GAO 

United States Government Accountability Office

Report to the Chairman, Subcommittee on 

Oversight of Government Management, the 

Federal Workforce, and the District of 

Columbia, Committee on Homeland Security 

and Governmental Affairs, U.S. Senate 

EMERGENCY 

COMMUNICATIONS 

National 

Communications 

System Provides 

Programs for Priority 

Calling, but Planning 

for New Initiatives 

and Performance 

Measurement Could 

Be Strengthened 

August 2009 

GAO-09-822 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2009

EMERGENCY COMMUNICATIONS 

National Communications System Provides Programs

for Priority Calling, but Planning for New Initiatives

and Performance Measurement Could Be 

Strengthened 

Highlights of GAO-09-822, a report to the 

Chairman, Subcommittee on Oversight of 

Government Management, the Federal 

Workforce, and the District of Columbia, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

Government functions and 

effective disaster response and 

management rely on the ability of 

national security and emergency 

preparedness (NS/EP) personnel to 

communicate. The Department of 

Homeland Security’s (DHS) 

National Communications System 

(NCS), is responsible for ensuring 

continuity of NS/EP 

communications when network 

congestion or damage occurs. As 

requested, GAO assessed the (1) 

priority communication programs 

NCS provides, how it enlists 

subscribers, and to what extent 

NCS controls access to these 

programs; (2) challenges that can 

affect delivery of these programs; 

and (3) extent to which NCS plans 

for and evaluates its services. GAO 

reviewed NCS program documents, 

such as annual reports and access 

control procedures and data on 

program subscribers. GAO also 

interviewed officials from NCS and 

select state and local government 

entities. GAO compared NCS 

performance measures to federal 

best practices. 

What GAO Recommends

Among other things, GAO 

recommends the Manager of NCS 

(1) define program capabilities, 

costs, and mitigation plans as part 

of NCS’s acquisition planning for 

enhanced NS/EP communications 

services; (2) incorporate strategic 

planning best practices as NCS 

finalizes its strategic plan; and (3) 

strengthen NCS’s performance 

measurement. DHS agreed with our 

recommendations. DHS’s detailed 

comments and GAO’s response are 

included in the report. 

NCS has two programs to provide NS/EP personnel with priority calling 

service when telephone networks are congested or damaged—the 

Government Emergency Telecommunications Service (GETS) and the 

Wireless Priority Service (WPS). NCS has undertaken several efforts, such as 

outreach at industry conferences, to increase participation in and control 

access to these programs. According to NCS, though outreach efforts have 

helped to increase overall enrollment, it is working to further address possible 

cost barriers to participation in WPS, such as discussing options with wireless 

carriers to help defray costs. In addition, NCS has implemented policies and 

procedures to ensure that access to its priority programs are limited to 

authorized users. GAO’s review of select GETS and WPS subscriber data 

revealed that, of the 85 records we examined, NCS generally followed its 

policies and procedures to limit GETS and WPS access to authorized 

subscribers. 

NCS is taking steps to address inherent challenges in the communications 

environment—such as network congestion. For example, NCS initiated a 

satellite pilot program to allow NS/EP officials to circumvent severely 

damaged or congested traditional telephone networks. However, methods for 

implementation and evaluation of the pilot were unclear and NCS 

subsequently terminated the pilot. NCS is also working to provide priority 

voice and data NS/EP communications as part of the evolving 

telecommunications networks, but it has not finalized an acquisition approach 

based on available technologies, costs, or plans to mitigate technological and 

other challenges to deliver such capabilities. The lack of this information has 

led to congressional restrictions on NCS’s funding. As NCS attempts to ensure 

that GETS and WPS services can operate in these evolving networks, an 

acquisition approach that includes this information will provide NCS officials 

and Congress with essential information to most effectively allocate resources 

and guide decision making. 

Although DHS agreed with GAO’s June 2008 recommendation to complete the 

NCS strategic plan, NCS has not finalized its strategic plan which has been 

under development since 2007. Furthermore, existing performance measures 

do not cover all of its core responsibilities, as suggested by best practices, and 

certain performance measures could be strengthened. For example, NCS does 

not have a measure to gauge its performance in two of its key federal roles—

critical infrastructure protection for communications under DHS’s National 

Infrastructure Protection Plan as well as coordinating communications issues 

under the National Response Framework. Furthermore, NCS does not use 

prior years’ enrollment levels to help determine increases, if any, to be made 

to future year’s goals for user enrollment. Fully and accurately measuring 

performance is critical to ensuring the agency and key stakeholders—such as 

Congress—base program and resource decisions on actual performance. View GAO-09-822 or key components.

For more information, contact William O. 

Jenkins at (202) 512-8777 or 

jenkinswo@gao.gov. 
Page i GAO-09-822 

Contents 

Letter 1

Background 5 

NCS Provides Priority Calling Services for NS/EP Personnel and 

Has Designed Mechanisms to Manage Access to These Services 13 

Initiatives Exist to Address Challenges in NCS’s Operating 

Environment, but Planning Efforts to Leverage Evolving 

Technology Could Be Strengthened 24 

NCS Has Implemented Strategic Planning Efforts, but These Could 

Be Strengthened by Incorporating Key Planning and 

Performance Measurement Practices 32 

Conclusions 43 

Recommendations for Executive Action 45 

Agency Comments and Our Evaluation 46 

Appendix I The NCS Organization Structure 49 

Appendix II Objectives, Scope and Methodology 54 

Appendix III Telecommunications Service Priority Program 59 

Appendix IV GETS and WPS Performance during Select 

Emergency Events 62 

Appendix V NS/EP Categories That Qualify for NCS’s Priority 

Telecommunications Services 65 

Appendix VI Comments from the Department of Homeland 

Security 68 

Appendix VII GAO Contacts and Staff Acknowledgments 70 

 National Communications System 
Tables 

Table 1: Participation Levels in the GETS and WPS Programs as of 

April 2009 19 

Table 2: GETS and WPS Subscriber Rates and Program Fees 21 

Table 3: NCS’s Strategic Goals and Select Objectives 33 

Table 4: NCS’s Performance Measures, Targets, and Results for 

Fiscal Years 2006 to 2009 39 

Table 5: GETS and WPS Performance during Select Emergency 

Events 63 

Table 6: NS/EP Categories That Qualify for NCS’s Priority 

Telecommunications Services 66 

Figures 

Figure 1: Packet-Switching Versus Circuit-Switching 9 

Figure 2: GETS Calling Card 15 

Figure 3: Linkages between NCS Performance Measures and NCS 

and DHS Strategic Goals and Objectives 36 

Figure 4: NCS Management Structure 53 

Page ii GAO-09-822 National Communications System
Abbreviations 

EOP Executive Office of the President 

ESF-2 emergency support function no. 2 

FCC Federal Communications Commission 

FEMA Federal Emergency Management Agency 

GETS Government Emergency Telecommunications Service 

HSC Homeland Security Council 

IP Internet Protocol 

IPv4 Internet Protocol version 4 

IPv6 Internet Protocol version 6 

IXC interexchange carrier 

NCC National Coordinating Center for Telecommunications 

NCS National Communications System 

NEMA National Emergency Management Association 

NGN next generation network 

NIPP National Infrastructure Protection Plan 

NS/EP national security and emergency preparedness 

NS/EP NGN national security and emergency preparedness next 

 generation network 

NSC National Security Council 

NSTAC National Security Telecommunications Advisory 

 Committee 

OMB Office of Management and Budget 

OMNCS Office of the Manager, National Communications System 

OSTP Office of Science and Technology Policy 

POC point-of-contact 

PSTN public switch telephone network 

VoIP Voice over Internet Protocol 

WPS Wireless Priority Service 

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Page iii GAO-09-822 National Communications System
Page 1 GAO-09-822 

 

United States Government Accountability Office

Washington, DC 20548 

 

August 28, 2009 

The Honorable Daniel K. Akaka 

Chairman 

Subcommittee on Oversight of Government Management, 

 the Federal Workforce, and the District of Columbia 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

Dear Mr. Chairman: 

The global community relies on telecommunications services and 

infrastructure to conduct business, government, and daily life.1

 Emergency 

events such as the September 11, 2001, terrorist attacks and Hurricane 

Katrina in 2005, during which communications capabilities were 

substantially disrupted, remind us of the fragility of the complex 

telecommunications infrastructure and the need to ensure availability of 

communications capabilities for leaders responsible for functions critical 

to the management of and response to national security and emergency 

situations. Telecommunications infrastructure is susceptible not only to 

flooding, fire, and power outages, but also to increased demand—all of 

which can limit the availability of telecommunications services or render 

services inoperable. In the United States, more than 2 billion calls are 

made every day via wireline and wireless networks, and, in 2008, more 

than 1 trillion text messages were transmitted. Additionally, since the mid1990s, U.S. wireless telephone subscriptions have grown from about 28 

million to more than 270 million as of December 2008, resulting in a 

significant surge in the number of daily voice and data transmissions. This 

surge can create increased competition for critical telecommunications 

resources that may be limited during disasters and emergencies.2

Heightened network use, in combination with the effects of disasters and 

emergencies, can produce cascading effects far beyond the physical 

location of the disaster area. 

1

Telecommunications is defined as the electronic transmission of information, including 

voice and data, over a long distance for the purpose of communicating. 

2

Data obtained from the Cellular Telecommunications and Internet Association, an industry 

trade association. 

 National Communications System 
 

In 1963, President Kennedy established the National Communications 

System (NCS),3

 which now falls under the Department of Homeland 

Security (DHS), to facilitate continuity of government by maintaining 

communications between the President and officials with national security 

and emergency preparedness (NS/EP) functions.4

 Given the critical nature 

of their roles, it is essential that these individuals have access to vital 

communications capabilities needed to carry out their NS/EP functions—

particularly during disasters or emergencies. To that end, the NCS 

provides a number of programs and services designed to enable 

communications and facilitate continuity of government during 

emergencies. 

You requested that we review the communications capabilities and access 

to the priority communications programs that NCS provides. In response 

to your request, we prepared this report to answer the following questions: 

(1) What priority communications programs does NCS provide, how does 

NCS enlist subscribers, and to what extent does NCS control access to 

these programs? 

(2) What challenges, if any, can affect NCS’s delivery of priority 

communications programs? 

(3) To what extent does NCS plan and evaluate its services? 

To analyze what priority communications programs NCS provides, we 

reviewed relevant legislation, available NCS program plans, as well as 

budget requests and annual reports. We also interviewed relevant NCS and 

Federal Communications Commission (FCC) officials who have varying 

 

3

The NCS is both a national communications system that brings together the 

telecommunications assets owned or leased by the federal government that can meet the 

federal government’s communications needs to support its national security and 

emergency preparedness activities as well as a management structure intended to ensure 

that a national telecommunications infrastructure is developed that is responsive to these 

needs. The management structure includes (1) an office within DHS that consists of the 

Office of the Manager, NCS, which includes the National Coordinating Center for 

Telecommunications, and (2) an interagency body of NCS member agencies, which is a 

consortium of 24 federal departments and agencies. 

4

NS/EP personnel include officials from across all levels of government including members 

of Congress, personnel in federal departments and agencies with continuity of government 

responsibilities, state governors, mayors, fire and police chiefs, and state and local 

government emergency managers. 

Page 2 GAO-09-822 National Communications System
 

responsibilities for priority communications. In addition, we interviewed 

cognizant representatives from AT&T, Qwest Communications, and 

Verizon. We selected these carriers because they provide NS/EP 

communications services and were amenable to meeting with us.5

Although their views cannot be generalized to all telecommunications 

companies that provide NS/EP communications, the information we 

obtained helped to enhance our understanding of their role in providing 

emergency communications. We also interviewed NS/EP officials from a 

nonprobability sample of 15 states and 13 localities, which we selected 

based on a variety of factors including geographical location, terrain and 

climate conditions, and types and frequency of natural disasters.6

 While 

the results of these interviews cannot be generalized to reflect the views of 

NS/EP emergency management officials in all states and localities, the 

information obtained provided us with useful information on the 

perspectives of various NS/EP personnel about NCS and its priority 

communications programs. To determine how NCS enlists subscribers and 

controls access to its priority programs, we collected and reviewed 

subscriber eligibility criteria, and interviewed NCS officials on these 

criteria, NCS’s outreach efforts to enlist new subscribers, and its internal 

controls for controlling access to these programs. We also obtained NCS 

standard operating procedures and compared them with criteria in 

Standards for Internal Control in the Federal Government.7

To determine whether NCS adhered to its procedures for terminating 

access for subscribers who no longer meet the programs’ eligibility 

criteria, we reviewed subscriber records for select former federal and 

state government officials. Specifically, we reviewed a nonprobability 

sample of records for former members of the U.S. Senate as well as 

members and delegates of the U.S. House of Representatives; immediate 

past heads of federal departments and agencies as of August 2008; and 

 

5

NS/EP communications are telecommunications services used to maintain a constant state 

of readiness—24 hours a day, 7 days a week, 365 days a year—or to respond to and manage 

any event or crisis that can (1) create injury or harm to the population and (2) threaten the 

NS/EP posture of the nation, among other things. 

6

Nonprobability sampling is a method of sampling when nonstatistical judgment is used to 

select members of the sample, usually specific characteristics of the population as criteria. 

Results from nonprobability samples cannot be used to make inferences about a 

population, because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample. 

7

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). 

Page 3 GAO-09-822 National Communications System
 

immediate past governors of U.S. states and territories as of August 2008, 

which is when we obtained the subscriber data. We selected these groups 

because they served in public positions that would allow NCS to easily 

determine that their positions ended, and in turn, work with the subscriber 

organization’s to update account status, as appropriate. Although the 

results of our work cannot be generalized to evaluate the effectiveness of 

controls used for all NCS program subscribers, the information obtained 

provided us with useful information about the extent to which subscriber 

records were terminated for groups we reviewed following a change in the 

subscriber’s eligibility status. Because the subscriber database, in its 

entirety, is classified, we have limited our reporting of the results of our 

analysis to only nonclassified information; however, this does not affect 

our findings. To assess the reliability of these data, we reviewed the data 

for obvious problems with completeness or accuracy, interviewed 

knowledgeable agency officials and contract support staff about the data 

quality control processes, and reviewed relevant documentation such as 

the database dictionary that describes various data fields in the subscriber 

database. We performed electronic testing on the data and found the data 

to be sufficiently reliable for the purposes of this report. 

To determine what challenges can affect NCS’s delivery of its priority 

communication programs, we interviewed relevant NCS officials who have 

responsibilities for the implementation of these programs. We also 

obtained information and reviewed documentation such as briefing slides 

from the agency regarding its efforts to implement a pilot program to 

explore utilizing satellite technology, the Satellite Priority Service pilot 

program, as well as its efforts to leverage next generation network (NGN) 

technology in its priority communication programs. We compared this 

information with our previous work on pilot program planning and 

technology acquisition to determine the extent to which it was consistent 

with these criteria.8

To assess NCS’s overall planning and evaluation efforts, we reviewed 

related program and planning documentation including Program 

Assessment Rating Tool (PART) reports submitted to the Office of 

 

8

GAO, Tax Administration: IRS Needs to Strengthen Its Approach for Evaluating the 

SRFMI Data-Sharing Pilot Program, GAO-09-45 (Washington, D.C.: November 7, 2008); 

and Information Technology: DHS Needs to Fully Define and Implement Policies and 

Procedures for Effectively Managing Investments, GAO-07-424 (Washington, D.C.: April 

27, 2007). 

Page 4 GAO-09-822 National Communications System
 

Management and Budget (OMB).9 We also interviewed NCS officials about 

their strategic planning efforts and the mechanisms NCS uses to evaluate 

its services. We compared these efforts with criteria in guidance from the 

Office of Management and Budget (OMB), related legislation such as the 

Government Performance and Results Acts of 1993, as well as federal best 

practices contained in our past reports.10 Our work primarily focused on 

the office that is charged with executing the day-to-day functions 

necessary to meet federal national security and emergency preparedness 

telecommunications needs, which is the Office of the Manager, NCS 

(OMNCS). Throughout this report, unless otherwise noted, we refer to the 

OMNCS as the NCS, though organizationally, the NCS includes the 

OMNCS, as well as a 24-member interagency body, among other entities. 

For more details on the overall NCS organization structure, see appendix I. 

We conducted this performance audit from June 2007 through August 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 provides a reasonable basis for our findings and conclusions 

based on our audit objectives. Appendix II contains more details on our 

scope and methodology. 

Background 

Telecommunications 

Infrastructure 

The telephone remains an essential communication tool for business, 

government, and the general public. The public switched telephone 

network (PSTN), an interconnected network of telephone exchanges over 

 

9

PART consists of a standard series of questions intended to determine the strengths and 

weaknesses of federal programs. The PART questions cover four broad topics—(1) 

program purpose and design, (2) strategic planning, (3) program management, and (4) 

program results/accountability. 

10Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285 

(1993); and OMB, OMB Circular A-11, Part 6, Preparation, Submission, of Strategic 

Plans, Annual Performance Plans, and Annual Program Performance Reports 

(Washington, D.C.: Executive Office of the President, June 2008). For our past work, see, 

for example, GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing 

Season Performance Measures, GAO-03-143 (Washington, D.C.: November 22, 2002); and 

Executive Guide: Effectively Implementing the Government Performance and Results 

Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

Page 5 GAO-09-822 National Communications System
 

which telephone calls travel from person to person, is the backbone of the 

communications architecture that enables the transmission of voice and 

data communications. In general terms, the PSTN is the public 

communications system that includes the networks of local and long 

distance telephone carriers, as well as cellular networks and satellite 

systems. To connect one wireline (also known as landline) telephone to 

another, the telephone call is routed through various switches at telephone 

exchanges that are operated by local and long-distance telephone 

carriers.11 As a caller dials another party’s number, the transmission from 

one caller to the other is made through a telephone company’s facility, 

known as the central office, over copper wires or fiber-optic cables to the 

called party’s telephone. Over time, the PSTN has evolved from an analog 

system to one that is almost entirely digital and able to support voice and 

data transmissions made from wireline and wireless devices. 

