Nuclear Terrorism Response Plans: Major Cities Could Benefit from Federal Guidance on Responding to Nuclear and Radiological Attacks
Published: 2013-09-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: A terrorist attack in a major city using an RDD or an IND could result not only in the loss of life but also have enormous psychological and economic impacts. Major cities are assumed to be preferred targets of such attacks, and local governments, along with their states, have primary responsibilities for early response (within the first 24 hours), with assistance from federal sources, as necessary, coming later. A disjointed or untimely response could increase the impact and undermine public confidence in federal, state and local governments' ability to respond to an attack.
GAO was asked to review issues related to response preparedness for RDD and IND attacks. This report examines major cities' (1) assessment of RDD and IND risks and development of response plans, (2) perceptions of their abilities to respond within the first 24 hours, and (3) perceptions of the need for federal support in early response to these attacks. GAO primarily relied on questionnaire responses from emergency managers of 27 of the 31 major cities that the Department of Homeland Security considers to be at high risk for terrorist attack, the review of pertinent federal guidance, and interviews with FEMA officials and others.
section_title: What GAO Found
paragraphs: Many emergency managers from the 27 major cities responding to GAO's questionnaire, although not all, reported that their city had assessed the risks of a terrorist attack using a radiological dispersal device (RDD) or improvised nuclear device (IND) and had ranked the risk of these attacks as lower than the risk of other hazards they face. Also, 11 of the 27 reported that they had completed RDD response plans, and 8 of the 27 reported that they had completed IND response plans. Some emergency managers for cities without specific RDD and IND response plans reported that they would rely on their city's all hazards emergency operations plan or hazard management plan if attacked. Most cities that had RDD and IND response plans reported conducting exercises to validate the plans based on federal guidance.
Major cities varied widely in perceptions of their abilities to respond within the first 24 hours of RDD and IND attacks (early response). For example, all 27 cities were perceived by their emergency managers as being able to conduct at least a few of the early response activities after an RDD attack, such as treating casualties, with assistance from other jurisdictions but not federal assistance. Ten of those cities were perceived as not being able to conduct any of the response activities for an IND attack without federal assistance. GAO analysis found that these perceptions were not necessarily related to a city having RDD and IND response plans but rather related to their understanding of nuclear and radiological incidents and the capabilities needed for response according to information obtained from Federal Emergency Management Agency (FEMA) officials. GAO found limited federal planning guidance related to the early response capabilities needed by cities for the large RDD attack depicted in the national planning scenarios. Federal guidance may not be needed, according to FEMA officials, because they expect cities to address a more likely but smaller RDD attack--as they would a hazardous materials spill--with limited federal assistance. More federal planning guidance applicable to cities has been developed for IND response, but this guidance does not detail the early response capabilities needed by cities in relation to other sources of assistance. Without greater awareness of and additional federal guidance on the capabilities needed by cities for early response to these attacks, cities may not have the information they need to adequately prepare for and respond to them. This could lead to complications that result in greater loss of life and economic impacts.
Most emergency managers reported perceived needs for federal technical and resource assistance to support their cities' early response to RDD (19 of 27 cities) and IND (21 of 27 cities) attacks. However, GAO found that federal guidance on the type and timing of such assistance is not readily available or understood by all emergency managers. This condition could lead to a disjointed and untimely response that might increase the consequences of either kind of attack. Emergency managers also reported a need for improved procedures and more information that FEMA is addressing. In addition, most emergency managers reported their city needed federal funding to maintain current capabilities to respond to RDD and IND attacks. According to DHS guidance, response capabilities are developed through planning, training, equipping, and exercising, which are essential elements of an integrated, capability-based approach to preparedness.
section_title: What GAO Recommends
paragraphs: GAO recommends that FEMA develop guidance to clarify the early response capabilities needed by cities for RDD and IND attacks. FEMA did not concur with this recommendation. GAO believes that gaps in early response abilities warrant federal attention and has clarified its recommendation.

section_title: Letter
paragraphs: A terrorist attack in a major city using a weapon of mass destruction  would result in not only the loss of life but also enormous psychological  and economic impacts. Since the terrorist attacks of September 11, 2001,  concerns have intensified over major cities’ preparedness to respond to  an attack using a radiological dispersal device (RDD)—a mechanism to  deliberately release radioactive material in sufficient quantities to require  protective actions—or an improvised nuclear device (IND)—a weapon  fabricated using fissile material that produces a nuclear explosion. Urban  centers of major cities are assumed to be preferred targets for a terrorist  attack, and local governments, along with their states, would have  primary responsibilities for early response—within the first 24 hours—until  additional resources, if needed, arrive from the federal government. To  prepare to respond early to an RDD or IND attack, cities will need to  understand the risks and plan to respond if an attack occurs. According to  a 2012 National Science and Technology Council report, the ability to  prepare for such an attack and act decisively and appropriately in the first  minutes and hours after an attack will require reliable information,  capabilities, and tools to assist in planning and to effectively mitigate  consequences. A disjointed or untimely response could put many  additional lives at risk, increase economic consequences, and undermine  the public’s confidence in the federal, state, and local governments’ ability  to respond to such a crisis.
In March 2011, the President directed the Secretary of Homeland  Security, Department of Homeland Security (DHS), to develop a national  preparedness goal and design a national preparedness system to  address the threats posing the greatest risk to the security of the nation,  and to issue an annual national preparedness report. The national  preparedness goal defines the core capabilities necessary to prepare for  specific types of incidents, including acts of terrorism, cyber attacks,  pandemics, and catastrophic natural disasters. In September 2011, DHS  published the National Preparedness Goal, which stated that all levels of  government and the whole community should present and assess risks in  a similar manner to provide a common understanding of the threats and  hazards confronting the country. Consistent with the National  Preparedness Goal, the information gathered during a risk assessment  will also enable a prioritization of preparedness efforts and provide an  opportunity to identify capability requirements across all levels of  government and the private sector. In this context, an RDD or IND attack  would pose both a threat prior to the incident and a hazard after  detonation.
