar
 

mitigation. 

Recmmendaton #6: Provide gudance for the Pre-isater Mitigation Grt progr tht offer
 

inction and examples of how mitigation offcials should preare grant applications for projec 

that pnmly addres natal haiars and also address hads caused by man-made forces.
 

Response: Concu in par. FEMA has accplished ths in par thugh our existg wid and
 

seismc mitigation prjec which by design also contrbute mitigation benfits for ma-made and 

technologica hazards. In general, however, Pre-disaer Mitgation (PDM) is authorize under 

Section 203(b) of the Stafford Act to fud mitigation activities identiñed in mitigation plan with 

respect to natual hads, and only cost-effectve meaures can be fuded under the progr. The 

foc of FEMA gudace for PDM is on addresing the risk from natu hazs that is the prima 

purse of the program; however, it is not curently feible to provide meangñ gudace on cost 

effectveness for ma-made and technological mitigation prjecs. 

FEMA's Progress in All-Hazards Mitigation 

Page 34 
Appendix B 

Management Comments to the Draft Report 

Page 5 

Recmmendation #7: Apply the risk-based methodology used by the Grants Program Dirctorate 

for homeland secty prardnes grts to technological and man-made haz mitigation
 

projec. 

Response: Concu in par. In coordination with GPO an NPD, Mitigation is evuati ths
 

metodology that is cuently limited to man-made haz. Curtly, project fuding solely to
 

addres tehnological and ma-made hazard risks are generally available under federal progrs and 

authorities outside FEMA Mitigation Directorate's HM grt programs. 

Than you aga for the opportty to comment on ths draft re and we look forwar to working
 

with you on other isses as we both stve to improve FEMA. 

FEMA's Progress in All-Hazards Mitigation 

Page 35 
 

Appendix C: FEMA Risk Management Series Publications 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 

	 


 

Appendix C 

List of Publications From FEMA’s Risk Management Series 

•	 FEMA 389, Communicating with Owners and Managers of New Buildings on 

Earthquake Risk: A Primer for Design Professionals, January 2004 

•	 FEMA 395, Incremental Seismic Rehabilitation of School Buildings (K-12): 

Providing Protection to People and Buildings, June 2003 

•	 FEMA 396, Incremental Seismic Rehabilitation of Hospital Buildings: Providing 

Protection to People and Buildings, December 2003 

•	 FEMA 397, Incremental Seismic Rehabilitation of Office Buildings: Providing 

Protection to People and Buildings, December 2003 

•	 FEMA 398, Incremental Seismic Rehabilitation of Multifamily Apartment 

Buildings: Providing Protection to People and Buildings, February 2004 

•	 FEMA 399, Incremental Seismic Rehabilitation of Retail Buildings: Providing 

Protection to People and Buildings, July 2004 

•	 FEMA 400, Incremental Seismic Rehabilitation of Hotel and Motel Buildings, 

April 2005 

•	 FEMA 424, Design Guide for Improving School Safety in Earthquakes, Floods, 

and High Winds, January 2004 

•	 FEMA 426, Reference Manual to Mitigate Potential Terrorist Attacks Against 

Buildings, December 2003 

•	 FEMA 427, Primer for Design of Commercial Buildings to Mitigate Terrorist 

Attacks, December 2003 

•	 FEMA 428, Primer to Design Safe School Projects in Case of Terrorist Attacks, 

December 2003 

•	 FEMA 429, Insurance, Finance, and Regulation Primer for Terrorism Risk 

Management in Buildings, December 2003 

•	 FEMA 430, Site and Urban Design for Security Guidance Against Potential 

Terrorist Attacks, December 2007 

•	 FEMA 433, Using HAZUS-MH for Risk Assessment: How-To Guide, August 2004 

•	 FEMA 452, A How-To Guide to Mitigate Potential Terrorist Attacks Against 

Buildings, January 2005 

FEMA’s Progress in All-Hazards Mitigation 

Page 36
 
 

	 

	 

	 

	 

	 

	 


 

Appendix C 

List of Publications From FEMA’s Risk Management Series 

•	 FEMA 453, Safe Rooms and Shelters – Protecting People Against Terrorist 

Attacks, May 2006 

•	 FEMA 454, Designing for Earthquakes: A Manual for Architects, December 2006 

•	 FEMA 455, Rapid Visual Screening for Building Security, Publishing pending 

•	 FEMA 459, Incremental Protection for Existing Commercial Buildings from 

Terrorist Attack, April 2008 

•	 FEMA 543, Design Guide for Improving Critical Facility Safety from Flooding 

and High Winds: Providing Protection to People and Buildings, January 2007 

•	 FEMA 577, Design Guide for Improving Hospital Safety in Earthquakes, Floods, 

and High Winds, June 2007 

FEMA’s Progress in All-Hazards Mitigation 

Page 37
 
Appendix D: National Planning Scenarios outlined in the National Response Framework 