Wireless networks, which include cellular and satellite-based systems, 

among other systems, are an important and growing element of the 

communications infrastructure. Cellular and satellite-based systems and 

networks provide an alternative to wireline networks because they are 

potentially accessible from any point on the globe without the cost of 

installing a wire or cable. Rather than relying on wired connections, 

wireless devices (such as cellular telephones) are essentially sophisticated 

radio devices that send and receive radio signals. These devices connect to 

a wireless network—which may also interact with the PSTN, depending on 

the type of connection—that enables the wireless telephone to connect to 

another wireless or wireline telephone. Wireless networks operate on a 

grid that divides large geographical areas (such as cities) into smaller cells 

that can range from a few city blocks to several miles. Each cell contains 

or is adjacent to a base station equipped with one or more antennas to 

receive and send radio signals to wireless devices within its coverage area, 

which can range from less than a mile to 20 miles from the base station. 

When a caller turns on a wireless device, the device searches for a signal 

on an available channel from a nearby base station to confirm that service 

is available. At that time, the base station assigns a radio frequency (also 

known as radio channels) to the wireless device from among the group of 

frequencies that the base station controls. Each base station is wirelessly 

linked to a mobile switching office, as well as a local wireline telephone 

 

11A switch is a piece of equipment in a telephone carrier’s central office facility that routes 

telephone signals between users and terminates connections when there is no longer a 

session to support. 

Page 6 GAO-09-822 National Communications System
 

network. The mobile phone switching office directs calls to the desired 

locations, whether to another wireless device or a traditional wireline 

telephone. 

If a wireless caller is connecting with another wireless telephone, the call 

may go through the wireline network to the recipient’s wireless carrier, or 

it may be routed wholly within the wireless network to the base station 

that is nearest the called party. On the other hand, when the wireless caller 

is connecting to a wireline phone, the call travels to the nearest base 

station and is switched by the caller’s wireless carriers to a wireline 

telephone network. The call then becomes like any other phone call and is 

directed over the PSTN to the destination number. 

NS/EP Communications in 

the Next-Generation 

Networks 

Because both voice and data transmissions have become common 

functions in daily life, an effective communications infrastructure that 

includes voice and data networks is essential to the nation’s ability to 

maintain communications to enable public health and safety during a 

natural disaster, such as a hurricane, or a man-made disaster, such as a 

terrorist attack. Over the years, voice and data networks have evolved 

separately, with voice networks relying on circuit-switching methods 

while data networks largely use packet-switching techniques.12 Thus, a 

user requiring voice, data, and videoconferencing services may have to use 

three separate networks—a voice network, a data network, and a 

videoconferencing network. The telecommunications industry has begun 

to address the limitations of legacy communications infrastructure (such 

as the PSTN) to provide integrated voice, data, and video services. 

Technological advances in these networks have led to a convergence of 

the previously separate networks used to transmit voice and data 

communications. These new converged networks—commonly referred to 

as next-generation networks—are capable of transmitting both voice and 

data on a single network and eventually are to be the primary means for 

voice and data transmissions. Converged voice and data networks use 

technology that is based on packet switching which involves breaking a 

message (such as an ongoing videoconference, images, or voice 

conversation) into packets, or small chunks of data. Using the packet’s 

 

12Conventional voice services use traditional telephone networks (such as the PSTN), 

which are based on circuit switching technology. Instead of breaking a message into 

packets, circuit-switching uses a dedicated channel to transmit the voice connection. Once 

all channels are occupied, no further connections can be made until a channel becomes 

available. 

Page 7 GAO-09-822 National Communications System
 

destination address, computer systems called routers determine the 

optimal path for the packets to reach their destination where they are 

recombined to form the original message. In doing so, packets can be 

transmitted over multiple routes rather than via a predetermined circuit, 

which, in turn, can help to avoid areas that may be congested or damaged, 

among other things. For example, information sent over the Internet is 

packet-switched, the transmission of which is defined by Internet protocol 

(IP).13 Wireline and wireless carriers have begun transforming their 

networks to route voice data this way, called Voice over Internet Protocol 

(VoIP) rather than circuit-switched methods. The adoption of VoIP and 

other technological advances is changing the way in which people 

communicate and, as a result, are likely to become central to the future of 

NS/EP communications. Figure 1 shows a comparison between how 

information is transmitted via packet switching versus circuit switching. 

Industry analysts have said that although the transition to converged 

networks is well underway, they expect the process to take many years. 

Furthermore, NCS projects that half of the existing circuit-switched 

network will be transitioned to packet-based network by 2015 with the 

remainder reaching full transition by 2025. 

 

13IP is a set of standards that enable the transmission of information such as text, video, 

and voice across a global network of networks. These protocols are updated as the uses 

and processes for transmitting voice and data communications evolve. For more 

information on the ongoing transition to the next version of IP, see GAO, Internet Protocol 

Version 6: Federal Government in Early Stages of Transition and Key Challenges 

Remain, GAO-06-675 (Washington, D.C.: June 30, 2006). 

Page 8 GAO-09-822 National Communications System
 

Figure 1: Packet-Switching Versus Circuit-Switching 

Original message Broken into 

packets

Routed across a network path 

that can be modified as needed

Reassembled to form 

original message

Original message Routed across a fixed network path Original message

Mr. Watson, 

Come here. 

I need you.

Mr. Watson, 

Come here. 

I need you.

Mr. Watson, 

Come here. 

I need you.

Mr. Watson,

Mr. Watson,

Mr. Watson,

I need you. I need you.

I need you.

Mr. Watson, 

Come here. 

I need you.

Circuit-switched network

Packet-switched network

Come here. Come here. Come here.

Source: GAO analysis; Art Explosion (images). 

Note: The example above demonstrates how an e-mail or similar message is transmitted between 

computers and/or enabled wireless devices using packet-based versus circuit-based methods. In the 

top example, the three packets that comprise the original message can travel various, different paths, 

and can be rerouted as necessary to successfully complete transmission. 

Page 9 GAO-09-822 National Communications System
 

Despite the evolution in telecommunications technology, congestion in the 

wireline and wireless telephone networks occurs. Damage or destruction 

of infrastructure, or extreme demand for service, can result in outages or 

congestion on the wireline and wireless networks which can impede or 

obstruct successful communications. During periods of congestion, the 

caller may encounter signs that the network is congested such as (1) a fast 

busy signal and (2) a prerecorded message alerting the caller that all 

circuits are busy. Given the importance of telecommunications to 

coordinating response and recovery efforts, it is essential that NS/EP 

officials successfully complete their calls even when there is damaged 

infrastructure or network congestion. For example, nationwide 

telecommunications congestion and failures during the September 11, 

2001, attacks and Hurricane Katrina in 2005 were due, in part, to both 

damaged infrastructure and high call volume. Additionally, high call 

volume that has the potential to create network congestion can occur 

independent of emergencies. For example, Mother’s Day has historically 

generated the highest volume of telephone calls of any day of the year. 

This increased call volume can create network congestion and cause call 

delay or disruption during normal operations; this congestion would also 

reduce the likelihood NS/EP personnel would be able to successfully place 

calls in the event of an emergency during this period. A similar issue exists 

for text messaging, wherein high volumes of text transmissions can create 

network congestion. For instance, on New Year’s Eve, a spike in the 

number of text messages transmitted in the minutes immediately 

preceding and following midnight could overload cellular networks. The 

effects of this congestion could be severe for emergency responders in the 

event they needed to coordinate planning for or response to an emergency 

at that time. 

Network Congestion Can 

Affect Communications 

Capabilities 

Organization and 

Responsibilities of the 

National Communications 

System 

As part of the creation of DHS under the Homeland Security Act of 2002, 

NCS was transferred to DHS from the Department of Defense.14 Within 

DHS, NCS is organized as part of the Office of Cyber Security and 

Communications and has a fiscal year 2009 budget of $141 million. While 

the Secretary of Homeland Security has overall responsibility for the 

broader NCS organization,15 the duties are delegated to the NCS Manager 

who has primary responsibility for day-to-day activities of the NCS, 

 

14Pub. L. No. 107-296, § 201, 116 Stat. 2135, 2145-49 (2002). 

15The duties of the NCS and the NCS Manager are set forth in Executive Order No. 12,472, 

49 Fed. Reg. 13,471 (April 3, 1984). 

Page 10 GAO-09-822 National Communications System
 

including coordinating the planning and provisioning of communications 

services that support NS/EP needs. Central to its functions are the 

partnerships that NCS has established with federal, state, and local 

government entities, and with the service providers and equipment 

vendors that provide wireline and wireless communications services to 

support NS/EP communications. For example, NCS has long-standing 

relationships with industry groups such as the National Security 

Telecommunications Advisory Committee (NSTAC)—a presidentially 

appointed committee of industry leaders—that help keep it abreast of 

changes in the commercial telecommunications marketplace.16 The 

committee provides industry-based analyses and recommendations to the 

President and executive branch regarding telecommunications policy and 

proposals for enhancing national security and emergency preparedness. 

Since joining DHS when DHS became operational in March 2003, federal 

policies provided that NCS’s responsibilities include, among other things, 

serving as the lead coordinating agency for communications issues 

(defined as emergency support function no. 2, or ESF-2), under the 

National Response Framework.17 As part of this responsibility, when 

significant impact to the communications infrastructure occurs or is 

expected, NCS is to serve as one of the primary agencies to (1) support the 

restoration of the communications infrastructure and (2) coordinate the 

deployment of federal communications support to response efforts.18 As 

part of its ESF-2 role, NCS conducts and/or supports training and 

exercises intended to test and improve response and recovery capabilities 

needed in the event of an emergency or disaster. For example, NCS has 

supported exercises that model emergency scenarios that include 

potential and actual impacts to the communications infrastructure. In 

addition to its ESF-2 responsibilities, NCS serves as the Sector-Specific 

Agency to lead the federal government’s efforts to protect critical 

 

16As of May 2009, the NSTAC is comprised of 22 industry leaders appointed by the 

President, usually chief executive officers, from telecommunications companies, network 

service providers, information technology firms, finance, and aerospace companies. 

17The National Response Framework, issued by DHS in 2008, is the policy document that is 

to guide how federal, state, local, and tribal governments, along with nongovernmental and 

private sector entities, are to collectively respond to and recover from all hazards, 

including catastrophic disasters, such as Hurricane Katrina. 

18Additionally, NCS is charged with facilitating the recovery of systems and applications in 

the event of a major Internet disruption caused by a cyber attack, among other things. 

Page 11 GAO-09-822 National Communications System
 

communications infrastructure.19 In this regard, NCS works with industry 

that owns and operates the vast majority of communications 

infrastructure to develop strategies to protect against and mitigate the 

effects of natural disasters or manmade attacks against critical 

communications infrastructure. As part of this function, NCS is working 

with industry to develop a risk assessment methodology for use in 

assessing the communications sector’s overall exposure including the 

threats, vulnerabilities, and consequences of an incident such as a natural 

disaster or man-made attack. 

Within NCS, the National Coordinating Center for Telecommunications 

(NCC), which serves as the operational component, is an industrygovernment collaborative body that coordinates the restoration and 

provisioning of NS/EP communications services during crises or 

emergencies.20 The NCC consists of officials from 24 government agencies 

and 49 companies including eight industry members that are co-located at 

the center (such as AT&T, Sprint, and Verizon) as well as nonresident 

members that comprise the telecommunications sector—wireless 

companies, cable companies, internet service providers, satellite 

providers, and communications equipment manufacturers and suppliers, 

among others. Since January 2000, the center also functions as the 

Telecommunications Information Sharing and Analysis Center to allow 

information sharing between representatives of the telecommunications 

companies. During a disruption to telecommunications services, the NCS, 

through the NCC, coordinates with both resident and nonresident 

members with the goal of restoring service as soon as possible. According 

to NCS, this partnership allows both industry and government to work in 

close proximity, helping to ensure that NCS successfully executes its 

mission. For example, during the 2008 hurricane season, the NCC worked 

 

19The National Infrastructure Protection Plan (NIPP), first released by DHS in 2006 and 

updated in 2009, is intended to integrate activities and strategies for the protection and 

continuity of critical infrastructure and key resources, such as communications 

infrastructure and networks, and outlines partnerships and responsibilities across federal, 

state, local, tribal, and private agencies. For example, federal agencies identified as the 

Sector-Specific Agency—the lead federal agency for a given sector’s protection—are 

responsible for, among other things, developing and implementing a Sector-Specific Plan to 

apply the NIPP to the unique characteristics and conditions of their sector. 

20NCS, through the NCC, manages the Telecommunications Service Priority program—a 

program that provides priority provisioning and restoration of telecommunications services 

that support emergency operations facilities for certain federal, state, and tribal 

governments, and other entities. For more information about this program, see appendix 

III. 

Page 12 GAO-09-822 National Communications System
 

with its government and industry partners to identify communications 

assets and infrastructure in the impacted areas and develop pre- and postlandfall strategies and response activities to help ensure availability of 

communications. 

In order to overcome network congestion, NCS has implemented priority 

calling programs to provide NS/EP personnel within all levels of 

government, as well as the private and non-profit sectors, with 

communications services during incidents of national security or 

emergency that can overwhelm the telecommunications network. 21 The 

two primary programs NCS provides to deliver priority calling are the 

Government Emergency Telecommunications Service (GETS) and the 

Wireless Priority Service (WPS). NCS has undertaken a number of 

outreach efforts to help increase participation in these priority calling 

programs and has designed controls to help ensure the use of these 

programs is only for authorized personnel and purposes. 

NCS Provides Priority 

Calling Services for 

NS/EP Personnel and 

Has Designed 

Mechanisms to 

Manage Access to 

These Services 

NCS’s Two Main Programs 

Provide Priority Calling for 

NS/EP Personnel in the 

Event of Network 

Congestion During 

Emergencies 

NCS has implemented two main programs intended to overcome busy 

networks during periods of congestion or network failure due to 

abnormally high usage or infrastructure damage; the GETS program 

provides wireline priority calling, and WPS provides wireless priority 

calling for authorized NS/EP officials. 

According to NCS, it established GETS in conjunction with the nation’s 

telecommunications industry to meet White House requirements for a 

nationwide voice and limited data service intended for authorized 

personnel engaged in NS/EP missions.22 GETS is designed to provide 

priority treatment in the wireline portions of the PSTN during an 

emergency or crisis situation when the PSTN is congested and the 

probability of completing a call by normal means has been significantly 

decreased. For example, during the 1995 Oklahoma City Bombing—one of 

 

21Priority calling is provided through special enhancements embedded in the PSTN and 

wireless networks to identify calls made by authorized users as a high priority. These 

enhancements automatically place the call higher in the queue and increase the probability 

that the call will be successfully completed over other calls made through traditional 

means. 

22GETS is designed to support low-speed data transmissions via facsimile machines or 

secure telephone equipment. Such data transmissions do not exceed 56 kilobytes which is 

equivalent to the speed for dial-up modems. 

Page 13 GAO-09-822 National Communications System
 

Illustration: The September 11, 2001, 

Terrorist Attacks

The September 11, 2001, terrorist attacks in 

New York City and the Washington, D.C., 

area inflicted extensive damage to 

telecommunications infrastructure and, 

combined with increased call volume, 

resulted in network congestion. While much 

of the infrastructure damage occurred in New 

York City, resulting in immediate service 

disruption in the disaster area, the attacks

also disrupted voice communications

nationally. When the collapse of the twin 

towers indirectly caused damage to a

telecommunications center owned by 

Verizon, about 182,000 voice circuits and 1.6 

million data circuits, among other things, 

were lost. In New York City, over 20 base 

stations in the immediate disaster area were 

damaged or destroyed, resulting in 

widespread cellular outages. Throughout the 

course of the day, heavy call volume across

the United States at times reached up to 250 

percent of normal levels and greatly 

overloaded the telecommunications

networks, according to NCS. These events

had a devastating effect on people’s ability to 

make calls into, within, and out of the 

immediate disaster areas. The network 

damage combined with increased call volume 

made it difficult for NS/EP officials in the New 

York and the Washington, D.C., areas to 

communicate using traditional calling 

methods in order to coordinate emergency 

response and recovery efforts. 

NCS describes the 2001 terrorist attacks as

the first large-scale emergency event in 

which the performance of GETS service was

tested. Despite the network congestion and 

damage, according to NCS, the GETS

service remained available and helped 

ensure that authorized NS/EP personnel had 

alternative means to communicate. For the 

period from September 11 to September 18, 

2001, NCS reports that more than 19,000 

calls were attempted of which 18,117 were 

successfully completed resulting in a call 

completion rate of 95 percent. NCS also 

reported that it distributed about 1,900 new 

GETS cards during the event. 

the earliest uses of GETS in an emergency event—a high call volume of 

three times more than the usual volume resulted in an overload of the 

telephone network in the Oklahoma City area, according to NCS. During 

this emergency event, officials from the federal government and the 

private sector were able to successfully complete about 300 calls using the 

GETS service. According to a senior official from the Florida Division of 

Emergency Management, GETS was also used in Florida during Hurricane 

Katrina. Prior to hitting the Gulf Coast, the hurricane made landfall in 

South Florida, damaging the communications infrastructure and resulting 

in network congestion that prevented Florida emergency management 

officials from completing calls. According to this official, GETS allowed 

Florida emergency management officials to circumvent the congested 

lines and successfully complete calls. 

To activate a GETS call, subscribers follow a three-step process similar to 

that of using a traditional calling card. First, subscribers must dial the 

universal access number by using equipment such as a standard desk 

phone, payphone, secure telephone, cellular phone, VoIP telephone, or 

facsimile. Next, a tone prompts the subscriber to enter their GETS 

personal identification number (PIN) found on the calling card distributed 

to the subscriber. (Figure 2 shows the GETS calling card that is provided 

to each authorized NS/EP subscriber.) Lastly, the subscriber is prompted 

to enter a destination telephone number. Once the calling party’s identity 

is authenticated (via the PIN), the call receives priority treatment that 

increases the probability of call completion in damaged or congested 

networks. GETS is designed to achieve a probability that 90 percent of 

calls made via the PSTN will be successfully completed—that is, establish 

a connection with the intended called party—during periods of network 

congestion or outage.23 The service achieves a high probability of call 

completion through a combination of features such as re-routing GETS 

calls around network blockage areas, routing calls to a second or third 

carrier if the first carrier’s network is congested, and queuing pending 

GETS calls for up to 30 seconds, among other things.24 Subscribers can 

 

23NCS describes a successful connection when using GETS as one in which the calling 

party gets (1) an answer by the called party, (2) a ring but no answer, or (3) a traditional 

busy signal. 