As directed by the President, the national preparedness system is  intended to guide activities to achieve the national preparedness goal.  Specifically, it is to provide guidance on the planning, organization,  equipment, training, and exercises needed to develop and maintain  domestic capabilities. The national preparedness system is to include a  series of integrated national planning frameworks for five mission areas— prevention, protection, mitigation, response, and recovery—built on basic  plans that support an all hazards approach to preparedness. The all  hazards approach allows emergency planners at all government levels to  address common operational functions in their basic plans instead of  having unique plans for every type of hazard. Each national planning  framework is directed to include guidance to support corresponding  planning at other governmental levels, including cities. The directive  called for the national preparedness system to include development of a  Federal Interagency Operational Plan (FIOP) to support each of the five  mission area planning frameworks, such as the one for the response  mission area. In November 2011, DHS published the National  Preparedness System and has been working to implement this system.
The directive also recognizes that the national planning frameworks could  include supplements, called annexes, describing additional planning  guidance for particular hazard scenarios. DHS has previously prepared  guidance in 2006 on planning assumptions for major attacks and natural  disasters, including RDD and IND attacks, as a reference to help planners  at all levels of government identify the potential scope, magnitude, and  complexity of these events. DHS stated in this guidance that this was  done to establish a range of response capabilities to facilitate  preparedness planning and exercising these plans. The 2008 National  Response Framework, under revision, already includes a nuclear and  radiological incident annex.  According to Federal Emergency  Management Agency (FEMA) officials, the FIOPs will likely include  operational details for most, if not all of the national planning framework  annexes.
The President also directed that the national preparedness system be  consistent with the previously developed National Incident Management  System, which provides a systematic and coordinated all hazards  approach to incident management across all levels of government. The  National Incident Management System sets forth a comprehensive  national approach that recognizes that incidents typically begin and end  locally and are managed on a daily basis at the lowest jurisdictional level.  However, there are incidents in which successful management of  operations will need the involvement of multiple jurisdictions, levels of  government, functional agencies, and emergency responder disciplines.  Effective response to an RDD or IND attack would require marshalling all  available federal, state, and local resources to save lives and limit  economic damage.
DHS has lead federal coordinating responsibility for attacks involving  nuclear or radiological materials, including RDDs and INDs. FEMA, within  DHS, has responsibility to reduce the loss of life and property, and protect  the nation from all hazards, including terrorism. FEMA has a leadership  role to coordinate the overall federal response to these attacks in close  coordination with many other federal agencies and departments. Among  other agencies, these include the Department of Energy (DOE),  Department of Defense (DOD), and the Department of Health and Human  Services (HHS). Within DOE, the semiautonomous National Nuclear  Security Administration (NNSA) would lead the early federal interagency  response to characterize the nature and dispersal of radioactive material  in the event of an RDD or IND attack. DOD may provide support in  response to requests for assistance from DHS, other federal agencies, as  well as state and local governments. HHS would lead all federal public  health and medical response to supplement state and local resources  during a public health and medical disaster. In addition, the National  Guard can provide governors with a wide array of response capabilities in  detection/identification, search and rescue, patient decontamination, and  medical care to relieve or augment first responders.
Since major cities are presumed to be preferred targets for terrorist  attacks, you asked us to examine their concerns about RDD and IND  attacks and how they perceive their ability to respond to them before  federal assistance arrives. This report examines major cities’ (1)  assessment of the risks of RDD and IND attacks and the extent to which  they have developed plans for responding to them, (2) perceptions of  their abilities to respond to RDD and IND attacks in the first 24 hours  (early response), and (3) perceptions of their need for federal support in  the early response to RDD and IND attacks.
To conduct this work, we developed a questionnaire for the directors of  emergency management of 31 major cities that DHS considers at highest  risk for a terrorist act in fiscal year 2012. We were able to contact an  emergency manager to receive the questionnaire in 29 of the 31 cities.  We selected city emergency managers to receive the questionnaire  because they are in the best position to provide a city-wide perspective  on the level of preparedness to respond to RDD and IND attacks.  Emergency managers from 27 of the 29 major cities that received our  questionnaire responded for a response rate of 87 percent. This  questionnaire asked city emergency managers to report on (1) how their  city assessed the risk of RDD and IND attacks, and the availability of local  response plans for these attacks; (2) their perceptions of their city’s ability  to respond within the first 24 hours (early response); and (3) their  perceptions of the need for federal support to prepare for and respond to  these attacks. In addition, we reviewed federal guidance documents and  other relevant reports. We also interviewed emergency managers or first  responders in seven major cities selected for their geographic location  and population size, and visited with emergency management planners  who participated in an interagency IND response planning effort in  Chicago. We also interviewed FEMA and NNSA emergency management  planners, DOE national laboratory officials, and subject matter experts.  We conducted these interviews to obtain information on the availability of  federal technical and response assistance, initiatives to improve  information and procedures, and the availability of federal funding to  support preparedness efforts by major cities. Appendix I provides a more  detailed description of our objectives, scope, and methodology. A copy of  our questionnaire is found in appendix II.
We conducted this performance audit from June 2012 to September 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: This section provides information on the characteristics of RDD and IND  attacks, major cities considered at high risk of terrorist act, core  capabilities for all hazards preparedness, and response planning and  associated federal guidance in the national preparedness system.
subsections: section_title: Characteristics of RDD and IND Attacks
paragraphs: A radiological attack is defined as an event or series of events leading to  the deliberate release, or potential release into the environment, of  radioactive materials in sufficient quantity to require consideration of  protective actions. Such an act would probably be executed with no  advance warning. The typical means of dispersing radioactive material in  an RDD is through a conventional explosion. There is a wide range of  possible consequences from an RDD incident depending on the type and  size of the device and the extent of dispersal. According to FEMA  officials, the most likely RDD attack would impact a small area and not  result in acutely harmful radiation doses to exposed individuals but could  result in latent effects increasing the risk of cancer to exposed individuals.  In contrast, an IND attack would produce a nuclear explosion from fissile  material, which releases extreme heat and powerful shock waves, and  disperses radiation that would be lethal for a significant distance. It also  produces radioactive fallout, which would deposit radioactive material  over a large area. If the fission of the radioactive material is not achieved,  the effects of the explosion may resemble the impacts of an RDD. A 2011  Congressional Research Service report states that the use of an RDD is  more likely than an IND because the radioactive material to construct an  RDD is more accessible, and it would be more difficult for a terrorist to  make an IND. In both cases, early response within the first hours  includes initial actions to protect public health and welfare.
section_title: Major Cities Considered at High Risk of Terrorist Attack
paragraphs: In 2003, DHS established an Urban Areas Security Initiative program to  allocate homeland security grants to enhance and sustain the capacity to  prevent, protect against, mitigate, respond to, and recover from acts of  terrorism in high density urban areas, particularly the urban centers. The  program identifies these high density urban areas by their major city. For  example, the Chicago area includes 3 states, 14 counties, and 10  principal cities. Figure 1 shows the 31 major cities in the Urban Areas  Security Initiative program in fiscal year 2012 within the 10 FEMA regions.