 

 

 

Appendix D 

National Planning Scenarios Identified in the National Response 

Framework 

Key Scenario Sets National Planning Scenarios 

1. Explosives Attack – Bombing Using 

Improvised Explosive Device 

Scenario 12: Explosives Attack – Bombing 

Using Improvised Explosive Device 

2. Nuclear Attack Scenario 1: Nuclear Detonation – Improvised 

Nuclear Device 

3. Radiological Attack – Radiological 

Dispersal Device 

Scenario 11: Radiological Attack – 

Radiological Dispersal Device 

4. Biological Attack – With annexes for 

different pathogens 

Scenario 2: Biological Attack – Aerosol 

Anthrax 

Scenario 4: Biological Attack – Plague 

Scenario 13: Biological Attack – Food 

Contamination 

Scenario 14: Biological Attack – Foreign 

Animal Disease 

5. Chemical Attack – With annexes for 

different agents 

Scenario 5: Chemical Attack – Blister Agent 

Scenario 6: Chemical Attack – Toxic 

Industrial Chemicals 

Scenario 7: Chemical Attack – Nerve Agent 

Scenario 8: Chemical Attack – Chlorine Tank 

Explosion 

6. Natural Disaster – With annexes for 

different disasters 

Scenario 9: Natural Disaster – Major 

Earthquake 

Scenario 10: Natural Disaster – Major 

Hurricane 

7. Cyber Attack Scenario 15: Cyber Attack 

8. Pandemic Influenza Scenario 3: Biological Disease Outbreak – 

Pandemic Influenza 

FEMA’s Progress in All-Hazards Mitigation 

Page 38 
 

Appendix E: Hazards Indentified in Local Hazard Mitigation Plans for the State of California, October 2007 

 

 

 

 

 

 

 

 


 

Appendix E 

Hazards Identified in Local Hazard Mitigation Plans for the State of 

California, October 2007 

Agriculture Insect Hazards 

Arson/Commercial Fire Landslides 

Avalanche Large Venue Fires 

Biological/Health Emergency Liquefaction 

Blackout Mass Casualty 

Civil Unrest Mine Safety 

Coastal Erosion Multi-Hazard 

Coastal Storm Nuclear Power Plant Accident 

Dam/Levee Failure Propane Distribution Facilities 

Data Telecommunications Radiological Incident/Accident 

Drought Severe Weather 

Earth Movement Sinkholes/Subsidence 

Earthquake Soil Hazards 

Economic Disruption Snow Storm 

Energy Emergency Special Events 

Explosions Substations 

Explosive Manufacturing & Storage Technological Failure 

Extreme Heat Terrorism 

Fire Tornados 

Flooding Toxic Pollution 

Fuel Release Transportation Incident (incl. Train & Airplane) 

Geologic Hazard Tsunami 

Ground shaking Unexploded Munitions 

Groundwater Contamination Utility Loss 

HAZMAT Volcanoes 

High/Straight Line Winds Water/Wastewater Disruption 

Human Caused Wildfire 

Infrastructure (Pipeline, Aqueduct) Windstorms 

Jail/Prisons Event 

FEMA’s Progress in All-Hazards Mitigation 

Page 39
 
 

 

Appendix F: Major Contributors to this Report 


 

Appendix F 

Major Contributors to This Report 

Norman Brown, Director, Preparedness and Mitigation Division, 

Office of Emergency Management Oversight 

Craig Anderson, Auditor-in-Charge, Preparedness and Mitigation 

Division, Office of Emergency Management Oversight 

Aaron Naas, Program Analyst, Preparedness and Mitigation 

Division, Office of Emergency Management Oversight 

FEMA’s Progress in All-Hazards Mitigation 

Page 40
 
 

Appendix G: Report Distribution

 


 

Appendix G 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

FEMA Administrator 

Assistant Administrator, FEMA Mitigation Directorate 

FEMA Audit Liaison (DP8R07) 

FEMA Grant Programs Directorate 

FEMA National Preparedness Directorate 

Science and Technology Directorate 

National Protection and Programs Directorate 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

FEMA’s Progress in All-Hazards Mitigation 

Page 41
 
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