24Early in the GETS program, the number of calls successfully completed during the time 

immediately following emergency events varied, but as the program has matured, GETS 

has increasingly achieved or surpassed its intention to complete 90 percent of calls. See 

appendix IV for the number of calls completed during past emergency events since the 

1995 Oklahoma City bombing. 

Page 14 GAO-09-822 National Communications System
 

place local, long distance, and international calls; however, it is not 

possible to use GETS to dial a toll-free destination number.25 When using 

GETS, subscribers are billed by the wireline carrier at a rate of $0.07 to 

$0.10 per minute for calls within the United States and its territories.26 As 

of April 2009, the program had grown to more than 227,000 subscribers, 

according to NCS. 

Figure 2: GETS Calling Card 

Sources: GAO, NCS.

Front Back

As significant increases in wireless telephone subscribers occurred in the 

mid-1990s, the concept for a wireless priority capability first emerged, 

according to NCS; however, it was in the wake of the events of Tuesday, 

September 11, 2001, that the Executive Office of the President, through the 

National Security Council, directed NCS to implement a wireless priority 

capability. According to NCS, in the aftermath of the terrorist attacks, 

wireless carriers experienced significant difficulties trying to cope with 

the unprecedented call volume. The reported increase in the number of 

phone calls in the Washington, D.C., New Jersey, and New York City areas 

made between 9:00 a.m. and 12:00 p.m. was 2 to 10 times the number on an 

average Tuesday. The resulting effort became WPS, which is a 

 

25Most toll-free numbers translate to a traditional 10-digit toll number. As such, NCS 

encourages GETS subscribers to obtain the regular 10-digit toll number for organizations 

that they may need to coordinate with during emergencies. NCS defines international calls 

as those that occur outside the United States, Canada, and parts of the Caribbean. For such 

calls, international calling privileges are applied to a GETS card only upon request and 

priority treatment is limited to US telephone networks. For example, for an outbound 

international call, once the call leaves US telephone networks, it will no longer receive 

priority treatment. 

26For GETS calls made from, to, or between international locations, prevailing international 

calling rates apply. 

Page 15 GAO-09-822 National Communications System
 

Illustration: 2005 Gulf Coast Hurricanes

In August 2005 and September 2005, the Gulf 

Coast was struck by two hurricanes (Katrina

and Rita). On August 29, 2005, Hurricane 

Katrina made landfall in Louisiana and 

significantly damaged or destroyed the 

communications infrastructure in Louisiana, 

Mississippi, and Alabama. According to the 

FCC, the storm caused outages for over 3 

million telephone customers. A substantial 

number of central offices were flooded and 

consequently forced out of operation, 

according to NCS. Additionally, about 1,500 

cellular sites were damaged and subsequently unable to provide wireless service. 

NCS reported that the infrastructure damage 

caused by the hurricane was among the worst 

of any disaster in the nation’s history. 

Moreover, Hurricane Katrina was the first 

large scale test of WPS in an emergency 

event, according to NCS. Despite the 

destruction and damage, from August 29 to 

September 5, 2005, more than 27,000 GETS

and about 3,400 WPS calls were successfully 

completed achieving a call completion rate of 

95 and 89 percent respectively, according to 

NCS.

On September 24, 2005, Hurricane Rita made 

landfall between Sabine Pass, Texas, and 

Johnson’s Bayou, Louisiana. Although the 

storm disabled thousands of phone lines, 

Hurricane Rita did not cause the extensive 

damage that occurred during Hurricane 

Katrina. In contrast, the number of GETS calls

attempted was about 50 percent less than the 

totals for Hurricane Katrina. From September 

24 to September 29, 2005, 11,145 GETS calls

were attempted, of which approximately 

10,740 were successfully completed resulting 

in a call completion rate of about 96 percent. 

During the same period, of the 1,109 WPS

calls attempted, 983 were successfully 

completed resulting in a call completion rate 

of about 89 percent. According to NCS, the 

majority of GETS and WPS calls that failed 

during Hurricanes Katrina and Rita were 

largely a function of damaged infrastructure 

rather than network congestion.

subscription-based service designed to help increase the probability of call 

completion for NS/EP personnel that rely on wireless devices—typically, a 

cell phone27—while performing duties related to emergency response and 

recovery. To that end, WPS provides nationwide wireless priority calling 

capabilities, from call initiation through to when a connection is 

established with the called party, to NS/EP personnel during natural or 

man-made disasters or emergencies that result in network congestion or 

outages in the nation’s wireless networks. 

Like the average U.S. consumer, NS/EP personnel have great flexibility in 

choosing a wireless carrier for wireless communications services. In order 

to assure that WPS capabilities are accessible by the majority of wireless 

services that could be used by NS/EP personnel, NCS has taken steps to 

ensure that the nationwide and regional wireless carriers that provide 

services to the greatest number of wireless customers upgrade their 

networks to support WPS functionalities. As a result, authorized WPS 

subscribers are able to access WPS in nearly all the major wireless 

markets in the continental United States and its territories. Currently, WPS 

is supported by all the nationwide wireless carriers (AT&T, Sprint Nextel, 

T-Mobile, and Verizon Wireless). Additionally, regional carriers (such as 

Cellcom and Cellular South) that can help to provide WPS coverage in 

geographically remote or sparsely populated areas are at varying stages of 

updating their networks to support WPS. 

To initiate a WPS call, authorized subscribers must dial *272 plus the 

destination number from their WPS-enabled cell phone.28 If all radio 

channels in the caller’s area are busy, the call will be placed in queue for 

up to 28 seconds for access to the next available local radio channel. WPS 

subscribers receive additional priority based on their office or position to 

ensure that communications are first available for senior leadership (see 

app. V for a description of how this priority is determined). While WPS 

provides priority access to the next available radio channel, it does not 

guarantee call completion as a WPS call may encounter further congestion 

while being routed through the wireline or wireless portions of the PSTN. 

Therefore, according to NCS, WPS is most effective when used in 

conjunction with GETS because GETS is also designed to help activate 

 

27WPS functionality can also work in wireless devices such as a Blackberry provided the 

device has voice communications capability. 

28WPS can be used to place calls from a cell phone to another cell phone or a wireline 

telephone device. 

Page 16 GAO-09-822 National Communications System
 

Illustration: 2009 Presidential Inauguration

On January 20, 2009, about 2 million people 

attended the Presidential Inauguration held in 

Washington, D.C., to observe the swearing in 

of the 44th President of the United States. 

Because of the anticipated large crowds on 

the National Mall and immediate surrounding 

areas, as well as the presence of numerous

senior government officials in the D.C. area, 

the federal government worked with its

private sector partners to ensure the 

availability of communications during the 

inauguration activities. For example, in 

anticipation that observers would use cell 

phones and other wireless devices to 

communicate information and images of their 

experiences to family, friends, and television 

stations, NCS issued an advisory to GETS

and WPS subscribers informing them of 

potential delays in using wireless

communications and reminding them to use 

GETS and WPS if they have difficulty 

completing a call. NCS officials stated that 

from January 16 to January 20, 2009, they 

activated about 1,200 new GETS accounts

and 3,700 WPS accounts—the majority of 

which were for law enforcement personnel 

and staff for the incoming administration.

During the 24-hour period covering 

inauguration day there was a combined total 

of 1,429 GETS and WPS calls attempted. 

NCS officials stated that there was

unprecedented stress on cellular networks

resulting in extreme congestion and 

numerous incidents of blocked calls even 

though wireless carriers had deployed mobile 

cellular equipment in the event area to 

augment the capacity of their networks. Of 

the 771 GETS calls attempted, about 99 

percent were successfully completed, but of 

the 658 WPS calls attempted, 60 percent 

were successfully completed.

priority calling features in the wireless network in addition to the wireline 

network. Thus, using a GETS calling card after activating WPS can help to 

ensure a higher probability of call completion for calls placed from a 

cellular telephone to another cellular or wireline telephone number. 

As with GETS, WPS subscribers incur expenses as part of their 

subscription; however, the WPS fee structure is more expensive. In 

addition to wireless calling plan fees, WPS subscribers must pay (1) a onetime activation fee of up to $10.00, (2) a monthly service fee of up to $4.50, 

and (3) a $0.75 per minute fee when WPS is invoked by dialing the WPS 

code, *272. These fees help wireless carriers to recoup the costs 

associated with providing NS/EP calling features in their respective 

wireless networks, according to NCS. As of April 2009, there are 

approximately 93,000 WPS subscribers, according to NCS. 

Page 17 GAO-09-822 National Communications System
 

NCS priority calling programs are primarily intended for officials with 

responsibilities for coordinating the functions critical to the planning, 

management, and response to national security and emergency 

situations—particularly during the first 24 to 72 hours following an 

emergency.29 According to NCS, participants in its priority programs come 

from federal, state, local, or tribal government, and private industry or 

nonprofit organizations.30 In order to subscribe to GETS and WPS, 

applicants must prove that their organization is engaged in activities 

essential to NS/EP functions including (1) national security leadership; 

(2) national security posture and U.S. population attack warning;31 (3) 

public health, safety, and maintenance of law and order; (4) public welfare 

and maintenance of national economic posture; and (5) disaster recovery. 

Furthermore, these individuals must demonstrate that they perform a 

function that is critical to the planning, management, and response to 

national security and emergency situations. At the federal government 

level, personnel that qualify to subscribe to the GETS and WPS service 

range from staff in the Executive Office of the President to members of 

Congress and officials in federal departments and agencies. Nonfederal 

representatives such as state governors, mayors, police and fire chiefs, as 

well as personnel engaged in restoration of services such as 

telecommunications and electricity, are among those who can qualify to 

use the priority calling programs. Appendix V provides further details 

NCS Uses Outreach to 

Enlist Subscribers and Has 

Designed Controls to Help 

Ensure Priority Calling 

Services Are Used as 

Intended by Eligible 

Subscribers 

Priority Calling Programs 

Available to Diverse Groups 

with NS/EP Responsibilities 

 

29NCS programs are not for immediate, on-site emergency response, and are therefore not 

geared toward first responders, such as police, fire fighters, emergency medical personnel, 

and others who are among the first on the scene of an emergency. 

30Nonfederal subscribers must be sponsored by the NCS or one of the 24 NCS member 

agencies. 

31Population attack warning includes threat assessments and warnings of potential nuclear 

attacks, among other things, within the United States. 

Page 18 GAO-09-822 National Communications System
 

about the types of positions and functions that generally qualify for access 

to the GETS and WPS programs. 

According to NCS, the number of personnel in the public and private 

sectors that perform functions critical to national security and emergency 

preparedness range from about 2 to 10 million people. In planning for 

future growth in its programs, NCS estimates that the communications 

network can successfully support up to 2 million priority subscribers. To 

that end, NCS has plans underway to achieve up to 2 million GETS 

subscribers. NCS officials have not yet finalized this goal or a goal for WPS 

subscribers but indicated that the WPS goal may be about 225,000 

subscribers.32 As of April 2009, NCS has 227,614 active subscribers in the 

GETS program. For WPS, there were 92,820 active subscribers. As table 1 

shows, the federal government accounts for about 46 percent of active 

GETS subscribers and 72 percent of active WPS subscribers. 

Table 1: Participation Levels in the GETS and WPS Programs as of April 2009 

Category GETS subscribers WPS subscribers

Federal government 104,391 67,222

State government 25,969 4,464

Local government 48,348 9,054

Tribal government 82 4

Industry 47,509 12,010

Other NS/EP organizations 1,315 66

Total 227,614 92,820

Source: NCS. 

NCS has undertaken several outreach efforts to help increase awareness 

of and participation in its priority calling programs across essential NS/EP 

personnel. These efforts include, for example, attending emergency 

management conferences, writing articles for emergency management and 

telecommunications publications, as well as deploying outreach 

coordinators to promote NCS’s priority calling programs. For example, 

since 1995, NCS has participated in various conferences hosted by the 

National Emergency Management Association (NEMA) and the 

International Association of Emergency Managers to facilitate its outreach 

and marketing efforts. At these conferences, NCS operates display booths 

NCS Conducts Outreach to 

Enlist Subscribers, Although 

WPS Cost Can Be a Barrier to 

Participation 

 

32The process NCS used to establish these subscriber goals is discussed later in the report. 

Page 19 GAO-09-822 National Communications System
 

and distributes marketing materials and may conduct presentations to 

help increase awareness about the benefits of its priority calling programs. 

NCS officials and/or contract personnel attend approximately 30 

conferences annually that target federal, state, local, and industry NS/EP 

members. NCS officials told us that it has enlisted all but 1 of the 50 state 

emergency operations centers to participate in GETS and/or WPS because 

of initial contacts made at events hosted by NEMA. Similarly, to expand its 

outreach to other essential emergency personnel who also rely on wireline 

and wireless communications services during emergencies such as those 

from water, gas, and electric companies, NCS has attended conferences 

and other events that attract this target audience. 

In addition to attending conferences to reach general NS/EP personnel, 

NCS has implemented targeted outreach efforts to groups such as 

governors and state homeland security advisors; critical infrastructure 

facilities, such as nuclear power plant operations centers, national and 

regional airport traffic control centers; and federal officials who serve as 

the designated continuity coordinator within their respective agency. NCS 

officials report that they have generally made progress in enlisting these 

groups in its priority calling programs. For example, in 2008 NCS enlisted 

56 of 71 federal continuity coordinators in the GETS program. NCS also 

worked with the Nuclear Regulatory Commission and the Federal Aviation 

Administration to ensure that GETS cards are available at all nuclear 

facilities and at all national and regional airports respectively. In 2005, 

NCS began deploying regional outreach coordinators to promote NCS’s 

priority calling programs to emergency management officials and other 

key decision makers (such as governors) that coordinate emergency 

response and recovery and continuity of government in state and local 

government.33 NCS credits the addition of the regional outreach 

coordinators as a key reason for significant growth in enrollment rates 

across all NS/EP categories since 2005. 

Despite the outreach efforts NCS has undertaken to increase participation 

in its priority calling programs, WPS fees are a barrier to participation in 

the program, according to NCS. For example, as of October 2008, while 

the majority of federal continuity coordinators enrolled in the GETS 

program, only 44 percent or 31 of 71 federal continuity coordinators are 

 

33The regional outreach coordinators are not NCS staff but rather part-time staff hired by 

NCS’s contractor—Computer Sciences Corporation. Currently, there are six regional 

outreach coordinators. 

Page 20 GAO-09-822 National Communications System
 

WPS subscribers. Additionally, while 24 of 56 state homeland security 

advisors subscribe to GETS, only 10 subscribe to WPS, and only 8 

governors subscribe to WPS while 43 subscribe to GETS. The subscriber 

levels for the GETS program are more than twice that of the WPS program 

as shown in table 2. For each WPS-activated device, subscribers pay an 

initial activation fee of $10, a monthly fee of $4.50 as well as a usage fee of 

$0.75 per minute. In 2006, NCS commissioned a study to examine barriers 

to WPS participation, among other things. According to NCS, the survey 

results found that program cost was the single largest impediment to 

participating in WPS. Similarly, our work showed that WPS fees can be a 

burden particularly for NS/EP members at the state and local government 

level due to limited financial resources. At least one-third of 37 state and 

local government entities that we spoke with—including some who 

subscribe to WPS—stated that WPS fees affected the extent to which they 

participate in the program. For example, an official from the Oregon 

Emergency Management Division stated his organization’s participation in 

the WPS is relatively low because the overall WPS costs can become very 

expensive when calculated across all subscribers in a particular agency. 

Another official from Ohio Emergency Management Division stated that 

his organization does not participate in the program due to budget 

constraints even though they consider WPS to be more beneficial than 

GETS because the wireless component is more widely used among staff 

performing emergency management functions. 

Table 2: GETS and WPS Subscriber Rates and Program Fees 

Program 

Number of 

subscribers

(as of April 2009)

One-time 

activation fee Monthly fee Usage fee

GETS 227, 614 $0 $0 $0.07 to $0.10 

per minute

WPS 92,820 $10 per device $4.50 per 

device

$0.75 per minute

Source: NCS. 

In light of concerns about WPS subscription costs, NCS has been 

exploring ways to minimize the burden of program fees for its intended 

subscribers. For example, NCS examined the feasibility of the federal 

government subsidizing all or part of the WPS fees; however, DHS and 

OMB determined that this may not be feasible because of questions about 

the federal government’s ability to sustain these costs in the future. 

Further, NCS has had discussions with the wireless carriers to explore 

ways to eliminate or defray the costs; however, the wireless carriers 

Page 21 GAO-09-822 National Communications System
 

maintain that the fees are necessary to operate and maintain WPS 

capabilities in their networks in order to comply with the NCS 

requirements. Nevertheless, some carriers have made arrangements with 

WPS subscribers to provide WPS as part of a bundled telecommunications 

service package, which, according to NCS, can defray the costs. NCS 

officials have stated that they plan to continue to explore ways to address 

the WPS cost issue as it believes doing so can help increase participation 

in the WPS program. 

Federal internal control standards34 state that documented policies and 

procedures to control access to agency resources and records to 

authorized individuals are essential to accountability and safeguarding 

assets, and NCS has developed and implemented policies and procedures 

to help ensure that access to its programs is limited to authorized 

subscribers. NCS has standard operating procedures that document how 

potential subscribers can gain access to its priority calling programs. To be 

approved for a GETS card and/or WPS service request, the NCS contractor 

must be able to confirm that the request is from an organization that 

performs any of five NS/EP functions mentioned earlier in this report. If 

the organization’s NS/EP status is unclear (such as chemical suppliers, 

radio and TV stations, or housing shelters), the organization must obtain 

sponsorship from NCS, 1 of the 24 NCS member agencies, or through the 

emergency management agency in the state or locality in which they 

operate. Once approved,35 the organization must identify a primary pointof-contact (POC) and an alternate POC, if available. Within each 

organization, the POC is the primary liaison between NCS and individual 

GETS and WPS subscribers. The POC is responsible for (1) determining 

who should have access to the GETS and WPS service within their 

organization;36 (2) processing all GETS and WPS service requests; (3) 

notifying NCS of changes to subscriber account data such as changes in 

name, telephone number, or eligibility status; (4) reviewing and certifying 

monthly subscriber calling data; (5) familiarizing subscribers with GETS 

NCS Has Designed Procedures 

and Controls to Limit Access to 

Authorized Subscribers 

 

34GAO/AIMD-00-21.3.1. 

35According to NCS, approximately 4 percent of the GETS and WPS service requests are 

denied because the requesting organization does not have a function that is clearly related 

to NS/EP and most often are industry organizations that provide services that are only 

tangentially related to NS/EP functions. 

36According to NCS guidance, access should be limited to staff who have a clearly defined 

NS/EP duty. 