In the National Preparedness Goal, DHS identified core capabilities  needed for each of the five national preparedness mission areas. These  core capabilities are considered necessary for an all hazards, capability- based approach to preparedness planning across all levels of  government, although each level of government does not have to  possess all capabilities. The five mission areas have in common three  core capabilities—planning, public information and warning, and  operational coordination—in addition to other capabilities specific to each  mission area. For the response mission area, there are 11 additional core  capabilities, for a total of 14. In compiling the list of core response  capabilities, DHS based them on those capabilities that would be needed  to respond to a large earthquake, major hurricane, and a weapon of mass  destruction attack. Table 1 describes the activities for each of the 14 core  capabilities in the response mission area that DHS considers necessary  to save lives, protect property, and meet basic human needs after a  catastrophic incident, such as an RDD or IND attack.
Under the national preparedness system, FEMA has issued guidance to  help planners at all levels of government develop and maintain viable, all  hazards emergency operations plans. This guidance describes how to  develop and maintain emergency operations plans and how to implement  these plans. While the basic emergency operations plan is oriented  around an all hazards approach, FEMA guidance states that special  policies may be necessary to respond to catastrophic incidents, such as  an RDD or IND attack. According to FEMA guidance, local governments  have the discretion to address these attacks in specific plans that are  annexed to a city’s emergency operations plan, and the inclusion of these  annexes will vary based on a jurisdiction’s assessment of the risks it  faces. DHS guidance establishing the national preparedness system  recognizes that since local governments will focus their planning efforts  on the more likely risks, federal planning must complement these  planning efforts for low-probability, high-consequence risks, such as a  terrorist attack using an RDD or IND. DHS issued preliminary guidance  for RDD and IND response planning to federal, state, and local  governments in 2008, through a Federal Register announcement, that  was followed in 2010 with additional federal guidance on responding to an  IND attack. Some professional organizations have also published  guidance covering measures that state and local government should  consider in responding to RDD and IND attacks. Figure 2 illustrates the  conceptual response planning framework, including possible nuclear or  radiological attack annexes as supplements to all hazards operational or  emergency operations plans supporting national preparedness.
section_title: Many Major Cities Assessed the Risk of RDD and IND Attacks as Lower Than Other Hazards They Face, and Few Had Developed Specific Response Plans
paragraphs: Many major city emergency managers, although not all, responded to our  questionnaire that their city had assessed the risks of RDD and IND  attacks and had ranked the risk of these attacks as lower than the risk of  other hazards their city faces. The results of our questionnaire also show  that fewer than half of the major cities that responded had developed  specific RDD and IND response plans. Most of the major cities that  reported having RDD and IND response plans also reported having  conducted exercises to validate those plans.
subsections: section_title: Many of the Major Cities Assessed the Risk of RDD and IND Attacks as Lower Than Other Hazards
paragraphs: Emergency managers of many of the major cities responding to our  questionnaire reported that their city assessed the risk of RDD and IND  attacks and ranked those risks as lower than other hazards their city  faces. We asked emergency managers to refer to their city’s most  recently completed Hazard Identification and Vulnerability Assessment,  and report whether they assessed the risk of RDD or IND attacks and, if  so, where those risks ranked relative to the other hazards assessed by  their city, such as hurricanes, tornadoes, and flooding. All 27 cities  responded to our question regarding their assessment of the risks of RDD  and IND attacks. Three major cities reported that they had not completed  a Hazard Identification and Vulnerability Assessment, or a similar  assessment, and 6 cities reported that while they did have a recent  assessment, they did not include either RDD or IND attacks in this  assessment. Of the remaining 18 cities, 7 combined RDD and IND  attacks into a single risk in their assessments, 9 assessed the risk of RDD  and IND attacks separately, and 2 assessed the risk of an RDD attack but  did not assess the risk of an IND attack. Of the 11 cities that assessed the  risk of an RDD attack separately, 7 ranked the risk as lower than most or  all other hazards their city faces. Of the 9 cities that separately assessed  the risk of an IND attack, 7 ranked the risk as lower than most or all other  hazards their city faces. In general, most cities that conducted a separate  risk assessment for both RDD and IND reported that the risk of an RDD  attack was higher than the risk of an IND attack. Table 2 shows the  approach taken by the major cities responding to our questionnaire for  assessing the risks of RDD and IND attacks, as well as the percentage of  cities for each approach that ranked these risks lower than most or all  other hazards they face.
According to the responses to our questionnaire, fewer than half of the  major cities have response plans that specifically address RDD and IND  attacks, although some emergency managers indicated that their city had  these plans in development. Of the 27 major cities that responded to our  questionnaire, 11 (41 percent) of the emergency managers reported that  their city had completed RDD response plans, and 8 (30 percent) had  completed IND response plans. Some emergency managers for cities  that did not have specific RDD and IND response plans reported that they  would rely on other plans in the event of such an attack, including their  city’s emergency operations plan or hazard management plan. Table 3  identifies the extent to which major cities have hazard-specific RDD or  IND response plans.
The questionnaire results regarding the number of cities with specific  response plans for RDD and IND attacks are generally consistent with  prior analyses conducted by FEMA. In 2010, FEMA conducted a national  review of the contents of state and urban area emergency operations  plans. FEMA found that more than 80 percent of urban areas reported  that their emergency operations plans were well-suited to meet the  challenges presented during large-scale or catastrophic incidents;  however, fewer than half expressed confidence that specific RDD and  IND response plans annexed to their emergency operations plans were  adequate to manage such attacks. Forty percent of the urban areas had  confidence in their RDD response plans, with 10 percent providing no  response. Thirty percent said they had confidence in their IND response  plans, with 20 percent providing no response.