Page 22 GAO-09-822 National Communications System
 

and WPS functionalities,37 and (6) annual verification of subscriber 

eligibility. 

As evidenced by their responsibilities, NCS relies on the POCs to manage 

almost all aspects of subscriber accounts. However, through an annual 

verification process, NCS seeks to ensure that POCs provide a current 

account of subscribers who meet the eligibility requirements. NCS will 

make multiple attempts over a 90-day period to ensure the POC responds 

to its request to validate subscriber information, according to NCS officials 

and failure to do so can result in cancellation of the subscribers’ account. 

NCS officials told us that they designed these verification procedures to 

help ensure that only eligible subscribers have access to NCS’s priority 

programs. From our review of selected GETS and WPS records as a 

limited check on whether current positions meet eligibility criteria, we 

found that the GETS and/or WPS accounts for former members and 

delegates of the U.S. House of Representatives and the U.S. Senate in the 

109th Congress were terminated in accordance with NCS’s procedures. 

However, when we reviewed accounts for 15 immediate past heads of 

federal departments and agencies as of August 2008, we found 4 of 15 

instances where these officials’ GETS and/or WPS accounts were not 

terminated. We brought this to NCS’s attention and officials told us that 

these accounts were terminated effective July 2009. Further, NCS plans to 

institute new processes that are to include more frequent monitoring of 

GETS and WPS accounts that coincide with administration changes to 

ensure that the subscriber’s account status is appropriately updated. 

In addition to verifying whether a subscriber is authorized to enroll in 

NCS’s programs, telephone carriers as well as NCS and its contractors 

have applied fraud detection mechanisms intended to protect against 

fraudulent calls in their networks as well as others that are unique to the 

GETS and WPS services. For example, carriers have fraud detection for 

general telephone use that also detects fraud for GETS and WPS services. 

These detection mechanisms include detection of a single PIN being used 

simultaneously from multiple originating phone numbers and calls of long 

duration, among other things. NCS and its contractor said that they have 

also instituted procedures to determine the legitimacy of calls and to take 

 

37In addition to the POC’s responsibilities to familiarize subscribers, NCS has incorporated 

priority calling programs in several training or preparedness exercises that it conducts or 

participates in with the goal of keeping subscriber’s knowledge of the services current 

because of concerns that subscribers may not be readily prepared to effectively use GETS 

and WPS during an emergency. 

Page 23 GAO-09-822 National Communications System
 

corrective action, which may include disabling the GETS and WPS account 

in question. According to NCS, it has rarely found actual cases of fraud 

and abuse. For example, although there were 45 reported cases of 

potential fraudulent calls in 2008, through further investigation NCS 

determined that the calls were legitimate and the reports typically resulted 

from calls placed by authorized subscribers conducting test calls or 

participating in preparedness exercises. Even if fraudulent calls were 

made using GETS and WPS services, the implications would likely be 

minimal due to two factors. First, the subscriber levels for GETS and WPS, 

which currently stand at more than 227,000 and about 93,000 respectively, 

are well below the capacity of the system. For example, according to NCS, 

the GETS system was designed to support up to 2 million subscribers, 

however, the current subscriber level—227,000 GETS subscribers—is well 

below the intended capacity. Second, the potential financial implications 

for the federal government would be nominal as NCS does not bear the 

costs for GETS and WPS charges for nonfederal subscribers. State and 

local governments as well as private and nonprofit organizations bear all 

of the costs related to the usage of the GETS and WPS programs. In 

general, NCS may cover GETS charges for federal departments and 

agencies up to an annual budget threshold; however, federal agencies may 

be responsible for these costs in the event of fraudulent or abusive calling 

activity. Federal and nonfederal WPS subscribers are responsible for all 

associated costs. 

The delivery of NCS’s priority calling services faces challenges related to 

the inherent vulnerabilities of the communication infrastructure such as 

downed phone lines, damaged cell towers, and broken circuits and 

switches. Therefore, NCS seeks to build redundancy into the 

communication capabilities and services it provides and has explored 

satellite technology to overcome such challenges. However, methods for 

implementation and evaluation of its related satellite pilot were unclear 

and NCS subsequently terminated the pilot. In addition, NCS faces the 

challenge of keeping pace with the rapid evolution in telecommunications 

technology and it is working with the telecommunications industry to 

ensure that NS/EP communications requirements are integrated into the 

next-generation communications networks. However, NCS’s planning 

efforts to update its programs as technology evolves could be 

strengthened. 

Initiatives Exist to 

Address Challenges in 

NCS’s Operating 

Environment, but 

Planning Efforts to 

Leverage Evolving 

Technology Could Be 

Strengthened 

Page 24 GAO-09-822 National Communications System
 

In December 2007, NCS launched a satellite pilot program to provide an 

alternative means to support NS/EP communications to help circumvent 

network congestion or outages in the PSTN. According to NCS, because 

GETS and WPS leverage PSTN-based infrastructure to enable 

communications for NS/EP personnel, these programs can be limited in 

their ability to provide services when damage renders the PSTN 

infrastructure inoperable, such as it did in certain regions affected by 

Hurricane Katrina. In February 2004, the National Security 

Telecommunications Advisory Council (NSTAC) issued a report to the 

Executive Office of the President recommending that NCS develop a 

satellite capability to facilitate NS/EP communications. The 

communications challenges that arose during the 2005 Gulf Coast 

hurricanes due to flooding and loss of power, among other things, 

underscored the need for a communications capability that could 

transcend these infrastructure issues, and NCS observed that satellite 

networks appeared to be the least disrupted communications service 

during this event. To that end, 3 years following the 2005 Gulf Coast 

Hurricanes, NCS launched the first of two phases of the satellite pilot 

program intended to enable unclassified voice connectivity during 

emergencies that leverages satellite infrastructure independent of the 

PSTN. As part of the pilot, according to NCS officials, NCS is to provide 

participants with a wall-mounted unit that consists of battery backup and 

surge protection and a satellite phone. According to NCS officials, one 

objective of the pilot is to evaluate two voice communications capabilities 

via satellite technologies: push-to-talk communication functions and GETS 

priority calling using a satellite phone. Push-to-talk is a radio-like function, 

similar to that of a walkie-talkie or three-way radio, with which a group of 

users would connect back-and-forth with each other from their individual 

satellite phones at the push of a button without having to make individual 

calls.38 NCS also plans to use the pilot to test the ability to make GETS 

priority functions to call a wireline or cellular telephone number using a 

satellite phone. According to NCS, calls made from a satellite phone to a 

cellular or wireline telephone can bypass congested or damaged areas of 

the PSTN, as such calls can be routed via satellite networks to a less 

congested area of the PSTN, thus increasing the likelihood of call 

completion. However, because these calls are still expected to travel 

NCS Launched the Satellite 

Pilot Program without 

Clear Methods for 

Implementation and 

Evaluation and Has Since 

Terminated the Pilot 

 

38This group of users is known as a talkgroup. The radio users are structured into 

talkgroups so that they can share calls and messages as a group. Satellite radio talkgroups 

allow authorized NS/EP users to participate in a nationwide two-way satellite 

communications whereby each group member can either listen to or join in the 

conversation taking place over the talkgroup. 

Page 25 GAO-09-822 National Communications System
 

through the wireline and wireless portions of the PSTN to reach their 

destination, they could face congestion while trying to connect to the 

PSTN. To bypass such congestion, NCS officials stated that the GETS 

priority calling features must be supported on the satellite networks, 

which currently they are not. By inserting priority calling functionality in 

satellite networks, GETS calls that originate from a satellite phone will 

have a greater likelihood of being successfully routed through the PSTN in 

times of network congestion. NCS officials also told us that other 

objectives for the pilot include determining the extent to which satellite 

communications meet NS/EP needs and educating NS/EP personnel about 

the availability of satellite communications for use in emergency 

situations. 

Although the pilot began in December 2007 and is estimated to last 3 years 

and cost $1.9 million, as of May 2009 NCS could provide little 

documentation to explain its objectives for the pilot, and how it planned to 

meet those objectives. For example, while NCS officials provided briefing 

slides to elaborate on the pilot program and describe some high-level 

program objectives, these slides lacked key program information such as a 

methodology for evaluating pilot results to determine whether the 

intended pilot objectives were met, and milestones for pilot 

implementation. Specifically, although the briefing slides noted the 

planned number of sites to be included in the pilot, it did not specify when 

the site selection would be completed, when sites would begin 

participating in the pilot, or the data that would be collected and analyzed 

to evaluate pilot performance. According to NCS, the pilot was to include 

up to 65 participating sites comprising emergency operations centers 

supporting federal and state government, and NCS officials stated they had 

initially identified six sites and conducted an evaluation of additional 

candidate sites. However, NCS officials could not provide any detailed 

information about what criteria or rationale was used to determine which 

sites to include in the pilot.39 For instance, while NCS officials told us they 

evaluated sites based on two factors (effects of disaster scenarios and 

population served by the respective location), they did not provide any 

documentation that outlined these details or demonstrated how these two 

factors would help it determine if the pilot objectives were met. In 

addition, as part of phase two of the satellite pilot, NCS officials said they 

 

39The six participating sites include the operations centers operated by (1) NCS, (2) the 

three major nationwide carriers (AT&T, Sprint, and Verizon), and (3) NCS’s contractors 

that support GETS and WPS (Computer Sciences Corporation and Science Applications 

International Corporation). 

Page 26 GAO-09-822 National Communications System
 

intended to use lessons learned from the experience of phase one of the 

pilot to migrate the satellite capability to another NCS technology 

initiative already underway; however, NCS launched the pilot program 

without the benefit of completing a methodology to evaluate the pilot. In 

addition, NCS could not provide documentation as to how the results of 

the pilot would be evaluated and used to inform future program decisions 

such as future rollout. Exacerbating the absence of program planning 

documents, is that key staff originally involved in the pilot have since left 

NCS resulting in the loss of institutional knowledge about the original 

decisions and planning for the pilot. 

In April 2009, officials told us that the pilot had been placed on hold as 

they were reassessing various aspects of the pilot such as conducting a 

cost-benefit analysis to determine which satellite provider and equipment 

to use. After reassessing the pilot, NCS subsequently terminated the pilot 

in May 2009, according to NCS officials. NCS officials acknowledged that 

the pilot program needed improved planning and metric documentation 

and noted that NCS took a number of issues into consideration including 

the current availability of push-to-talk capability among existing satellite 

service providers in making the decision to end the pilot. 

NCS Is Restructuring 

Efforts to Keep Pace with 

Emerging 

Telecommunications 

Technology, but Further 

Development of Plans and 

Program Details Would 

Better Inform Program and 

Budget Decisions 

NCS is mandated by presidential directive to support the use of 

technological advances and evolutionary communications networks for 

NS/EP communications functions assigned to NCS, including programs it 

provides to maintain continuity of communications.40 GETS and WPS are 

designed to operate on the circuit-based PSTN platform, while packetbased IP networks are increasingly used and expected to eclipse the use of 

circuits in telecommunications, according to representatives from the 

telecommunications industry. As a result, NCS and its GETS and WPS 

subscribers face the risk that these services will not work within these 

next-generation networks. To avoid disruption or degradation of service, 

NCS plans to migrate existing GETS and WPS priority calling features 

from circuit-based networks to public telephone packet-based networks to 

assure that the programs will be operable on new technologies available 

 

40Executive Order 12,472, which outlines the responsibilities of the NCS as it relates to 

NS/EP communications, states that NCS shall develop for consideration a recommended 

evolutionary telecommunications architecture designed to meet the current and future 

NS/EP telecommunications requirements and shall ensure that current and future 

telecommunications standards are utilized as the basis for the federal telecommunications 

standards. 

Page 27 GAO-09-822 National Communications System
 

from wireline and wireless carriers.41 NCS’s efforts to integrate new and 

existing NS/EP services into next-generation networks (NS/EP NGN) 42

consist of two primary components: (1) priority voice communications 

and (2) priority data communications that includes priority treatment for 

the transmission of e-mail, streaming video, text messaging, and Internet 

access, among other things. 

NCS has taken steps to assess how the evolution of technology will affect 

the provision of its priority calling services and to plan for these changes. 

In addition, because NCS’s programs are largely dependent on the 

telecommunications industry, which owns and operates most of the 

communications infrastructure on which GETS and WPS operate, NCS has 

partnered with industry to inform and implement these changes. 

According to NCS, adding the priority voice communications component 

of NS/EP NGN is less challenging than adding data services because while 

priority calling programs exist (GETS and WPS), priority data programs do 

not. NCS officials estimate that at least one of the three major carriers 

(AT&T) will begin supporting priority communications via VoIP by 2010 

and the remaining carriers (Sprint and Verizon) by 2014. However, less is 

known about supporting priority data communications and, consequently, 

this effort is more challenging, according to NCS officials. 

The challenge to develop priority data services is not a new issue; in 2006 

we reported that the obstacles to offering the service include both 

technical and financial challenges.43 For example, the commonly used 

version of Internet protocol (known as IPv4) does not guarantee priority 

delivery and has certain security limitations that may not adequately 

protect information from being monitored or modified while in transit via 

the Internet. Though the next version (IPv6) has features that may help 

prioritize the delivery of data in the future and provide enhanced security, 

it is not yet widely adopted. Also, in March 2006, the NSTAC reported that 

while the NS/EP NGN initiative is expected to offer improvements for 

NS/EP communications, the security challenges are likely to have an 

operational impact on the transmission of NS/EP communications if not 

 

41According to industry experts, current and next-generation networks will operate in 

parallel until the circuit-based portion of the PSTN is phased out. 

42For the purposes of this report, we refer to NCS’s efforts to plan for and implement these 

NS/EP voice and data services on the next-generation networks as the NS/EP NGN. 

43GAO-06-672. 

Page 28 GAO-09-822 National Communications System
 

adequately addressed.44 Specifically, they noted that robust user 

authentication methods are needed in order to enable NS/EP personnel to 

share information in a secure manner. While these authentication methods 

are to be available through IPv6, they are not available through IPv4, 

which is the more widely used version. In April 2009, NCS officials told us 

they have not yet finalized what types of authentication methods or which 

IP version would support the NS/EP NGN, though they plan to request 

additional information from industry experts about how to address 

authentication issues. In our 2006 report, we noted that NCS had 

previously requested information from private companies on the potential 

for prioritizing services, and found that there was no offering for a priority 

service, nor was there any consensus on a standard approach to 

prioritization. Although, NCS, in conjunction with international standards 

bodies, completed the first set of engineering standards for priority VoIP in 

December 2007, as of May 2009, standards had not yet been established to 

support prioritized NS/EP NGN data communications.45 Moreover, NCS 

could not provide further detail as to how its planning efforts account for 

the different capabilities of the available technology, and the associated 

challenges. 

In addition to NCS not fully detailing how it plans to mitigate existing 

challenges, it also could not provide details about key program elements 

such as, the estimated total costs, and a timeline for implementation of the 

NS/EP NGN initiative. Officials said the information was not yet finalized. 

Our previous work on acquisition and technology investment management 

has shown that undertaking such efforts is strengthened by first ensuring 

that (1) an acquisition approach, such as the one for NS/EP NGN, is based 

on available technologies that support the intended capability; (2) cost 

estimates are realistic; and (3) risks have been identified and analyzed, and 

corresponding mitigation plans have been developed.46 NCS officials told 

 

44National Security Telecommunications Advisory Committee, Next Generation Networks 

Task Force Report, March 28, 2006. 

45The international standards bodies involved in this effort include the Alliance for 

Telecommunications Solutions, The European Telecommunications Standards Institute’s 

Telecoms and Internet Converged Services and Protocols for Advanced Networks, 

International Telecommunication Union-Telecommunication Standardization Sector, The 

Internet Engineering Task Force, and The Third Generation Partnership Project. 

46GAO-07-424; Department of Homeland Security: Billions Invested in Major Programs 

Lack Appropriate Oversight, GAO-09-29 (Washington, D.C.: November 18, 2008); and 

Defense Acquisitions: Restructured JTRS Program Reduces Risk, but Significant 

Challenges Remain, GAO-06-955 (Washington, D.C.: September 2006). 

Page 29 GAO-09-822 National Communications System
 

us they planned to develop program plans that included this information, 

but as of May 2009 these documents were in the early stages of 

development, and officials stated they were finalizing cost and schedule 

estimates for the initiative, which may be greater than previously 

projected. In addition, for the last 2 years, Congress has raised questions 

about the absence of detailed program information such as costs of 

planned investments for some of NCS’s programs, and NCS has faced 

difficulties in justifying its budget requests. For example, during the 

appropriations process for fiscal years 2008 and 2009, the House and 

Senate Committees on Appropriations raised questions about the intended 

investments in NS/EP NGN. Because of the lack of explanation about the 

significant increase in funds requested for fiscal year 2008 compared to the 

previous year, the House and Senate Committees on Appropriations stated 

that NCS had not adequately justified funding for the NS/EP NGN effort.47

Consequently, Congress appropriated $21 million—about 60 percent less 

than requested—to DHS for NS/EP NGN.48 In addition, the House of 

Representatives Committee on Appropriations directed DHS to brief them 

on the planned expenditures for NS/EP NGN in fiscal year 2008.49 Again, 

for the fiscal year 2009 budget request for NS/EP NGN, the House of 

Representatives Committee on Appropriations raised questions about the 

lack of a thorough explanation of (1) information about planned 

investments, (2) clarity about how the initiative aligns with DHS’s 

homeland security goals, and (3) information about the total costs to 

complete the initiatives.50 As a result, Congress withheld half of the fiscal 

year 2009 funding for NS/EP NGN until NCS completes an expenditure 

plan to be approved by the House and Senate Committees on 

Appropriations that identifies the strategic context, specific goals and 

milestones, and planned investments.51 Although NCS had planned to 

submit the expenditure plan to the Committees on Appropriations in 

 

47In fiscal year 2008, DHS requested about $52 million for the NS/EP NGN initiative—a 270 

percent increase over the $14 million provided in fiscal year 2007. See, H.R. Rep. No. 110-

181, at 85 (2007) and S. Rep. No. 110-84, at 85-86 (2007). 

48Consolidated Appropriations Act, 2008, Pub. L. No. 110-161, 121 Stat. 1844 (Dec. 26, 2007). 

See also, House Appropriations Committee Print for the Consolidated Appropriations Act, 

2008. 

49H.R. Rep. No. 110-181, at 85 (2007). 

50H.R. Rep. No. 110-862, at 97, 100 (2008). 

51Department of Homeland Security Appropriations Act, 2009, Pub. L. No. 110-329, 122 Stat. 