section_title: Most Major Cities That Have Specific RDD and IND Response Plans Have Also Exercised These Plans
paragraphs: Most emergency managers responding to our questionnaire who reported  having specific RDD or IND response plans also reported having  conducted exercises to validate those plans based on federal guidance.  According to FEMA, a response plan should not be considered complete  until exercises are conducted to validate it. Of the 11 cities that have  specific RDD response plans, 9 of their emergency managers reported  that their city had participated in RDD exercises from 2010 to 2012. Of  the 8 cities that have specific IND response plans, 5 of their emergency  managers reported that their city had participated in IND exercises over  this same time period. These results are comparable to FEMA’s 2010  national review of emergency operations plans that found that plans were  frequently exercised. Specifically, 95 percent of all states and urban areas  (including the major cities in our questionnaire) had conducted exercises  using their basic plans, an increase from the previous review in 2006, and  the response planning annexes subject to the most exercises included  those involving the response to the release of hazardous materials, which  can include the dispersal of radioactivity from RDD and IND attacks.
section_title: Major Cities Vary Widely in Perceptions of Their Abilities to Respond within 24 Hours of RDD and IND Attacks
paragraphs: Major city emergency managers responding to our questionnaire varied  widely in their perception of their cities’ abilities to respond within the first  24 hours (early response) to an RDD or IND attack. Limited DHS  guidance exists that is applicable to major cities on the capabilities  needed for early response to an RDD attack, but more such guidance  exists for the early response to an IND attack. According to FEMA  officials, the agency is considering developing additional guidance on  nuclear and radiological incidents to be annexed to the forthcoming  FIOPs for the response and recovery mission areas that may help guide  the preparation of specific response plans to supplement the all hazards  emergency operations plans of cities interested in doing so.
subsections: section_title: Major Cities Vary Widely in Perceptions of Their Ability to Respond within 24 Hours of RDD and IND Attacks, but Perceive More Ability to Respond to an RDD Attack
paragraphs: Our analysis of the questionnaire responses from major city emergency  managers showed a wide variation in their perceptions regarding their  cities’ abilities to respond within the first 24 hours to the RDD or IND  attack depicted in the National Planning Scenarios, but most perceived  that their city has more ability to conduct the early response for an RDD  attack than for an IND attack. To gather this information, we obtained the  emergency managers’ self-assessments of their cities’ abilities for early  response to the national planning scenarios for RDD and IND attacks, but  we did not ask them to assess their level of ability for each of the 14  federal core response capabilities. We also asked them to consider  mutual aid from other jurisdictions in estimating their early response  abilities, but not to consider assistance from federal sources. Our analysis  of emergency manager responses showed a wide variation in perceived  early response abilities across the major cities. For example, 7 of 27 cities  were perceived by their emergency managers as being able to conduct all  of the activities needed for early response to an RDD attack without  federal assistance—such as treating casualties—while 2 cities were  perceived as being able to conduct all of the activities needed for an IND  attack, without federal assistance. Moreover, all cities were perceived by  their emergency managers as being able to conduct at least a few early  response activities for an RDD attack, while 10 cities were perceived as  not being able to conduct any early response activities for an IND attack.  Overall, our analysis concluded that more emergency managers  perceived that their city was able to conduct some, almost all, or all of the  early response activities needed for an RDD attack (22 of 27 cities)  compared with an IND attack (7 of 27 cities). Ten major cities reported not  having any ability to conduct the early response after an IND attack, even  considering assistance from the surrounding jurisdictions and their states,  which would suggest a high expectation for federal assistance during  early response. For RDD, emergency managers from 20 major cities  reported perceiving that their city was not able to conduct all of the  necessary early response activities, which may also suggest some  expectation for federal assistance. Figure 3 shows the distribution of  major cities among five categories of early response activities following  an RDD or IND attack based on emergency manager perceptions of their  city’s early response abilities including mutual aid from other jurisdiction  but not federal assistance.
The wide variation among emergency manager perceptions of their cities’  abilities to conduct the early response to RDD and IND attacks is not  necessarily related to whether or not a city had specific response plans.  Our analysis found that 10 of the 17 major cities perceived by their  emergency managers as being able to conduct all or almost all the  necessary response activities for an RDD attack did not have specific  RDD response plans. For IND attacks, three of the four major city  perceived by their emergency managers as able conduct all or almost all  of the necessary response activities for an IND attack did not have  specific IND response plans. Regarding the wide differences in  emergency managers’ perceptions of their cities’ abilities to respond,  FEMA officials told us that some cities will tend to overestimate the risks  of an RDD attack due to their lack of understanding about dispersed  radioactive material and underestimate their actual abilities to conduct  responses across the federal core response capabilities. They told us that  cities in states with nuclear power plants are likely to have a greater  understanding of the possible effects of a radiological attack and thus  might be able to assess the risks and their cities’ abilities to respond  better than other cities. These cities would have access to state technical  and resource assistance developed and exercised to respond to a  radiological dispersal incident at a nuclear power plant, which would have  some characteristics of the dispersal of radioactive material by an RDD.  Moreover, FEMA officials told us that cities closer to federal offices and  facilities tend to have more interaction with FEMA and NNSA subject  matter experts and are likely to have a greater understanding of the  nature of an RDD attack. In regard to IND attacks, FEMA officials told us  that they would expect that emergency managers would claim that such  an attack would overwhelm their city response resources and that their  city would need federal assistance across most federal core response  capabilities.
section_title: Limited Federal Guidance Available on Early Response Capabilities Needed by Major Cities for RDD Attacks, but More Available for IND Attacks
paragraphs: DHS has provided limited guidance on the early response capabilities  needed by cities for a large RDD attack based on the planning  assumptions contained in the National Planning Scenarios, but more such  guidance exists for the IND attack substantially based on the planning  assumptions contained in the National Planning Scenarios. DHS has  identified the core capabilities needed to respond to any catastrophic  incident but generally not the specific capabilities needed by cities for  early response to these attacks. DHS guidance contained in an annex  to the 2008 National Response Framework states that an RDD or IND  attack directed at a major city can have consequences that overwhelm  the capabilities of state and local governments and may also seriously  challenge existing federal response capabilities. In regard to RDD  response, this DHS guidance states that major cities should be able to  respond to small radiological releases with only occasional federal  assistance but does not address the large RDD attack depicted in the  National Planning Scenarios. According to FEMA and NNSA officials,  additional federal guidance may not be necessary because they expect  major cities to have the abilities to respond to a more likely smaller scale  RDD attack than the large RDD attack, as they would a hazardous  materials spill. If needed, the federal response to a hazardous materials  release is described in an emergency support function covering oil and  hazardous materials releases that is annexed to the National Response  Framework. DHS has also issued guidance on protective actions that  should be taken at various phases of response, including early response  to the dispersal of radioactive materials, such in an RDD attack.  However, the only detailed planning assumptions in current federal  guidance for an RDD attack are those in the National Planning Scenarios  and this is for a large RDD attack. DHS has not provided guidance on  the early response capabilities needed by major cities for such an attack.  According to NNSA officials, cities are likely to reach out for federal  support in the case of either a large or small-scale RDD attack due to the  rarity of the event and the high profile of any radiological emergency.
The federal government has issued more guidance pertaining to early  response to an IND attack substantially based on the National Planning  Scenario. In 2009, DHS issued an interim concept of operations plan for  the federal response to the IND attack. This federal operations plan  states that the federal priority in the first 24 hours is to assist in saving  lives and reducing casualties, while providing advice to those in the  incident area to shelter in the nearest structure and listen for instructions  from authorities. This federal operations plan also directs the states and  local governments to delineate control zones, coordinate evacuations,  make shelter-in-place decisions, issue protective action  recommendations, initiate decontamination procedures, and use the  National Guard to assist with environmental monitoring, but it provides  limited information on the capabilities needed to complete these actions.  In 2010, a federal interagency task force issued planning guidance to all  levels of government that expanded on the 2008 DHS planning guidance  by addressing gaps in IND response, expanding the discussion of needed  capabilities, and examining other IND scenarios beyond the one identified  in the National Planning Scenario. This 2010 guidance presents general  background information that builds a foundation for specific planning  recommendations on response to an IND attack during the first 24 to 72  hours prior to the arrival of significant federal resources. This guidance  states that other recommendations would be forthcoming, such as for  establishing critical communications among first responders. This  guidance recognizes that response planning must be done on a city- specific basis using city-specific impact assessments. However, this  guidance also points out that response to an IND will largely be provided  from neighboring jurisdictions, which would require advanced planning to  establish mutual aid and response protocols. Notwithstanding the specific  planning recommendations, the 2010 planning guidance does not detail  the early response capabilities needed by major cities to an IND attack in  relation to other sources of assistance. Without greater awareness of and  additional federal guidance on the capabilities needed by cities for early  response to both RDD and IND attacks, cities may not have the  information they need to adequately prepare for and respond to them.  Any gaps in response capabilities could lead to complications that result  in greater loss of life and economic impacts. Figure 4 provides a simple  illustration of the capability requirements for increasing levels of incident  effects, with an IND attack likely to be the highest level of incident effect.
FEMA is considering the need to develop a nuclear and radiological  annex, as depicted in figure 2, to help guide federal response activities  and possibly assist in the development of specific response plans for  RDD and IND attacks as supplements to city emergency operations  plans. This federal nuclear and radiological annex would be attached to  the forthcoming FIOPs—currently under review for approval—for the all  hazards planning framework for the response and recovery mission  areas.  FEMA officials told us that a nuclear and radiological annex may  be needed to supplement these FIOPs because their all hazards  orientation would not address several unique requirements and concepts  of operations specifically tailored to the needs for nuclear and radiological  incidents. The need for such an annex is also supported by a 2012 DHS  report that found the response and recovery needs after a radiological  attack differ from traditional all hazards incidents due to the need for  decontamination activities, heightened public anxiety, long-term risk  management, and substantial disruption to citizen’s lives and the  economy. FEMA officials said that if they decide to develop a nuclear  and radiological annex it could help guide adjustments to FEMA regional  operational plans. They also told us that these adjustments to the regional  operational plans may help encourage major cities in FEMA regions to  develop annexes to their all hazards emergency operations plans  covering specific RDD and IND response plans.
FEMA has not determined what it might include in the nuclear and  radiological annex or how to address RDD and IND response planning.  FEMA officials told us that this annex is expected to address RDD and  IND attacks, as well as a broader spectrum of radiological dispersal  incidents, such as nuclear power plant accidents. According to FEMA  guidance, separate hazards can be grouped under a more general  category, such as terrorist acts, but FEMA recognizes that problems can  arise that will affect subsequent analysis when grouping hazards with a  wide range of consequences under a single category, such as might be  the case with RDD and IND attacks. FEMA officials provided information  to compare the characteristics of RDD and IND attacks, as shown in table  4. One of the characteristics is the magnitude of the RDD and IND  attacks. FEMA officials told us that if they decided to develop the nuclear  and radiological annex, they would also consider the need to clarify the  planning assumptions for these incidents, particularly the RDD attack  scenario.
An additional FEMA consideration in developing the nuclear and  radiological annex to the FIOPs is the information recently gained from  the agency’s participation in a multigovernmental initiative to develop an  IND regional operations plan for Chicago, which is intended to guide  development of other regionally based IND operations plans. For  example, FEMA found that the development of this IND regional  operations plan provided information on needed early response  capabilities, coordination of stakeholder groups, the type and timing of  federal assistance, and the level of effort to complete the plan. The IND  planning team determined that the most feasible course of action to save  the greatest number of lives during early response involved concentrating  on a limited number of activities around public information and warning,  operational coordination and communications, on-scene security and  protection, situational assessment, and shelter-in-place and evacuation.
These activities are covered by 7 of the 14 federal core response  capabilities in the national preparedness goal. In addition, IND planning  team members told us that the planning effort gave them a greater  appreciation of the communication and coordination activities needed  across stakeholder groups to respond to an IND attack. The planning  effort involved more than 300 local, state, and federal emergency  management offices and private entities. Moreover, the IND planning  team was able to develop a detailed spreadsheet containing the type and  timing of assistance that might be available and needed—at the three  response phases—for an IND attack on Chicago. The development of the  plan has taken time and substantial funding. The IND planning process  has been under way since 2010, costing about $7.6 million, as of 2012,  when the plan was completed. This cost includes the project work of the  city, the state of Illinois, neighboring states, and federal agencies that  contributed to the development of the overall plan.