3652, 3668 (2008) enacted as Division D of the Consolidated Security, Disaster Assistance, 

and Continuing Appropriations Act, 2009, Pub. L. No. 110-329, 122 Stat. 3574. 

Page 30 GAO-09-822 National Communications System
 

January 2009, they have not done so, and as of May 2009, the plan was still 

being reviewed internally.52

Based on technological and planning challenges, NCS officials told us that 

in 2008 it began taking steps to restructure its acquisition approach to 

focus first on voice with data to follow much later. However, as noted by 

Congress in its response to NCS’s fiscal year 2009 budget request, little is 

known about this restructuring, including key program information such 

as what capabilities will be delivered, total costs, and milestones. 

Moreover, despite requirements from Congress to articulate its strategy for 

the NS/EP NGN initiative, as of May 2009 NCS had not yet clearly defined 

program objectives and total costs, among other things. While NCS 

officials told us that they expect increased costs and schedule delays, they 

have not provided any further details or plans to mitigate these challenges, 

and it is unclear when important technological and program details of the 

restructuring will be finalized. In February 2009, NCS hired a new manager 

whose responsibilities include NS/EP NGN, who stated the need to plan 

for these issues and develop corresponding program plans that outline the 

NS/EP NGN acquisition approach including costs, milestones, and risk 

mitigation plans. 

GAO and commercial best practices show that incorporating cost 

information and strategies to mitigate program and technical challenges 

are essential to successfully meeting program objectives and minimizing 

the risk of cost overruns, schedule delays, and less than expected 

performance.53 As NCS moves forward with the NS/EP NGN effort, clearly 

defining and documenting its technical approach to achieve program 

objectives within the constraints imposed by known challenges—such as 

the limitations of available technologies and NCS’s dependence on the 

telecommunications industry—could help provide reasonable assurance 

that an executable approach is in place to meet current and future NS/EP 

communications needs. Furthermore, such planning could provide a 

sound basis for determining realistic cost and schedule estimates and 

provide key stakeholders such as Congress with information they need to 

make funding decisions over time. 

 

52Although Congress did not set a deadline for DHS to submit the expenditure plan, DHS 

officials told us they planned to submit the plan by January 2009 to avoid delays in moving 

forward with planned activities. 

53GAO-09-29 and GAO-06-955. 

Page 31 GAO-09-822 National Communications System
 

NCS Has 

Implemented 

Strategic Planning 

Efforts, but These 

Could Be 

Strengthened by 

Incorporating Key 

Planning and 

Performance 

Measurement 

Practices 

NCS has been developing its strategic plan since 2007, and although 

officials have stated that a strategic plan could help inform their efforts, it 

has not been finalized. In addition, while NCS has generally linked the 

performance of its programs to broader agency and department goals, the 

performance of two of NCS’s core responsibilities is not measured. Finally, 

focusing program evaluation efforts on outcomes, gauging progress, 

incorporating past performance, and clarity can improve the usefulness of 

NCS’s performance measures. 

NCS Has Been Developing 

a Strategic Plan since 2007, 

but It Has Not Been 

Finalized and Could Be 

Strengthened with Key 

Planning Practices 

NCS has undertaken strategic planning for its programs and documented 

some key elements of strategic planning—such as a statement of the 

agency’s mission, strategic goals, and objectives—across a range of 

documents and sources. For example, the mission statement is 

documented in program documents such as NCS’s Annual Reports, and 

NCS officials told us they have identified 21 strategic objectives that align 

with its three strategic goals (information on the three strategic goals and 

some of the related objectives is shown in table 3). However, this 

information has not been incorporated into a strategic plan. Furthermore, 

NCS officials stated that these goals and objectives are being revised, but 

they did not provide a date when this would be finalized. Additionally, 

NCS’s congressional budget justification documents for fiscal years 2007 

through 2009 contain planned milestones and spending for various 

program initiatives. 

Page 32 GAO-09-822 National Communications System
 

Table 3: NCS’s Strategic Goals and Select Objectives 

NCS Strategic Goals Select NCS Objectives 

Ensure performance of priority communications 

services during normal and stressed emergency 

situations 

Ensure availability of the 

communications infrastructure 

to support NS/EP requirements 

Enhance existing NS/EP communication capabilities

Serve as the lead agency for Emergency Support 

Function 2 (ESF-2) in support of the National 

Response Plan 

Enhance and maintain NCS 

operational preparedness for 

effective and timely response 

and recovery to national 

emergencies Build on the strategic outreach and communication 

program to continue to raise awareness about NCS 

and NSTAC programs and activities 

Serve as the sector-specific agency for the 

telecommunications sector 

Provide leadership in Critical 

Infrastructure Protection (CIP) as 

the telecommunications SectorSpecific Agency Work with industry and other sector-specific 

agencies to improve communications assurance 

and preparedness 

Source: NCS. 

In June 2008, we reported that efforts were under way to draft a strategic 

plan for the NCS, and recommended that DHS establish milestones for 

completing the development and implementation of the strategic plan.54

DHS agreed with our recommendation and stated that it was taking steps 

toward finalizing the strategic plan. However, as of April 2009, the plan, 

which has been in draft since mid-2007, had not yet been finalized and 

NCS officials could not provide a date for when this would occur. A draft 

strategic plan for fiscal years 2007 to 2013 did not include some of the key 

elements associated with effective strategic plans. For example, while the 

plan included NCS’s mission, strategic goals and high-level objectives, it 

did not include a discussion of the resources needed to achieve these 

goals and objectives. Although NCS intends to enhance its priority 

communications offerings to keep pace with emerging technology (such as 

priority data in an IP environment), it has not yet finalized the total costs 

to do so. In addition, the draft plan did not identify external factors that 

could affect achievement of strategic goals (such as management or 

 

54GAO, Critical Infrastructure Protection: Further Efforts Needed to Integrate Planning 

for and Response to Disruptions on Converged Voice and Data Networks, GAO-08-607 

(Washington, D.C.: June 26, 2008). The NCS strategic plan is to be part of an overarching 

strategy for all the entities that comprise the Office of Cyber Security and Communications 

that also includes the National Cyber Security Division and Office of Emergency 

Communications. 

Page 33 GAO-09-822 National Communications System
 

technological challenges). Moreover, the plan did not articulate how 

current and planned initiatives such as the NS/EP NGN and the satellite 

pilot program fit into the broader agency goals. 

Our past work has discussed the importance of strategic planning as the 

starting point for results-oriented management.55 Strategic plans are to 

articulate the mission of an organization or program, and lay out its longterm goals and objectives for implementing that mission, including the 

resources needed to reach these goals. Leading management practices 

state that federal strategic plans include six key elements: (1) a 

comprehensive mission statement, (2) strategic goals and objectives, 

(3) strategies and the various resources needed to achieve the goals and 

objectives, (4) a description of the relationship between the strategic goals 

and objectives and performance goals, (5) an identification of key external 

factors that could significantly affect the achievement of strategic goals, 

and (6) a description of how program evaluations were used to develop or 

revise the goals and a schedule for future evaluations.56 As we have 

previously reported, strategic plans are strengthened when they include a 

discussion of management challenges facing the program that may 

threaten its ability to meet long-term, strategic goals.57

While NCS has completed some key aspects of strategic planning, critical 

elements such as the key external factors that could affect achievement of 

its mission—for example, challenges affecting the NS/EP NGN initiative—

have not yet been documented and NCS has not committed to 

incorporating these elements in its strategic plan. A strategic plan that 

captures these key elements in a centralized way would help inform 

stakeholders, such as departmental leadership, Congress, and the 

administration about NCS’s priorities and plans and assist stakeholders in 

making efficient and effective program, resource, and policy decisions. In 

addition, because NCS has experienced frequent turnover in leadership, 

such a plan would be beneficial for new agency management during 

transition periods. For example, since January 2007, there have been two 

directors and one acting director as well as three different staff serving in 

 

55GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

56 Government Performance and Results Act of 1993 and OMB Circular A-11provide 

guidance in this instance since NCS’s strategic plan is not an agency-wide strategic plan. 

57GAO, Managing for Results: Critical Issues for Improving Federal Agencies’ Strategic 

Plans, GAO/GGD-97-180 (Washington, D.C.: September 16, 1997). 

Page 34 GAO-09-822 National Communications System
 

the capacity of Chief for the Technology and Programs Branch—a position 

that oversees the day-to-day operations regarding NS/EP NGN, among 

other initiatives. 

NCS’s Performance 

Measures Are Generally 

Linked to Broader Agency 

and Department Goals and 

Objectives, but Measures 

Do Not Cover All Core 

Program Activities 

NCS has five performance measures which relate to three aspects of GETS 

and WPS—the number of subscribers, priority call completion rates in 

emergencies, and cost to support GETS and WPS subscribers. While NCS 

has not documented how its performance measures link to NCS’s and 

DHS’s strategic goals and objectives, we used various documents, such as 

DHS’s fiscal year 2008 to 2013 strategic plan, to determine that NCS’s five 

performance measures link to agency and department strategic goals and 

objectives (see figure 3, which illustrates the connection between DHS’s 

mission to NCS’s performance measures). For example, NCS’s 

performance measure to track the call completion rate of priority calls is 

linked to its strategic goal of ensuring availability of communications as 

well as to DHS’s strategic objective to ensure continuity of government 

communications. Consistent with our past work on performance 

management, linking performance measures with strategic goals and 

objectives in this way provides managers and staff with a roadmap that 

shows how their day-to-day activities contribute to achieving broader DHS 

and NCS goals.58

 

58GAO, Homeland Security: Guidance and Standards are Needed for Measuring the 

Effectiveness of Agencies’ Facility Protection Efforts, GAO-06-612 (Washington, D.C.: May 

31, 2006). 

Page 35 GAO-09-822 National Communications System
 

Figure 3: Linkages between NCS Performance Measures and NCS and DHS Strategic Goals and Objectives 

Source: GAO analysis of DHS and NCS data.

Call completion rate 

for priority calling 

services

NCS

Performance 

Measures

Number of WPS

subscribers

Number of GETS

subscribers

Percent of federal 

continuity coordinators

with access to priority 

calling services

Average cost to 

maintain a subscriber 

to priority calling 

services

Protect nation from 

dangerous people

DHS Strategic 

Goals Protect nation from 

dangerous goods

Protect critical 

infrastructure

Strengthen nation’s

preparedness and 

emergency response 

capabilities

Strengthen and unify 

DHS operations and 

management

Assist the President, the National Security Council, the Homeland Security Council, the Director of the Office of Science and 

Technology Policy and the Director of the Office of Management and Budget in: (1) the exercise of the telecommunications

functions and responsibilities; and (2) the coordination of the planning for and provision of national security and emergency 

preparedness communications for the Federal government under all circumstances, including crisis or emergency, attack, 

recovery and reconstitution.

NCS Mission

Ensure Continuity of Government Communications and Operations: Implement continuity of operations planning at key 

levels of government. Improve our ability to continue performance of essential functions/business and government operations, 

including the protection of government personnel, facilities, national leaders, and the Nation’s communications infrastructure 

across a wide range of potential emergencies.

Select DHS

Strategic 

Objective

Lead the unified national effort to secure America; prevent and deter terrorist attacks and protect against and respond to threats

and hazards to the Nation; secure the national borders while welcoming lawful immigrants, visitors, and trade.

DHS Mission

Ensure availability of the 

communications infrastructure to 

support NS/EP requirements

NCS Strategic 

Goals Enhance and maintain NCS

operational preparedness for 

effective and timely response and 

recovery to national emergencies

Provide leadership in critical 

infrastructure protection as the 

telecommunications Sector Specific 

Agency

While NCS’s performance measures generally link to overall goals and 

objectives, NCS’s performance measures focus exclusively on its priority 

calling programs, and NCS does not have measures to assess the 

performance of its other two primary responsibilities—serving as the ESF2 coordinator and the lead federal agency for critical infrastructure 

protection for the communications sector. Although NCS officials 

Page 36 GAO-09-822 National Communications System
 

acknowledged that they do not have such measures and noted that they 

could be helpful, these officials did not commit to developing such 

measures. While we have previously reported that agencies do not need to 

develop performance measures that cover all of their activities, OMB 

requires that performance measures reflect a program’s mission and 

priorities.59 Furthermore, we have also reported that an agency’s 

performance measurement efforts are strengthened when they sufficiently 

cover its core activities.60 NCS’s critical infrastructure protection and ESF2 responsibilities are key components of the agency’s mission to help 

ensure that NS/EP communications are available during disasters or 

emergencies, and are articulated in NCS’s strategic goals (see table 3). For 

example, NCS, in conjunction with the telecommunication industry is 

responsible for conducting risk assessments of the nation’s critical 

communication infrastructure; according to Executive Order 13,231, as 

amended, communications infrastructure is critical not only to emergency 

preparedness, but all aspects of U.S. national security and economy. 

Without the benefit of performance measures that cover these functions, 

NCS may be limited in its ability to assess its overall effectiveness in 

meeting all three of its strategic goals. Moreover, developing performance 

measures for these mission-critical functions would help strengthen and 

inform future program and budget decisions, improve critical program 

activities, and as we have previously reported, help verify that NCS’s 

resources are being used responsibly.61

 

59GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: November 22, 2002); and OMB, 

Guide to the Program Assessment Rating Tool (Washington, D.C., January 2008). 

60GAO-03-143. 

61GAO-06-612. 

Page 37 GAO-09-822 National Communications System
 

Of its five performance measures, NCS has identified two as outcome 

measures, two as output measures, and one as an efficiency measure (see 

table 4 for more information on each of these measures).62 While OMB 

guidance defines output measures (such as the number of products or 

services delivered) as a description of the level of activity provided over a 

period of time, it asserts program performance is most effectively 

measured by focusing on how those outputs support the achievement of 

desired outcomes—the intended results of carrying out a program or 

activity.63 NCS’s two output measures—the number of GETS subscribers 

and the number of WPS subscribers—could be strengthened to focus on 

outcomes, more effectively gauge progress toward achieving results, and 

set more reliable targets. In addition, one of NCS’s outcome measures, the 

call completion rate, does not clearly illustrate the measures’ intended 

purpose. OMB guidance emphasizes the use of outcome measures as a 

more meaningful indicator of performance and encourages agencies to 

translate existing measures that focus on outputs into outcome measures, 

or at least demonstrate that measured outputs would logically lead to 

intended outcomes. Currently, neither of NCS’s output measures fully 

demonstrates how it supports NCS in the achievement of the intended 

outcomes of the GETS and WPS programs, which, as articulated in one of 

NCS’s strategic goal, is to ensure the availability of communications 

capabilities for all NS/EP officials. For example, NCS told us that the longterm goal for the GETS program may be to reach 2 million subscribers; 

however, NCS has not demonstrated how reaching 2 million subscribers 

achieves the result of ensuring the availability of communications 

capabilities for NS/EP officials that could benefit from the use of the GETS 

service. According to NCS officials, NCS based this number on an internal 

study that identified 2 million subscribers as the capacity level that the 

PSTN can support. However, NCS could not provide a rationale as to how 

2 million subscribers appropriately quantifies the population of NS/EP 

personnel critical to NCS achieving its desired results. Therefore, it is 

unclear whether achieving 2 million GETS subscribers means that all the 

NS/EP personnel who have the greatest need for access to priority calling 

capabilities are enlisted in the program thereby enabling them to make 

calls that can help to coordinate planning for national security incidents 

and emergencies and facilitate continuity of government under these 

Focusing on Outcomes, 

Progress, and Past 

Performance to Set 

Performance Targets and 

Clarity Can Improve the 

Usefulness and Reliability 

of Performance Measures 

 

62OMB defines an efficiency measure as one that captures a program’s ability to carry out 

its activities and achieve results (an outcome or output) relative to resources (an input 

such as cost). 

63OMB, Guide to the Program Assessment Rating Tool. 

Page 38 GAO-09-822 National Communications System
 

conditions—a key function of the GETS program. In addition, NCS 

officials have told us that the agency has an unofficial long-term goal of 

225,000 subscribers for the WPS program. Although NCS officials noted 

that this number has not been finalized, the measure also does not portray 

how well or if WPS is achieving its desired program outcome. 

Furthermore, NCS has not been able to provide information regarding how 

it developed this WPS subscriber goal or describe how it will do so in the 

future. 

Table 4: NCS’s Performance Measures, Targets, and Results for Fiscal Years 2006 to 2009 

Performance measure Description 

FY 2006 

target

FY 2006 

results

FY 2007 

target

FY 2007 

results

FY 2008 

target 

FY 2008 

results

FY 2009 

target

Priority service call 

completion rate during 

emergency 

communication periods 

Measures the call 

completion rate for 

GETS, WPS, and a 

classified priority calling 

program during 

emergency 

communication periods. 

The call completion rate 

is defined as the 

number of successful 

calls made divided by 

the total number of calls 

originated. A successful 

call is one in which the 

user (1) gets an 

answer, (2) a ring but 

no answer, or (3) a 

traditional busy signal. 

a

a 90% 94% 90% 97% 90%

Number of WPS 

subscribers 

Measures the total 

number of subscribers 

who are authorized to 

use the Wireless 

Priority Service. 

30,000 38,594 39,000 47,214 57,000 85,076 68,500

Number of GETS 

subscribers 

Measures the total 

number of subscribers 

registered to use the 

GETS program. 

118,000 158,669 155,000 168,428 185,000 208,600 204,000

Percent of Federal 

Continuity Coordinators 

with access to priority 

telecommunications 

services 

Measures the 

percentage of federal 

continuity coordinators 

that are registered to 

use the GETS program. 

b b b b 80% 81% 90%

Page 39 GAO-09-822 National Communications System
 

Performance measure Description 

FY 2006 

target

FY 2006 

results

FY 2007 

target

FY 2007 

results

FY 2008 

target 

FY 2008 

results

FY 2009 

target

Average cost to 

maintain priority 

telecommunications 

service subscribers 

Measures the average 

cost to NCS to maintain 

subscribers in the 

GETS and WPS 

programs, as well as a 

classified priority calling 

program. 

c c $21.00 $17.00 $15.63 $13.70 $14.22

Source: NCS. 

a

Data not available as NCS implemented this performance measure in fiscal year 2007. 

b

Data not available as NCS implemented this performance measure in fiscal year 2008. 

c

Data not available as NCS implemented this performance measure in fiscal year 2007. 