As a result of the IND planning effort in Chicago, FEMA officials told us  that they plan to use the information gained to assist other major cities  seeking to develop similar operations plans with regional partners. FEMA  officials told us that they also plan to undertake this planning initiative in  Boston, the District of Columbia, and Houston during fiscal year 2013,  with planning initiatives in Los Angeles, New York and Philadelphia to  follow. In addition, FEMA officials told us that they plan to look for  geographic and infrastructure similarities, such as common building  structures and transportation systems in each region in order to expedite  the planning process and reduce planning costs for other cities in a  region. FEMA’s Response Planning Division has allocated about $3.8  million for IND planning activities for fiscal year 2013. FEMA officials also  told us that they thought that an IND response plan would be sufficient to  address most of the response needs after an RDD attack as well.
section_title: Most Major Cities Expressed Need for Federal Support for Early Response to RDD and IND Attacks
paragraphs: Emergency managers of major cities responding to our questionnaire  reported varying levels of need for federal support in early response to  RDD and IND attacks in the form of technical and resource assistance,  procedures and information for early response activities, and  preparedness funding. Emergency managers identified a number of areas  for federal technical and resource assistance, but we found limitations in  the federal guidance applicable to major cities on the type and timing of  this assistance. Emergency managers of major cities also reported the  need for federal government research that could improve procedures and  information for their early response to RDD and IND attacks. DHS has  supported working groups of subject matter experts to help mitigate  shortcomings in response capabilities for IND attacks, which may have  applications for improving RDD response capabilities. In addition,  emergency managers reported that a decrease in federal funding would  affect their abilities to conduct early response to RDD and IND attacks.
subsections: section_title: Major Cities Reported Need for Guidance on the Type and Timing of Federal Technical and Resource Assistance for Early Response to RDD and IND Attacks
paragraphs: Most emergency managers from major cities responding to our  questionnaire reported that they need federal technical and resource  assistance to support their early response to RDD and IND attacks, but  federal guidance on the type and timing of this assistance is not found in  a single document and may not be well understood by emergency  managers. Nineteen of 27 emergency managers perceive a need for  federal technical and resource assistance for early response to an RDD  attack, and 21 of them perceive a need for this assistance in early  response to an IND attack. Our analysis of questionnaire responses  determined that of the 14 core response capabilities, emergency  managers indicated that the capability most needing federal technical and  resource assistance for both RDD and IND attacks (11 of 27 cities each)  was situational assessment. Situational assessment provides decision  makers with technical information such as the nature and extent of the  hazard, its cascading effects, and the status of the response. For RDD  attacks, after situational assessment, the emergency managers’ next  most frequently cited federal assistance needs were the following: public health and medical services (8 of 27 cities), operational coordination (5 of 27 cities), and on-scene security and protection (5 of 27 cities).
For IND attacks, after situational assessment, the emergency managers’  next most frequently cited federal assistance needs were as follows: on-scene security and protection (5 of 27 cities), and public health and medical services (5 of 27 cities).
We also obtained several responses from emergency managers  regarding actions, such as planning, that the federal government should  take to help sustain and improve early response capabilities. For  example, one emergency manager commented that integrated RDD and  IND plans of local, state, and federal government roles and  responsibilities are nonexistent. Another emergency manager stated that  that the federal government should provide a model RDD and IND  response plan and templates to assist local jurisdictions’ efforts.
The type and timing of federal assistance to major cities during the early  response to an RDD or IND attack may not be well understood by all  major city emergency managers, even though some guidance is available  but in different documents. For example, in 2008, DHS issued guidance  on federal agency responsibilities for responding to incidents involving the  release of nuclear, radiological, and hazardous materials in the National  Response Framework, and introduced the concept of phases of response  in planning guidance for RDD and IND attacks. However, these and other  guidance documents do not contain complete information on the type and  timing of federal technical and resource assistance by response phases.  For RDD attacks, DHS has not provided specific operational guidance on  the type and timing of federal assistance that might be made available to  cities for early response, although some information is available in an  emergency support function annex to the National Response Framework.  For IND attacks, DHS identified the technical and resource activities that  federal agencies could provide to respond to an IND attack in a 2009  federal interim concept of operations plan and more recently in the 2012  IND regional operations plan for Chicago. In addition, federal agencies  have provided various descriptions of the type and timing of the federal  assistance that might be available on their websites. However, FEMA  officials told us that the type and timing of the federal response would  depend on the proximity of the city to federal offices. Confusion over the  type and timing of assistance, such as federal assistance in the case of  an IND attack, could produce a disjointed and untimely early response to  the attack that might increase its consequences.
Based on information from a variety of sources, some of which may not  be readily available to major cities, we developed an illustration of the  federal agencies most likely to assist these cities during early response  with activities associated with the core capabilities they claim they can  support after an IND attack. While other federal agencies are involved  through their emergency support functions under the National Response  Framework, a senior FEMA official told us that the four federal agencies  we identified in figure 5 would be the most involved during the first 24  hours after an IND attack. Figure 5 provides an illustration of the federal  technical and resource support for the core capabilities necessary for  major city early response to an IND attack.
Most emergency managers responding to our questionnaire indicated that  their cities perceive a need for federal government research that could  improve procedures or information for their early response to RDD and  IND attacks. Using DHS guidance, we developed a list of 10 topic areas  for federal government research initiatives that could improve procedures  or information used by cities during the first 24 hours after the detonation  of an RDD or IND. We asked emergency managers for their opinions on  how much impact, if any, each topic area might have on improving their  city’s capability for early response to an RDD or IND attack. For example,  emergency managers from two-thirds of the major cities (18 of 27 cities)  identified communicating a sheltering-in-place strategy to the public and  communicating potential impacts of radiation exposure to the public as  the topic areas having the highest impact. Figure 6 shows emergency  managers’ responses identifying the topic areas their city considers  important for improving procedures or information necessary for early  response to RDD and IND attacks.
We compared the emergency managers’ responses on the impact that  improved procedures and information might have on their city’s early  response to RDD and IND attacks with the research initiatives being  considered by six FEMA IND focus working groups to determine if they  align. FEMA has established these working groups of subject matter  experts to mitigate shortcomings in response capabilities for an IND  attack, such as clarifying responsibilities and coordinating efforts among  government levels and federal agencies. We found that the areas  addressed by the working groups through their initiatives are generally  the same as those topic areas emergency managers reported as having a  high impact on procedures and information needed for early response to  an RDD and IND attack.