Our past work, along with federal guidance, has discussed the importance 

of using a series of output and outcome goals and measures to depict the 

complexity of the results that agencies seek to achieve.64 We recognize 

that it can be difficult to develop outcome goals and corresponding 

measures. Nonetheless, by further articulating how NCS’s measures 

support the intended outcome articulated in its strategic goal—ensuring 

availability of communications for NS/EP functions—, NCS and its 

stakeholders could more effectively gauge the extent to which subscriber 

levels in GETS and WPS reflect if communications capabilities are 

available to all critical NS/EP personnel as intended. 

 

NCS’s progress can be better measured through annual performance 

targets that track subscriber levels to demonstrate how overall subscriber 

goals for GETS and WPS lead to program outcomes. This would help to 

better illustrate NCS’s annual progress toward achieving its desired 

results. Furthermore, although both of NCS’s output measures reflect the 

number of subscribers in each program for a given year, the measures do 

not reflect whether NCS’s annual achievement demonstrate significant or 

marginal progress toward reaching 2 million subscribers, and NCS has not 

defined a time by which it hopes to achieve this goal. In its GETS and WPS 

performance measures, NCS states annual results as an output of the 

number of subscribers in a particular year—for example, 208,600 GETS 

subscribers in fiscal year 2008. These output measures do not capture 

percentage increases in the number of subscribers from year to year to 

help measure performance changes in achieving any long-term goal for 

subscribers. According to OMB guidance, performance over time is to be 

64GAO/GGD-96-118, and OMB, Guide to the Program Assessment Rating Tool. 

Page 40 GAO-09-822 National Communications System
 

expressed as a tangible, measurable objective, against which actual 

achievement can be compared, such as a quantitative standard, value, or 

rate.65 For example, for NCS’s performance measure related to the percent 

of federal continuity coordinators with access to priority calling 

programs—NCS tracks change over time by showing a rate of annual 

progress toward enlisting these particular officials in the GETS and WPS 

programs. In doing so, NCS can provide insight as to the extent to which 

this group can successfully place calls to help facilitate continuity of 

government at the federal level—particularly in the event of network 

congestion during emergencies.66 Although NCS has reported ongoing or 

planned targeted outreach efforts to similar groups that play a leadership 

role in coordinating emergency response and continuity of government 

such as governors or mayors, they have not developed similar 

performance measures to track their annual progress in enlisting and 

maintaining these subscribers. NCS has not finalized its overall goal for the 

number of GETS and WPS subscribers or set a timeline for when it plans 

to achieve its unofficial goals for the number of GETS and WPS 

subscribers. Based on GETS enrollment levels over the last 3 fiscal years, 

at current rates NCS may not achieve its unofficial subscriber goals until 

somewhere between 2015 and 2047. OMB guidance states that 

performance goals are to be comprised not only of performance measures 

and targets, but also include time frames for achieving these goals.67

In addition, OMB guidance states that targets are to consider past 

performance, adjusted annually as conditions change, such as funding 

levels and legislative constraints. However, NCS did not consider past 

performance when setting annual performance targets for several of its 

performance measures. As a result, the targets are not ambitious or based 

on reliable baselines. For example, NCS did not modify its targets for the 

number of GETS subscribers for fiscal years 2007 and 2009 based on 

actual results achieved in the previous fiscal year. According to OMB 

performance guidance, baselines are the starting point from which gains 

 

65OMB, Guide to the Program Assessment Rating Tool. 

66Federal continuity coordinators as defined in the National Continuity Policy are staff 

designated within federal departments and agencies, at the Assistant Secretary level, to 

coordinate their agency’s continuity of operations requirements which includes the 

availability of critical communications capabilities, among other things. Because this 

performance measure was introduced in fiscal year 2008, we could not evaluate how useful 

this measure has been in gauging progress over time. 

67OMB, Guide to the Program Assessment Rating Tool. 

Page 41 GAO-09-822 National Communications System
 

are measured and targets set; and performance targets are to be ambitious. 

Our past work has also emphasized the importance of baselines and 

multiyear goals particularly when results are expected to take several 

years to achieve.68 As detailed in table 4, for fiscal year 2006, NCS reported 

a target of 118,000 GETS subscribers and achieved 158,669, which also 

surpassed its 2007 goal. However, NCS did not update its fiscal year 2007 

goal of 155,000 when it was achieved in 2006. Similarly, in fiscal year 2008, 

NCS set a target of 185,000 subscribers and achieved 208,600 subscribers, 

which surpassed the fiscal year 2009 goal. However, as of April 2009, the 

goal remained at 204,000 subscribers even though NCS exceeded this level 

in the previous fiscal year. Similarly, the target level for another 

measure—the average cost to maintain a priority telecommunications 

service subscriber—has not been modified to reflect the actual results of 

the prior year. NCS began using this measure in fiscal year 2007 and has 

exceeded its target reductions in cost for the 2 years that the measure has 

been in place. For fiscal years 2008 and 2009, the average cost targets were 

$15.63 and $14.22, respectively; however, NCS reported that the average 

cost to maintain a priority service subscriber in 2008 was $13.70, 

surpassing targeted reductions for both 2008 and 2009. As with the target 

for the subscriber measures, the average cost target was not modified to 

build upon actual results of the prior fiscal year. Furthermore, the baseline 

upon which each annual average cost goal is determined is the number of 

GETS and WPS subscribers. While officials cite reductions in operating 

costs as one reason for exceeding the target, they also stated that the 

achievement was more a function of the fact that they exceeded the 

projected number of GETS subscribers. As a result, because the annual 

GETS subscriber performance measure is not composed of ambitious 

targets from year to year, the baseline it provides for determining the 

average cost target is unreliable. Without considering changes in this 

baseline information—in this case, number of subscribers—valid 

comparisons to measure improvement over time cannot be made. 

Considering past performance in setting targets could help NCS develop a 

true sense of continued improvement in enlisting priority service 

subscribers and reducing costs to service the subscribers. 

Finally, while NCS has implemented an outcome-oriented measure to 

assess the effectiveness of its priority calling programs during periods of 

 

68GAO, Agency Performance Plans, Examples of Practices That Can Improve Usefulness 

to Decisionmakers, GAO/GGD-AIMD-99-69 (Washington, D.C.: February 26, 1999); and 

GAO/GGD-96-18. 

Page 42 GAO-09-822 National Communications System
 

congestion, the information the measure intends to convey—priority 

service call completion rate—is not consistent with the methodology used 

to calculate the results. Specifically, the measure is intended to capture 

and measure combined call completion rates for GETS and WPS. 

However, wireless carriers collect the relevant information that NCS 

reports via this measure, and under current processes for capturing 

attempted WPS calls, wireless carriers are unable to identify all attempted 

WPS calls that are not completed.69 Our previous work holds that 

performance measures should be clearly stated in order to ensure that the 

name and definition of the measure are consistent with the methodology 

used to calculate it.70 Furthermore, OMB guidance states that agencies are 

required to discuss the completeness and reliability of their performance 

data, and any limitations on the reliability of the data. As the call 

completion measure does not provide clear information about program 

performance and limitations, NCS risks overstating the completion rate for 

WPS and the use of this measure may affect the validity of managers’ and 

stakeholders’ assessment of WPS performance in comparison to the 

intended result. NCS officials agreed that opportunities exist to strengthen 

this measure to ensure that it accurately reflects the activity being 

measured, and stated they are taking steps to work with carriers that 

support WPS services to develop a solution that would allow them to track 

the full range of WPS calls. However, in the meantime, NCS has not 

committed to revising the measure to accurately reflect the activity being 

monitored. 

The events of September 11, 2001, and the 2005 hurricane season 

dramatically demonstrated how catastrophic man-made and natural 

disasters can disrupt communication capabilities and highlight the need 

for essential NS/EP officials to be able to communicate during and in the 

aftermath of such events. NCS continues to recognize the need to keep 

pace with technological changes and look for ways to better meet NS/EP 

personnel’s current and future communications needs as evidenced by the 

development of its NGN initiative. Information such as costs, available 

Conclusions 

 

69When a WPS user attempts to place a call, the call can be dropped—or incomplete—at 

several stages. The manner in which wireless carriers are currently able to identify 

incomplete calls occurs only for calls that have reached the mobile switching center. 

However, those WPS calls that have reached the base station, but failed to reach the mobile 

switching center, would not be captured as an incomplete call. 

70GAO-03-143. 

Page 43 GAO-09-822 National Communications System
 

technology, and future capabilities for these types of initiatives are 

unknown, and as such require thoughtful planning to most effectively 

allocate current and future resources. These efforts to ensure that the 

communication capabilities it provides to NS/EP personnel will be 

operable on and leverage next-generation networks could benefit from 

better planning. By clearly defining its acquisition approach for the 

initiative and developing mitigation plans to address known risks and 

technical challenges, NCS can help minimize cost overruns and schedule 

delays, and more importantly help ensure that it is developing services that 

meet the emerging communication needs of the NS/EP community. 

Strategic plans are an essential element in results-oriented program 

management, and provide agencies and stakeholders a common set of 

operational principles with which to guide actions and decisions. Although 

DHS stated that it was taking steps to finalize its strategic plan in response 

to our June 2008 recommendation, it has not yet finalized the plan which 

has been in draft since mid-2007 or committed to incorporating key 

elements of a strategic plan. We continue to believe that our prior 

recommendation has merit and that NCS could benefit from completing a 

strategic plan. A strategic plan that includes identifying strategic goals and 

objectives, the resources needed to achieve those goals and objectives, 

and a description of the relationship between planned initiatives and 

strategic goals could serve as the foundation to help NCS align its daily 

activities, operations, program development, and resource allocation to 

support its mission and achieve its goals. As NCS undertakes a variety of 

new initiatives and attempts to strengthen existing programs, finalizing its 

strategic plan will also help strengthen NCS’s ability to efficiently and 

effectively allocate resources, inform key stakeholders, and provide 

agency and congressional decision makers the ability to assess NCS’s 

programs and initiatives. 

As part of strategic planning, it is important that related performance 

measures are linked and support NCS strategic goals, as well as DHS’s 

strategic goal of ensuring continuity of communications. In the absence of 

performance measures for the key functions NCS performs as the lead for 

the federal government’s efforts to protect critical communications and as 

the coordinator for ESF-2, NCS cannot reasonably measure or 

demonstrate how these core program activities are contributing to 

achieving all three of its strategic goals and DHS’s overall mission of 

providing continuity of communications. For a performance measure to be 

used effectively, it is essential that a measure’s definitions, and its 

intended use, are consistent with the methodology used to calculate it. 

While NCS acknowledges that its primary performance measure for its 

Page 44 GAO-09-822 National Communications System
 

priority calling programs—call completion rate—does not capture all WPS 

calls completed and is exploring ways to capture the full spectrum of 

uncompleted, by not revising the measure in the meantime to accurately 

portray what is being measured, NCS continues to inaccurately measure 

performance and provide potentially misleading information to decision 

makers. Similarly, by not adjusting the performance targets that intend to 

measure number of subscribers and average costs to build upon and 

reflect previous years’ results, NCS cannot make valid comparisons to 

measure improvement over time, and cannot ensure whether performance 

goals are reasonable and appropriate. Beyond adjusting targets for the 

number of subscribers, opportunities exist to make these measures more 

outcome oriented to reflect the progress in reaching NCS’s ultimate goals 

for the number of subscribers to its GETS and WPS programs. However, 

without clearly defining or demonstrating how its ultimate subscriber 

goals achieve the result of ensuring the availability of communications 

capabilities for NS/EP personnel who need these services, it will remain 

difficult to measure progress. To its credit, NCS has identified federal 

continuity coordinators as critical NS/EP personnel needing access to its 

programs and has developed an outcome measure to track progress in 

enlisting and maintaining this group of subscribers. However, without 

similar measures for other groups that play a significant role in 

coordinating emergency response and continuity of government, NCS will 

not be in a position to evaluate its efforts to reach out, target, and 

ultimately provide priority calling programs to these groups. 

To help ensure that NCS management has sufficient information needed to 

assess and improve NCS’s programs and new initiatives and to effectively 

support budget decisions, we recommend that the Secretary of DHS direct 

the Manager of the NCS to take the following three actions: 

Recommendations for 

Executive Action 

• Develop program plans for the NS/EP NGN initiative that outline an 

acquisition approach based on available technologies, realistic cost 

estimates, and that include mitigation plans to address identified 

challenges and risks. 

• Follow best practices for strategic planning in finalizing the NCS strategic 

plan including identifying the resources needed to achieve its strategic 

goals and objectives and providing a description of the relationship 

between planned initiatives such as the NS/EP NGN and strategic goals. 

• Strengthen NCS’s performance measurement efforts by (1) developing 

measures to cover all core program activities, (2) exploring opportunities 

to develop more outcome-oriented measures, (3) ensuring performance 

Page 45 GAO-09-822 National Communications System
 

measure baselines are reliable and based upon past performance, (4) and 

improving the clarity of its call completion measure. 

We provided DHS a draft of this report for review and comment. DHS 

provided written comments on August 7, 2009, which are summarized 

below and presented in their entirety in appendix VI. DHS also provided 

technical comments, which we incorporated where appropriate. 

Agency Comments 

and Our Evaluation 

DHS disagreed with the recommendation in our draft report that it develop 

an evaluation plan for its satellite program that includes milestones for 

continued implementation and a methodology for assessing the results of 

the pilot before moving forward with the program. Specifically, DHS noted 

that the pilot program, which was on hold at the time of our review, was 

now complete. However, at the conclusion of our field work, our 

understanding from the NCS Director was that the pilot was on hold and 

that NCS was reassessing various aspects of the pilot such as conducting a 

cost-benefit analysis to determine which satellite provider and equipment 

to use. In light of this discrepancy, we subsequently obtained clarification 

on the status of the pilot. Our discussion with DHS revealed that the pilot 

program was terminated rather than completed. In providing clarification, 

DHS stated that it agreed with our assessment that the pilot program 

needed improved planning and metrics documentation and that NCS took 

a number of issues into consideration including the current availability of 

push-to-talk capability among existing satellite service providers to 

determine whether the pilot should be continued. Given these 

considerations, as well as the issues that we identified such as lack of 

program objectives, documentation and metrics, NCS terminated the pilot. 

According to NCS, about $900,000 had already been spent or obligated to 

support various activities for the pilot program. According to NCS 

officials, the remaining $1 million for the pilot will be reprogrammed and 

any funds that had already been obligated but not yet spent will be 

deobligated and also reprogrammed for other priority communications 

services. Thus, based on the termination of the pilot, we withdrew our 

recommendation and have modified our report to reflect the current status 

of the pilot. 

DHS concurred with our recommendation that it develop program plans 

for the NS/EP NGN initiative that outline an acquisition approach based on 

available technologies, realistic cost estimates, and that include mitigation 

plans to address identified challenges and risks. Although it concurred 

with our recommendation, DHS also reported that NCS currently follows a 

structured approach in the design and implementation of program plans 

Page 46 GAO-09-822 National Communications System
 

and that it assesses industry trends to help determine program 

enhancements and mitigation plans. Developing program plans for the 

NS/EP NGN initiative as we recommended can help NCS minimize cost 

overruns and schedule delays and help ensure that it is developing 

services that meet the needs of the NS/EP community. 

DHS concurred with our recommendation that NCS follow best practices 

for strategic planning in finalizing the NCS strategic plan including 

identifying the resources needed to achieve its strategic goals and 

objectives and providing a description of the relationship between planned 

initiatives, such as the NS/EP NGN, and strategic goals. DHS stated that 

all NCS activities are directly linked to its mission and associated 

performance measures. Finalizing its strategic plan as we have 

recommended will help provide decision makers with information to help 

them assess NCS’s programs and initiatives. 

With regard to our recommendation that NCS strengthen its performance 

measurement efforts by (1) developing measures to cover all core program 

activities, (2) exploring opportunities to develop more outcome-oriented 

measures, (3) ensuring performance measure baselines are reliable and 

based upon past performance, and (4) improving the clarity of its call 

completion measure, DHS concurred. Specifically, DHS reported that NCS 

will continue to develop performance measures. Taking action to 

strengthen its performance measures as we recommended should help 

NCS improve its ability to evaluate its efforts to reach out, target, and 

provide priority calling programs. 

DHS also commented on the report’s discussion of subscriber database 

accuracy, stating that it disagreed with what it viewed as our assertion that 

NCS should be able to easily determine whether certain individuals 

serving in public positions were still entitled to be GETS subscribers, as 

well as our expectation that NCS terminate access for individuals 

regardless of whether the subscriber’s organization has notified NCS to do 

so. DHS also highlighted the steps that NCS takes to help ensure agency 

points of contact keep NCS’s subscriber database updated. We modified 

the report to better recognize the role agency Points of Contacts play in 

updating NCS’s database. 

DHS also noted that the report suggested that NCS’s outreach efforts are 

limited to a select number of activities and noted that NCS also meets with 

other governmental bodies. We have modified our report to clarify the 

discussion that these are examples of outreach efforts that are not 

intended to be inclusive of all of NCS’s efforts. 

Page 47 GAO-09-822 National Communications System
 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretary of Homeland Security, and any other interested parties. In 

addition, this report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-8777, or jenkinswo@gao.gov. Contact points for 

our Office of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

Appendix VII. 

Sincerely yours, 

s, Jr. 

Director, Homeland Security and Justice Issues 

William O. Jenkin

Page 48 GAO-09-822 National Communications System
Appendix I: The NCS Organization Structure Appendix I: The NCS Organization Structure 

The National Communications System (NCS) was established by a 

memorandum signed by President Kennedy in 1963, in the wake of the 

communications challenges that arose during the Cuban Missile Crisis 

when, according to NCS, delays in sending and receiving communications 

between the United States and foreign governments involved in the crisis 

threatened to further complicate the crisis. The original memorandum 

which has been amended and superseded over time, called for establishing 

a national communications system by linking together, and improving the 

communications assets of various federal agencies.1

 Such a system is to 

provide the necessary communications for the federal government under 

all conditions ranging from normal conditions to domestic emergencies 

and international crises. Today, Executive Order 12,472 is the primary 

federal guidance in force that dictates the composition and functions of 

the NCS. Executive Order 12,472 defined the NCS as those 

telecommunications assets owned or leased by the federal departments, 

agencies, or entities that comprise the NCS that can meet the national 

security and emergency preparedness (NS/EP) needs of the federal 

government together with a management structure that could ensure that 

a national telecommunications infrastructure is developed that is 

responsive to NS/EP needs, among other things. Executive Order 12,472 

which was amended by Executive Order 13,286 on February 28, 2003, 

provided that NCS’s mission is to assist the President, the National 

Security Council, the Homeland Security Council,2

 the Directors of the 

Office of Science and Technology and Office of Management and Budget 

in, among other responsibilities, “the coordination of the planning for and 

provision of NS/EP communications for the Federal government under all 

circumstances, including crisis or emergency, attack, recovery, and 

reconstitution.” 

The NCS organization structure largely consists of federal entities. 

However, the telecommunications industry serves in an advisory capacity 

to the federal government on matters regarding NS/EP communications. A 

description of the roles and responsibilities of the entities that comprise 

the NCS organization follows. See figure 4 for an illustration of the current 

NCS management structure. 

 

1

Congressional Research Service, John Moteff, Computer Security: A Summary of Selected 

Federal Laws, Executive Orders, and Presidential Directives, RL32357 (Apr. 16, 2004). 

2

On May 26, 2009, the President announced the full integration of White House staff 

supporting national security and homeland security. 

Page 49 GAO-09-822 National Communications System 
Appendix I: The NCS Organization Structure 

• Executive Office of the President (EOP). Within the EOP, the National 

Security Council (NSC), the Homeland Security Council (HSC), the Office 

of Science and Technology Policy (OSTP), and the Office of Management 

and Budget (OMB) have varying responsibilities for setting the policy 

direction for NS/EP communications and providing oversight of the NCS.3

For example, in consultation with the Executive Agent and a group of 

federal telecommunications officers (known as the NCS Committee of 

Principals), the EOP helps to determine NS/EP telecommunications 

requirements. 

• NCS Executive Agent. Pursuant to the Homeland Security Act of 2002, the 

functions and responsibilities of the NCS Executive Agent were 

transferred to the Secretary of Homeland Security.4

 Among other things, 

the Executive Agent is responsible for ensuring that the NCS conducts 

unified planning and operations, in order to coordinate the development 

and maintenance of an effective and responsive capability for meeting the 

domestic and international NS/EP telecommunications needs for the 

federal government as well as ensuring coordination with emergency 

management activities of the Department of Homeland Security (DHS). 

Additionally, the Executive Agent designates the NCS Manager and 

oversees related activities including the delivery of priority 

communications programs (such as Government Emergency 

Telecommunications Service (GETS) and the Wireless Priority Service 

(WPS)). 

• Office of the Manager, NCS. The Office of the Manager, NCS (OMNCS) 

falls under the Office of Cyber Security and Communications which is part 

of the National Protection and Programs Directorate within DHS. The 

responsibilities of the NCS Manager include, among other responsibilities, 

preparing for consideration by the NCS Committee of Principals and the 

Executive Agent: 

• recommendations on an evolutionary telecommunications architecture 

to meet current and future NS/EP needs; and 

• plans and procedures for the management, allocation and use, 

including the establishment of priorities or preferences, of federally 

owned or leased telecommunications assets under all conditions of 

crisis or emergency. 

 

3

Executive Order No. 12,472, 49 Fed. Reg. 13,471 (April 3, 1984). 

4

Pub. L. No. 107-296, § 201, 116 Stat. 2135, 2145-49 (2002). 

Page 50 GAO-09-822 National Communications System
Appendix I: The NCS Organization Structure 

Additionally, the NCS Manager is responsible for implementing and 

administering any approved plans or programs as assigned, including any 

system of priorities and preferences for the provision of communications 

service, in consultation with the NCS Committee of Principals and the 

Federal Communications Commission (FCC), to the extent practicable or 

otherwise required by law or regulation. Further, the NCS Manager is to 

conduct technical studies or analyses for the purpose of identifying 

improved approaches which may assist in fulfilling NS/EP 

telecommunications objectives, among other things. Additionally, in 

consultation with the NCS Committee of Principals and other appropriate 

entities of the federal government, the NCS Manager is to ensure that, 

where feasible, existing and evolutionary industry, national, and 

international standards are used as the basis for federal 

telecommunications standards. The OMNCS also includes the National 

Coordinating Center—a joint industry-government entity—which assists in 

coordinating the initiation and restoration of NS/EP communications 

services and is involved in critical infrastructure protection of 

telecommunications assets. 

• NCS Committee of Principals. According to NCS, this collaborative body, 

chaired by the NCS Manager comprises of the key telecommunications 

officers of those agencies designated by the President that own or lease 

telecommunications assets of significance to national security or 

emergency preparedness, and other executive entities which bear policy, 

regulatory, or enforcement responsibilities of importance to NS/EP 

telecommunications capabilities. Currently, the NCS Committee of 

Principals includes representatives from 24 federal departments and 

agencies—known as the NCS Member Agencies.5

 In accordance with 

Executive Order 12,472, the NCS Committee of Principals, among other 

things, provides comments and recommendations to the National Security 

Council, the Director of OSTP, the OMB Director, the NCS Executive 

 

5

These entities include the Department of State (DOS), the Central Intelligence Agency 

(CIA), the Department of the Treasury (Treasury), the Federal Emergency Management 

Agency (FEMA), the Department of Defense (DOD), the Joint Staff (JS), the Department of 

Justice (DOJ), the General Services Administration (GSA), the Department of the Interior 

(DOI), the National Aeronautics and Space Administration (NASA), the Department of 

Agriculture (DOA), the Nuclear Regulatory Commission (NRC), the Department of 

Commerce (DOC), the National Security Agency (NSA), the Department of Health and 

Human Services (DHHS), the National Telecommunications and Information 

Administration (NTIA), Office of the Director of National Intelligence (ODNI), the 

Department of Transportation (DOT), the United States Postal Service (USPS), the 

Department of Energy (DOE), the Federal Reserve Board (FRB), the Department of 

Veterans Affairs (VA), the FCC, and DHS. 

Page 51 GAO-09-822 National Communications System
Appendix I: The NCS Organization Structure 

Agent, or NCS Manager regarding ongoing or prospective activities of the 

NCS. According to NCS, the NCS Committee of Principals, in accordance 

with its bylaws, has established subgroups such as the NCS Council of 

Representatives to help support the work activities of the NCS. Further, 

the NCS Committee of Principals established other groups such as the 

Priority Services Working Group to analyze the potential impact of future 

technologies on priority services programs and examine the outreach 

efforts for the GETS and WPS programs, among other things. 

• The National Security Telecommunications Advisory Committee (NSTAC). 

The NSTAC was established in 1982 by Executive Order 12,382 to serve as 

an advisory committee to the President on matters related to NS/EP 

communications and may comprise of no more than 30 industry leaders 

appointed by the President. The NSTAC members are usually chief 

executive officers, from the telecommunications companies, network 

service providers, information technology firms, finance, and aerospace 

companies.6

 As we previously reported, over the course of its longstanding 

relationship with the NSTAC, the NCS has worked closely with NSTAC 

member companies during emergency response and recovery activities 

following a terrorist attack or natural disaster. 7

 For example, after the 

September 11, 2001, terrorist attacks, NSTAC member companies 

immediately coordinated with NCS to assist with communication 

restoration efforts despite the fact that some of their network 

infrastructure had been among the most severely damaged. As we have 

previously reported, the NCS and NSTAC share information on a variety of 

issues including federal policies related to NS/EP communications and 

changes in the telecommunications marketplace. The NSTAC has also 

issued multiple reports addressing a wide range of policy and technical 

issues regarding communications, information systems, information 

assurance, critical infrastructure protection, and other NS/EP 

communications concerns. For example, in 2006, NSTAC issued a report 

that identified challenges related to NS/EP communications and provided 

recommendations to the President intended to help ensure that next 

generation network initiatives meet NS/EP user’s need, among other 

 

6

As of May 2009, the NSTAC is comprised of representatives from the following companies: 

AT&T, Bank of America, Computer Sciences Corporation, Boeing Company, Harris 

Corporation, Intelsat General, Juniper Networks, Lockheed Martin, Microsoft, Motorola, 

National Cable and Telecommunications Association, Nortel, Qwest, Raytheon Company, 

Rockwell Collins, Science Applications International Corporation, Telcordia Technologies, 

Teledesic, Tyco Electronics, United States Telecom Association, Verisign, and Verizon. 

7

GAO-06-672. 

Page 52 GAO-09-822 National Communications System
Appendix I: The NCS Organization Structure 

things.8 As provided under Executive Order 12,382, the NSTAC has 

established subgroups such as the Industry Executive Committee to help it 

carry out its functions.9

 it 

Figure 4: NCS Management Structure 

9

Direction 

Coordination

Advice

Source: NCS.

Secretary of Homeland Security 

NCS Executive Agent

NCS Committee of

Principals

NCS Council of

Representatives

Working Groups

National Security

Telecommunications

Advisory Committee

Government Arm Industry Arm

Industry Executive

Subcommittee

Task Forces and

Ad Hoc Groups

Executive Office of the President 

Office of the Manager, NCS (OMNCS)

Manager, NCS

Deputy Manager, NCS

Deputy Manager, NCS and Director

OMNCS Staff

NCS Member Agencies

DOS

DOC

CIA

NTIA

TREAS

DHHS

FEMA

NSA

DOD

DOT

JS

USPS

DOJ

DOE

GSA

FRB

DOI

VA

NASA

FCC

USDA

DHS

NRC

ODNI

HSC NSC OMB OSTP

 

8

 The President’s National Security Telecommunications Advisory Committee, Next 

Generation Network Task Force Report, (March 28, 2006). 

9

These subgroups may be composed, in whole or in part, of individuals who are not 

members of the NSTAC. 

Page 53 GAO-09-822 National Communications System
Appendix II: Objectives, Scope and 

Methodology 

Page 54 GAO-09-822 

Appendix II: Objectives, Scope and 

Methodology 

To analyze the extent to which the National Communications System 

(NCS) provides priority communications programs, we reviewed relevant 

legislation, regulations and other documentation that outline NCS 

responsibilities in ensuring the continuity of communication including the 

Homeland Security Act of 2002, Executive Orders 12,472 and 13,231, and 

NCS Directive 3-10. We also reviewed budget requests, annual reports, the 

Performance Assessment Rating Tool (PART) reports submitted to the 

Office of Management and Budget (OMB),1

 and other documentation 

related to NCS activities. We also obtained and reviewed relevant agency 

documents such as internal briefings, program planning documents, and 

standard operating procedures that describe how Government Emergency 

Telecommunications Service (GETS) and the Wireless Priority Service 

(WPS) operate and the capabilities that each program delivers. We 

obtained information on the mechanisms NCS utilizes to collect, track and 

analyze the performance of GETS and WPS. In addition, we obtained and 

analyzed data on the performance of GETS and WPS during select 

emergency or national special security events such as the 1995 Oklahoma 

City Bombing, the September 11, 2001, attacks, Hurricane Katrina in 2005, 

and the 2009 Presidential Inauguration, among others. We also interviewed 

NCS officials to obtain information on the agency’s role in ensuring 

continuity of communications, the types of priority communications 

capabilities it provides to the national security and emergency 

preparedness (NS/EP) community—specifically through the GETS, WPS, 

and Telecommunications Service Priority (TSP) programs—as well as the 

types of challenges, if any, the agency may face in providing these 

services. We interviewed officials from the Federal Communications 

Commission (FCC) to obtain information on the agency’s role in providing 

emergency communications, including how it works with NCS in 

providing priority communications capabilities. Furthermore, we 

interviewed telecommunications industry representatives from AT&T, 

Qwest Communications, and Verizon that are among the U.S. telephone 

carriers that provide NS/EP communications services. Although their 

views cannot be generalized to all telecommunications companies that 

provide NS/EP communications, the information we obtained helped to 

enhance our understanding of their role in providing emergency 

communications and their views on the impact the next generation 

 

1

PART consists of a standard series of questions intended to determine the strengths and 

weaknesses of federal programs. The PART questions cover four broad topics—(1) 

program purpose and design, (2) strategic planning, (3) program management, and (4) 

program results/accountability. 

 National Communications System 
Appendix II: Objectives, Scope and 

Methodology 

network (NGN) technology transition may have on NCS’s priority 

communication programs. 

We also interviewed NS/EP officials from a non-probability sample of 15 

states and 13 localities2

 to obtain their perspectives and views on the NCS 

and its priority communication programs. Specifically, we obtained 

information from these officials regarding (1) their awareness of the NCS 

and the GETS, WPS, and TSP programs; (2) the extent they had utilized 

these programs in responding to an emergency situation and/or in their 

training and exercise activities; and (3) their perspectives on the benefits 

of these priority calling programs and potential barriers to participation. In 

selecting these states and localities, we considered a variety of factors 

including (1) the frequency and types of declared disasters by the Federal 

Emergency Management Agency (FEMA), (2) geographic dispersion, and 

(3) topographical factors that could affect the functionality of 

communications. The selected states and localities represent a range of 

natural disasters, terrains, climates, and population densities and also 

include areas that have recently experienced high-profile natural disasters 

or man-made attacks. While the perspectives of the officials we 

interviewed cannot be generalized to reflect the views of NS/EP 

emergency management officials in all states and localities, we believe the 

perspectives of the officials in these locations provided us with an 

overview and useful information on the NCS and the priority 

communications programs it provides. 

To determine how NCS enlists subscribers and controls access to its 

priority programs, we collected and analyzed documentation, and 

interviewed NCS officials (1) on subscriber eligibility criteria, (2) to 

determine NCS’s outreach efforts to enlist new subscribers for its priority 

calling programs, and (3) to identify its internal controls for controlling 

access to these programs. With regards to NCS’s outreach efforts, we 

obtained and reviewed documentation such as brochures, newsletters, and 

 

2

In total, we interviewed NS/EP officials from 37 state and local agencies. State interviews 

were held with emergency management agencies and/or homeland security departments 

and covered the following states: Alabama, California, Colorado, Florida, Illinois, Kansas, 

Louisiana, Maryland, New York, North Carolina, Ohio, Oklahoma, Oregon, Virginia, and 

Wyoming. Local interviews were held with local emergency management agencies, police 

and fire departments, and other entities with NS/EP responsibilities. Localities we covered 

included: City of Sacramento, County of Sacramento, County of Santa Clara, County of San 

Diego, City of San Diego Lee County, Broward County, Miami-Dade County, Palm Beach 

County, City of Fort Lauderdale, City of Boynton Beach, City of New York, and the City of 

New Orleans. 

Page 55 GAO-09-822 National Communications System
Appendix II: Objectives, Scope and 

Methodology 

conference schedules on NCS outreach efforts including its use of regional 

outreach coordinators and its awareness booth deployments at various 

emergency management conferences. We also attended several NCS userfocused meetings and obtained documentation which detailed NCS efforts 

to attract new subscribers and provide support to current subscribers. To 

determine what internal controls NCS utilizes to grant and control access 

to its priority calling programs, we obtained the NCS standard operating 

procedures for GETS and WPS programs which outlined the procedures 

and processes to participate in the programs including the eligibility 

criteria, the approval process, and the re-validation process. We also 

obtained NCS standard operating procedures and compared them with 

criteria in Standards for Internal Control in the Federal Government.3

 To 

determine whether NCS adhered to its procedures for terminating access 

for subscribers who no longer meet the programs’ eligibility criteria, we 

reviewed a nonprobability sample of records for 76 former federal and 9 

former state government officials including former members of the U.S. 

Senate as well as members and delegates of the U.S. House of 

Representatives for the 109th Congress; immediate past heads of federal 

departments and agencies as of August 2008; and immediate past 

governors of U.S. states and territories as of August 2008, which is when 

we obtained the subscriber data. We selected these groups because they 

served in public positions that would allow NCS to easily determine that 

their positions ended, and in turn, work with the subscriber’s organization 

to update account status, as appropriate. Although the results of our work 

cannot be generalized to evaluate the effectiveness of controls used for all 

NCS program subscribers, the information obtained provided us with 

useful information about the extent to which subscriber records for these 

groups were terminated following a change in the subscriber’s eligibility 

status. Because the subscriber database, in its entirety, is classified, we 

have limited our reporting of the results of our analysis to only 

nonclassified information; however, this does not affect our findings. 

To assess the reliability of these data, we reviewed the data for obvious 

problems with completeness or accuracy and interviewed knowledgeable 

agency officials and contract support staff about the data quality control 

processes and reviewed relevant documentation such as the database 

dictionary that describes the data fields in the subscriber database. When 

we found discrepancies (such as duplicate records), we brought them to 

 

3

GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999). 

Page 56 GAO-09-822 National Communications System
Appendix II: Objectives, Scope and 

Methodology 

the attention of NCS officials and its contract support staff to better 

understand the nature of the discrepancies and resulting impact on our 

work. We performed electronic testing on the data and found the data to 

be sufficiently reliable for the purposes of this report. 

To determine what challenges can affect NCS’s delivery of its priority 

communications programs, we interviewed relevant NCS officials who 

have responsibilities for these programs. We also obtained information 

and reviewed documentation from the agency regarding its efforts to 

implement the Satellite Priority Service pilot program, as well as its efforts 

to leverage NGN technology in its priority communication programs. We 

compared this information with our previous work on pilot program 

planning and technology acquisition.4

To assess NCS’s overall planning and evaluation efforts, we interviewed 

NCS officials and reviewed relevant documentation regarding their 

strategic planning efforts and the mechanisms they use to evaluate their 

services. Specifically, we reviewed and analyzed NCS’s draft strategic plan 

to determine the extent to which the plan outlined the agency’s short and 

long term strategic goals and objectives, the associated time frames with 

their identified goals and objectives, the current status of the goals and 

objectives and internal and external factors that may affect their ability to 

achieve their goals and objectives. We also obtained and reviewed the 

OMB Performance Assessment Rating Tool, NCS’s Congressional Budget 

Justifications, and other documents that outlined the performance 

measures utilized to assess the extent they are achieving their goals and 

objectives; and planned milestones and spending for their priority calling 

programs. To assess the effectiveness of NCS planning efforts, we 

compared their efforts with federal best practices contained in our past 

reports which discussed the importance of strategic planning.5

 We also 

utilized guidance from OMB Circular A-11, and related federal legislation, 

such as the Government Performance and Results Acts of 1993, which 

identifies the six key element of a strategic plan.6

 In addition, we 

interviewed NCS officials about their strategic planning efforts and the 

 

4

GAO-09-45 and GAO-07-424. 

5

See for example, GAO-03-143 and GAO/GGD-96-118. 

6

Government Performance and Results Act of 1993, Pub. L. No. 103-62, 107 Stat. 285 (1993); 

and OMB, OMB Circular A-11, Part 6, Preparation, Submission, of Strategic Plans, 

Annual Performance Plans, and Annual Program Performance Reports (Washington, 

D.C.: Executive Office of the President, June 2008). 