FEMA does not have current plans to identify or attempt to fill potential  gaps in capabilities for early response specifically to an RDD attack.  However, IND focus area working group experts and a senior FEMA  official told us that their efforts to fill gaps in IND capabilities and all  hazards plans would have application for other catastrophic hazards,  including RDD attacks. For example, they told us that RDD and IND  attacks share some common attributes, such as (1) the release of  radiological materials, (2) the need for decontamination and radiation  treatment, and (3) prioritization of response resources and personnel  based on ethical, philosophical, legal, and practical decision tools. In  addition, both types of attacks also require communication of consistent  information about radiation effects on general health outcomes and  protective measures. Further, NNSA officials told us they also have  several programs that might apply to RDD, as well as IND planning and  capability enhancements.
section_title: Major Cities See Need for Federal Funding to Maintain Early Response to RDD and IND Attacks
paragraphs: Most emergency managers responding to our questionnaire indicated that  their cities need federal funding to maintain current early response  capabilities to an RDD or IND attack. Almost all emergency managers (24  of 27 cities for RDD and 23 of 27 cities for IND) indicated that their city  needs federal funding to maintain current early response capabilities.  According to the 2008 National Response Framework, response  capabilities are developed within the national preparedness system  through effective planning, coordinating, training, equipping, and  exercising activities. These activities are essential elements of an  integrated, capability-based approach to preparedness. Emergency  managers reported that a decrease in federal funding would affect the  degree to which each of these activities builds the capabilities needed for  early response to an RDD or IND attack. Our analysis of questionnaire  results indicated that about a third of 27 cities identified equipment,  training, and planning activities important to the capabilities that would be  most affected by a decrease in federal preparedness funding, with fewer  cities indicating that coordination and exercising would be affected.
Federal funding to support preparedness against terrorist attacks and  other catastrophic incidents such as RDD and IND attacks currently  comes from seven DHS grant programs. In fiscal year 2013, DHS  allocated more than $1.5 billion for these seven grant programs, but  officials in charge of these programs were unable to determine how much  of the funding was used by major cities to improve early RDD and IND  response capabilities. Two of the DHS grant programs that have been  most relevant to response preparation for an RDD or IND attack are the  Homeland Security Grant Program and the temporary (fiscal years 2008  to 2011) Regional Catastrophic Planning Grant Program. In fiscal year  2013, DHS allocated more than $968 million to the Homeland Security  Grant Program, and more than half (roughly $560 million) was allocated  to Urban Areas Security Initiative grants, a portion of which goes to law  enforcement terrorism prevention activities. The Regional Catastrophic  Planning Grant Program awarded $14 million in grants in fiscal year 2011,  the last year it made awards, to support regional planning efforts to  address catastrophic incidents. For example, these funds were used by  New York and New Jersey to develop RDD and IND response plans and  were also combined with other federal funding to support development of  the IND regional operations plan for Chicago. According to members of  the IND planning team for Chicago, the Regional Catastrophic Planning  Grant Program provided the funding to bring together the many  stakeholder groups that would be involved in responding to an IND attack  and, without continued funding, it would be difficult to maintain the same  level of collaboration. Appendix III provides a detailed breakdown of the  seven federal grant programs for fiscal year 2013.
section_title: Conclusions
paragraphs: DHS has recognized that the early response to catastrophic incidents  such as an RDD or IND attack on a major city is critical and has to come  first from the city and surrounding jurisdictions. While cities are assumed  to be preferred targets for an RDD or IND attack, in response to our  questionnaire, many emergency managers indicated that their cities  ranked the risk of these attacks as lower than other hazards their cities  face, and fewer than half of the cities have specific response plans for  such attacks. City emergency managers rely on federal guidance to  prepare all hazards emergency operations plans and also specific  response plans for hazards of concern that can be annexed to these  emergency operations plans at the discretion of the city. However, we  found limitations in the federal planning guidance applicable to the early  response capabilities needed by cities for an RDD attack of the size  depicted in the National Planning Scenarios. More federal planning  guidance applicable to major cities has been developed for IND response,  primarily based on the event depicted in the National Planning Scenarios,  but this guidance does not detail the early response capabilities needed  by major cities in relation to other sources of assistance. Perceptions of  emergency managers varied widely on their cities’ abilities to conduct the  activities needed for early response to the type of RDD attacks described  in the National Planning Scenarios—with assistance from surrounding  jurisdictions but not the federal government—from being able to conduct  all activities for early response to being able to conduct few early  response activities. Less variation was evident for perceived early  response abilities to an IND attack—considering this same source of  assistance—with many cities indicating that such an attack would  overwhelm their response abilities. Most cities indicated the need for  federal technical and resource assistance—among other areas of federal  support—for early response to RDD and IND attacks, but we found that  complete guidance on the type and timing of this assistance is not readily  available in a single document and is not well understood by all major city  emergency managers. Any confusion over the type and timing of federal  assistance could produce a disjointed and untimely early response to an  attack that might increase its consequences. Without greater awareness  of existing federal guidance and continued actions to close gaps in the  guidance applicable to cities’ early response to RDD and IND attacks,  some cities may not have the information they need to adequately  prepare for and respond to them. Lack of adequate response planning  could lead to complications that result in greater loss of life and economic  impacts.
section_title: Recommendation for Executive Action
paragraphs: To provide assistance to major cities in planning for early response to  RDD and IND attacks, we recommend that the Secretary of Homeland  Security direct the Administrator for the Federal Emergency Management  Agency to promote greater awareness of existing federal guidance and  develop additional guidance where appropriate to clarify the capabilities  needed by cities for these attacks, including the planning assumptions for  an RDD attack and the type and timing of federal assistance for early  response.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DHS and to DOE through NNSA for  review and comment. DHS did not concur with our recommendation and  provided written comments, which are reproduced in appendix IV. In  addition, in an e-mail received August 27, 2013, the Director, Audit  Coordination and Internal Affairs Office of Management and Budget (NA- MB-1.1) for NNSA stated that as the recommendations in the report are  directed to DHS and FEMA, NNSA would not be preparing a formal  response. DHS and NNSA provided technical comments, which we  incorporated as appropriate.
In the comment letter, DHS states that FEMA program officials and  subject matter experts are concerned that our survey may have resulted  in the receipt of skewed data and information that affected our analysis  and conclusions. For example, the letter stated that some respondents  may have believed that an IND/RDD event would or could be fully  handled at the local level and therefore provided inputs partial toward  taking on an inordinate level of responsibility. They also stated that our  recommendation runs contrary to the survey results which illustrate a  trend of grouping RDD and IND attacks for analysis and planning. We  disagree. Our questionnaire explicitly asked city emergency managers to  consider response assistance from surrounding jurisdictions in their  assessment of response abilities, and only exclude federal assistance. In  this way, we were able to isolate the perceived need for federal support,  which we found for technical and resource assistance, improved  procedures and information, and funding. Further, emergency managers  did not provide trend information through their questionnaire responses  on assessing RDD and IND risks, and cities more often separated the  assessment of RDD and IND risks than combined them as DHS indicated  in its comment letter. In addition, we took a number of steps to develop  the questionnaire and to identify the best source for a response. For  example, we conducted extensive pretesting and obtained comments on  a draft questionnaire from officials at FEMA’s National Preparedness  Assessment Division. We also determined that city emergency managers  were in the best position to provide a city-wide perspective on this issue,  but we allowed them to seek advice from other city officials as necessary.