Page 57 GAO-09-822 National Communications System
Appendix II: Objectives, Scope and 

Methodology 

mechanisms they use to monitor and evaluate their services. While NCS is 

not required to explicitly follow these guidelines, the guidelines do provide 

a framework for effectively developing a strategic plan and the basis for 

program accountability. 

We conducted this performance audit from June 2007 through August 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 provides a reasonable basis for our findings based on our 

audit objectives. 

Page 58 GAO-09-822 National Communications System
Appendix III: Telecommunications Service Appendix III: Telecommunications Service Priority Program 

Priority Program 

The Telecommunications Service Priority (TSP) program provides priority 

provisioning and restoration of telecommunications services that support 

emergency operations facilities for certain federal, state, and local 

governments and other entities. Such services include equipment used to 

transmit voice and data communication by wire, cable, and satellite, 

among other things. During and following an emergency event, wireless 

and wireline carriers may receive numerous requests for new 

telecommunications service as well as for the restoration of existing 

services. Under this program, telecommunications carriers and their 

partners (collectively referred to as service vendors) are required to 

restore national security and emergency preparedness (NS/EP) 

telecommunications services that suffer outage, or are reported as 

unusable or otherwise in need of restoration, before non-NS/EP services.1

As with Government Emergency Telecommunications Service (GETS) and 

the Wireless Priority Service (WPS), certain government agencies and 

other groups are identified as having specific NS/EP responsibilities that 

qualify them for priority provisioning and restoration of services. 

However, unlike GETS and WPS, for which new subscriptions can be 

requested and approved during emergency response and recovery 

activities, authorization to receive TSP priority services must be in place 

before it is needed. Although the federal government does not charge a 

fee, telecommunications service providers (such as wireless carriers and 

cable and satellite providers) may charge an initial startup fee of up to 

$100 per circuit and a monthly fee of up to $10 per circuit.2

 The National 

Communications System (NCS) reported that as of fiscal year 2008, over 

1,000 organizations have registered more than 191,000 circuits under the 

TSP program. 

Telecommunications personnel have traditionally faced difficulties in 

accessing disaster areas in order to make TSP repairs to communications 

assets. According to telecommunications representatives that are part of 

 

1

Miscellaneous Rules Relating to Common Carriers: Telecommunications Service Priority 

(TSP) System for National Security Emergency Preparedness (NSEP), 47 C.F.R. pt. 64, App. 

A. Under the appendix, service vendors are defined as any person, association, partnership, 

corporation, organization, or other entity (including common carriers and government 

organizations) that offer to supply any telecommunications equipment, facilities, or 

services (including customer premises equipment and wiring) or combination thereof and 

the term includes resale carriers, prime contractors, subcontractors, and interconnecting 

carriers. 

2

The fees charged may differ depending on the service provider and are separate from any 

charges related to the installation or repair of circuits following an emergency event. 

Page 59 GAO-09-822 National Communications System 
Appendix III: Telecommunications Service 

Priority Program 

the National Coordinating Center for Telecommunications (NCC) within 

NCS, access for repair crews to disasters areas has been an issue dating 

back to Hurricane Hugo in 1989, and during the aftermath of Hurricane 

Katrina. For example, an independent panel formed to examine the 

telecommunications challenges during Hurricane Katrina, reported that 

inconsistent and unclear requirements for repair crews and their 

subcontractors to gain access to the affected area impeded their efforts to 

make necessary repairs including those that they are required to complete 

under the TSP program.3

 The panel reported that there were no 

mechanisms in place to issue credentials to those who needed them prior 

to Hurricane Katrina making landfall. Consequently, personnel from 

telecommunications companies were unable to gain access to repair some 

communications assets in the disaster area because they lacked the 

necessary credentials to access these areas. For example, during 

Hurricane Katrina, Louisiana authorities, among others, provided 

credentials to telecommunications repair crews to permit them access to 

certain affected areas; however, telecommunications personnel reported 

that within disaster areas, credentials that permitted access through one 

checkpoint would not be honored at another. In addition these personnel 

reported that in some cases the checkpoints required different 

documentation and credentialing before granting access to repair 

personnel. As a result, repair personnel had to carry multiple credentials 

and letters from various federal, state, and local officials authorizing their 

access to the disaster area. Furthermore, telecommunications personnel 

were unclear about which government agency had the authority to issue 

the necessary credentials. Similarly, repair crews reported that other 

factors delayed or interrupted the delivery of TSP services, such as the 

enforcement of curfews and other security procedures intended to 

maintain law and order. 

Although the full scope of these credentialing issues is outside NCS’s 

jurisdiction, under the communications annex of the revised 2008 National 

Response Framework, NCS is to coordinate with other emergency support 

function 2 (ESF-2) support agencies, among others, to ensure that 

telecommunications repair personnel have access to restore 

communications infrastructure in the incident area. To help facilitate this, 

NCS has taken steps to work with federal, state, and local government 

 

3

Independent Panel Reviewing the Impact of Hurricane Katrina on Communications 

Networks, Report and Recommendations to the Federal Communications Commission, 

(Washington D.C., June 12, 2006). 

Page 60 GAO-09-822 National Communications System
Appendix III: Telecommunications Service 

Priority Program 

agencies as well as the private sector to identify solutions. For instance, 

NCS has coordinated with emergency management officials in Georgia and 

Louisiana to develop standard operating procedures to ensure access for 

critical infrastructure workers during emergencies or disasters. NCS 

officials also told us that they have begun to catalog the access procedures 

for various states and localities that could be provided to 

telecommunications personnel in order to facilitate access to damaged 

infrastructure in the aftermath of an emergency or disaster. In addition, 

other federal agencies, such as the Federal Emergency Management 

Agency (FEMA), have also taken steps to address this issue. For example, 

in November 2008, FEMA released for comment credentialing guidelines 

for essential personnel who need access to disaster areas in order to 

facilitate response, recovery and restoration efforts.4

 The guidelines are 

intended to provide a uniform approach at the state and local level to 

provide telecommunications repair personnel, among others with access 

and credentials needed to enter a disaster area in order to expedite the 

restoration of communication capabilities. 

 

4

DHS defines credentialing as the administrative process for validating personnel 

qualifications and providing authorization to perform specific functions in response to an 

emergency or disaster. 

Page 61 GAO-09-822 National Communications System
Appendix IV: GETS and WPS Performance Appendix IV: GETS and WPS Performance during Select Emergency Events 

during Select Emergency Events 

Government Emergency Telecommunications Service (GETS) and the 

Wireless Priority Service (WPS) are designed to achieve a probability that 

90 percent of calls made using these services will successfully connect. 

The ability to communicate is critical to coordinating emergency response 

and recovery efforts during the first 72 hours following an emergency; 

however, the availability of communications can be disrupted by increased 

call volume or outages that occur in wireline and wireless networks. 

According to NCS, telephone calls made without the use of GETS or WPS 

during nonemergency periods generally result in a 99 percent likelihood of 

successful completion—that is the (1) called party answers the call, (2) 

called number rings but is not answered, or (3) called number responds 

with a busy signal. However, during a disaster or emergency event, NCS 

officials stated that the public switched telephone network (PSTN) can 

experience up to 10 times the normal call volume. Conversely, without 

using GETS or WPS, approximately 9 out of every 10 calls would not 

complete during a time period when the PSTN is highly congested. 

NCS’s priority calling programs services have been used to facilitate 

communications across the spectrum of emergencies and other major 

events dating back to the 1995 Oklahoma City Bombings through the 

recent 2009 Presidential Inauguration. GETS and WPS usage has varied 

greatly during disasters or emergencies as the programs have evolved and 

the programs have generally achieved call completion rates that range 

from 68 percent to 99 percent. For example, during the 1995 Oklahoma 

City bombings, of 429 GETS calls attempted 291 calls that may not have 

otherwise been completed due to network overload reached the intended 

destination number and resulted in a call completion rate of about 68 

percent.1

 In contrast, during Hurricane Katrina in 2005, the number of 

GETS calls attempted was 28,556, of which 27,058 (or 95 percent) were 

successfully completed (see table 5). Additionally, GETS and WPS 

capabilities were also used during the 2003 power outage that affected 

New York City and other areas. During this event, there were fewer GETS 

and WPS calls made in comparison to other events; however, the call 

completion rates for the duration of the event were 92 percent and 82 

percent respectively. 

 

1

At that time, GETS was in the early stages of deployment and had not yet achieved initial 

or full operating capability. 

Page 62 GAO-09-822 National Communications System 
Appendix IV: GETS and WPS Performance 

during Select Emergency Events 

Table 5: GETS and WPS Performance during Select Emergency Events

Event 

Time frame 

following 

onset of 

event Date 

GETS 

calls 

attempted

GETS 

calls 

completed

GETS call 

completion 

rate

GETS 

cards 

distributed

WPS calls 

attempted 

(a) 

WPS calls 

completed 

(b)

WPS Call 

completion 

rate

24 hours 11-Sep-01 2,283 2,025 89% 100

48 hours 12-Sep-01 628 556 89% 100

72 hours 13-Sep-01 675 617 91% 155

September 

11, 2001 

Terrorist 

Attacks 

Total duration 

of event 

11-27 

Sep-01 

19,071 18,117 95% 1,956

Data unavailable as WPS did not yet 

exist. 

24 hours 14-Aug-03 658 604 92% 21 22 13 59%

48 hours 15-Aug-03 344 308 90% 20 38 28 74%

72 hours 16-Aug-03 85 85 100% 0 56 55 98%

2003 

Northeastern 

Blackout 

Total duration 

of event 

14-16 

Aug-03

1,087 997 92% 41 116 95 82%

24 hours 29-Aug-05 1,075 1,030 96% 208 656 611 93%

48 hours 30-Aug-05 2,071 1,989 96% 109 1,400 1,217 87%

72 hours 31-Aug-05 2,345 2,236 95% 166 1,728 1,528 88%

2005 

Hurricane 

Katrina 

Total duration 

of event 

29 Aug-09 

Sep-05 

28,556 27,058 95% 1,027 3,784 3,356 89%

24 hours 22-Sep-05 1,783 1,628 91% 0 471 428 91%

48 hours 23-Sep-05 1,211 1,107 91% 0 728 617 85%

72 hours 24-Sep-05 817 756 93% 139 621 540 87%

2005 

Hurricane 

Rita 

Total duration 

of event 

22 -29 

Sep-05 

14,139 13,475 95% 1,356 2,308 2,028 88%

24 hours 24-Oct-05 458 458 100% 0 783 780 100%

48 hours 25-Oct-05 1,277 1,276 100% 317 861 855 99%

72 hours 26-Oct-05 1,988 1,987 100% 141 517 507 98%

2007 San 

Diego 

Wildfires 

Total duration 

of event 

24-28 Oct05 5,152 5,147 100% 543 2,617 2,582 99%

24 hours 1-Sep-08 1,200 1,199 100% 0 395 369 93%

48 hours 2-Sep-08 1,404 1,401 100% 0 611 588 96%

72 hours 3-Sep-08 517 503 97% 6 785 765 97%

2008 

Hurricane 

Gustav 

Total duration 

of event 

1-3 Sep 

2008

7,026 6,923 99% 555 3,311 3,028 91%

24 hours 11-Sep-08 1,629 1,625 100% 53 580 528 91%

48 hours 12-Sep-08 1,345 1,337 99% 52 821 756 92%

72 hours 13-Sep-08 2,420 2,344 97% 0 1,011 983 97%

2008 

Hurricane 

Ike 

Total duration 

of event 

11-18

Sep-08

17,525 17,301 99% 1,433 7,231 6,884 95%

Page 63 GAO-09-822 National Communications System
Appendix IV: GETS and WPS Performance 

during Select Emergency Events 

Event 

Time frame 

following 

onset of 

event Date 

GETS 

calls 

attempted

GETS 

calls 

completed

GETS call 

completion 

rate

GETS 

cards 

distributed

WPS calls 

attempted 

(a) 

WPS calls 

completed 

(b)

WPS Call 

completion 

rate

24 hours 16-Jan-09 1,260 1,235 98% 23 536 372 69%

48 hours 17-Jan-09 228 228 100% 0 86 58 67%

72 hours 18-Jan-09 222 220 99% 0 156 96 62%

2009 

Presidential 

Inauguration 

Total duration 

of event 

16-20 Jan 

2009 

4,032 4,005 99% 1,188 1,615 1,050 65%

Source: NCS. 

Note: In some cases, call completion rate may not equal 100% due to rounding. 

Page 64 GAO-09-822 National Communications System
Appendix V: NS/EP Categories That Qualify 

for NCS’s Priority Telecommunications Appendix V: NS/EP Categories That Qualify Services 

for NCS’s Priority Telecommunications 

Services 

The National Communications System (NCS) uses five broad categories to 

determine who may be eligible to participate in its priority calling 

programs such as the Government Emergency Telecommunications 

Service (GETS) and the Wireless Priority Service (WPS). Eligible 

subscribers may include personnel from federal, state, local, or tribal 

government; as well as private industry and or non-profit organizations 

(see table 6 below for further detail on each of these categories). In 

addition, these categories are used to prioritize WPS calls in order to 

further ensure that communications are first available for senior executive 

leaders and policy makers at the federal, state, and local government level. 

The Federal Communications Commission (FCC), in response to NCS’s 

request, established these priority levels that are used to determine which 

WPS calls are to receive the first available channel with level five receiving 

the lowest priority (though all levels receive priority over non-WPS 

callers).1

 In the event of an emergency and network congestion, the 

mobile switching center queues the call according to the subscriber’s 

priority level and call initiation time. For example, authorized staff from 

the Executive Office of the President would receive priority over national 

security and emergency preparedness (NS/EP) officials who have 

responsibility for public health and law enforcement if they placed calls at 

the same time. NCS has not determined whether a similar approach is 

required for the GETS program; however, if it is determined that a similar 

approach is needed—NCS believes it can apply the WPS approach to the 

GETS program. Table 6 also shows the priority level for each user 

category. 

 

1 47 C. F. R. pt. 64, App. B. 

Page 65 GAO-09-822 National Communications System 
Appendix V: NS/EP Categories That Qualify 

for NCS’s Priority Telecommunications 

Services 

Table 6: NS/EP Categories That Qualify for NCS’s Priority Telecommunications Services 

NS/EP category 

Priority 

level Description 

Examples of positions that could qualify for 

GETS and WPS 

Executive Leadership and 

Policymakers 

n Individuals in high-level government 

positions 

• The President of the United States, the 

Secretary of Defense, selected military 

leaders, and the minimum number of senior 

staff 

• Members of the United States Congress and 

senior staff 

• State governors, lieutenant governors, 

cabinet-level officials responsible for public 

safety and health, and the minimum number 

of senior staff 

• Mayors, county commissioners, and the 

minimum number of senior staff 

Disaster Response/Military 

Command and Control 

o Individuals eligible for this category include 

personnel key to managing the initial 

response to an emergency at the local, 

state, regional and federal levels. 

Personnel selected for this priority level 

should be responsible for ensuring the 

viability or reconstruction of the basic 

infrastructure in an emergency area. In 

addition, personnel essential to continuity 

of government and national security 

functions (such as the conduct of 

international affairs and intelligence 

activities) are also included in this priority. 

• Federal emergency operations center 

coordinators, e.g., Manager, National 

Coordinating Center for 

Telecommunications, National Interagency 

Fire Center, Federal Coordinating Officer, 

Federal Emergency Communications 

Coordinator, Director of Military Support 

• State emergency services director, National 

Guard Leadership, State and Federal 

Damage Assessment Team Leaders 

• Federal, state and local personnel with 

continuity of government responsibilities 

• Incident Command Center Managers, local 

emergency managers, other state and local 

elected public safety officials 

• Federal personnel with intelligence and 

diplomatic responsibilities 

Public Health, Safety, and 

Law Enforcement 

p Individuals eligible for this category are 

individuals who direct operations critical to 

life, property, and maintenance of law and 

order immediately following an event. 

• Federal law enforcement command 

• State police leadership 

• Local fire and law enforcement command 

• Emergency medical service leaders 

• Search and rescue team leaders 

• Emergency communications coordinators 

Public Services/Utilities and 

Public Welfare 

q Individuals eligible for this category are 

those users whose responsibilities include 

managing public works and utility 

infrastructure damage assessment and 

restoration efforts and transportation to 

accomplish emergency response activities.

• Army Corps of Engineers leadership 

• Power, water and sewage and 

telecommunications utilities 

• Transportation Leadership 

Page 66 GAO-09-822 National Communications System
Appendix V: NS/EP Categories That Qualify 

for NCS’s Priority Telecommunications 

Services 

NS/EP category 

Priority 

level Description 

Examples of positions that could qualify for 

GETS and WPS 

Disaster Recovery r Individuals eligible for this category are 

those individuals responsible for managing 

a variety of recovery operations after the 

initial response has been accomplished. 

These functions may include managing 

medical resources such as supplies, 

personnel, or patients in medical facilities. 

Other activities such as coordination to 

establish and stock shelters, to obtain 

detailed damage assessments, or to 

support key disaster field office personnel 

may be included. 

• Medical recovery operations leadership 

• Detailed damage assessment leadership 

• Disaster shelter coordination and 

management 

• Critical Disaster Field Office support 

personnel 

Source: NCS. 

Page 67 GAO-09-822 National Communications System
Appendix VI: Comments from the Department Appendix VI: Comments from the of Homeland Security 

Department of Homeland Security 

Page 68 GAO-09-822 National Communications System 
Appendix VI: Comments from the Department 

of Homeland Security 

Page 69 GAO-09-822 National Communications System
Appendix VII: 

A

GAO Contacts and Staff 

cknowledgments 

Page 70 GAO-09-822 

Appendix VII: GAO Contacts and Staff 

Acknowledgments 

William O. Jenkins, 202-512-8777 or jenkinswo@gao.gov 

In addition to the contact named above, Kirk Kiester, Assistant Director, 

and Candice Wright, Analyst-in-Charge, managed this review. Mark 

Abraham, Flavio Martinez, and Daniel Paepke made significant 

contributions to the work. David Alexander and Arthur James assisted 

with design, methodology, and data analysis. Sally Williamson provided 

assistance in report preparation. Pille Anvelt provided assistance with the 

report’s graphics. 

 National Communications System 

GAO Contacts 

Staff 

Acknowledgments 

(440620) 
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