In its comment letter, DHS stated that neither the department nor FEMA  believes that our recommendation that FEMA develop additional  guidance in a single document to clarify the capabilities needed by cities  for these attacks, including the planning assumptions for an RDD attack  and addressing the type and timing of federal assistance for early  response takes into sufficient account advances made to the  preparedness system. In addition, the comment letter states that FEMA  program officials and subject matter experts believe the recommendation  does not align with our survey results or all-hazard risk management for  worst case catastrophic scenarios. It also states that FEMA has concerns  with the report’s characterization of the nation’s ability to respond to a  nuclear and/or radiological attack. Furthermore, the letter states that  additional RDD response guidance in a single document would be  counterproductive to the existing planning and guidance structure for IND  and all hazards incidents. As we note in the report, FEMA is already  considering development of a nuclear and radiological incident annex to  the FIOPs for the response and recovery mission areas based on the  recognition that the all hazards approach may be insufficient to cover the  unique response needs for nuclear and radiological incidents. While our  recommendation did not specify how FEMA should provide this additional  guidance, we have added language to the recommendation to clarify that  that we are not recommending a single guidance document to cover only  RDD response. In addition, to address the DHS/FEMA concern that city  emergency managers may not be fully informed about available  guidance, we added language to the recommendation for FEMA to  promote greater awareness of existing federal guidance.
More generally, DHS’ comment letter states that FEMA officials do not  believe we provided adequate context for the National Preparedness  System as defined by Presidential Policy Directive 8, which may cause  confusion for cold readers not familiar with how the directive has been  implemented. In addition, the comment letter states that the operational  frameworks, structures, and ongoing efforts that have been developed in  support of the directive’s comprehensive approach to national response  are not fully outlined in the report; specifically, the letter states that the  Nuclear and Radiological Incident Annex to the National Response  Framework and Emergency Support Functions as the nation’s  coordinating structures are not accurately portrayed and cites figure 5 as  an inaccurate and misleading depiction of the federal response for an  IND/RDD event. While the purpose of this report was not to conduct a  detailed assessment of federal guidance or implementation of the  directive, we added additional information about FEMA’s leadership role  in coordinating the federal response to nuclear and radiological incidents  within the context of the National Response Framework and its efforts to  develop IND response planning guidance. We also added that the  illustration in figure 5 of federal agency support for core response  capabilities that might be available to cities during the first 24 hours after  an IND attack does not include all federal agencies’ activities but only  those four agencies confirmed by a senior FEMA official as being most  present during this time period.
We are sending copies of this report to the Secretary of Homeland  Security and the Secretary of Energy, the appropriate congressional  committees, and other interested parties. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202)512-3841 or trimbled@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made contributions to this  report are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: In our review, we examined major cities’ (1) assessment of the risks of  RDD and IND attacks and the extent to which they have developed plans  for responding to them, (2) perceptions of their abilities to respond to  RDD and IND attacks in the first 24 hours (early response), and (3)  perceptions of their need for federal support in the early response to RDD  and IND attacks. To address these questions we sent a questionnaire to  major city emergency managers, and we conducted interviews with  outside experts and federal, state, and local officials.
To gather information from major U.S. cities relevant to all three of our  objectives, we developed a questionnaire for the directors of emergency  management for each of the 31 major cities that were in the Urban Areas  Security Initiative (UASI) program in fiscal year 2012. We chose the  major cities within each UASI region because in our document review, as  well as in interviews with the Federal Emergency Management Agency  (FEMA), UASI regions were identified as higher risk jurisdictions for  terrorist acts, including those using RDDs or INDs. As FEMA guidance  states that local jurisdictions should plan and develop capabilities to  respond to incidents based on risk, these jurisdictions are in need of  developing plans and preparing for the response to RDD and IND attacks.  Each of the 31 UASI locations covers a large metropolitan area that  includes many local governments. For example, the Chicago UASI  includes 3 states, 14 counties, and 10 principal cities. It did not serve our  purpose to send the questionnaire directly through the UASI structure  itself as the number of jurisdictions involved could introduce issues of  reliability in the answers, as well as consistency in terms of the process  used by each UASI to fill out our questionnaire. FEMA officials told us that  the largest metropolitan area within each UASI constitutes the area at the  highest risk for attack in each jurisdiction. In addition, we selected city  emergency managers to receive the questionnaire because they were in  the best position to provide a city-wide perspective on the level of  preparedness to respond to RDD and IND attacks. Therefore, we chose  to send questionnaires to only the emergency managers of these large  metropolitan areas. The emergency management offices in Atlanta and  Newark did not respond to our contact attempts, so we sent out  questionnaires to the 29 cities that did reply. In developing our  questionnaire, we developed questions that addressed all three of the  report objectives and had these reviewed both internally, as well as by  staff of FEMA’s National Preparedness Assessment Division. We  conducted seven cognitive pretests with emergency management officials  and first responders from major cities selected for their geographic  location and population size in order to minimize errors that might occur  from respondents who interpreted our questions differently than we  intended. During these pretests, we also interviewed these emergency  management officials and first responders to gain additional context  regarding their city’s preparedness for responding to either an RDD or  IND attack.
The questionnaire was implemented as a self-administered Microsoft  Word form e-mailed to respondents. We sent e-mail notifications to  emergency managers beginning on December 11, 2012. We then sent  the questionnaire and a cover e-mail to officials on December 12, 2012,  and asked them to fill in the questionnaire form and e-mail it back to us  within 3 weeks. To encourage emergency managers to complete the  questionnaire, we sent e-mail reminders and a replacement questionnaire  to nonrespondents approximately 1 week after, and again 3 weeks after,  the initial questionnaire was distributed. We also made follow-up phone  calls to nonrespondents from January 24, 2013, to February 8, 2013. We  closed the questionnaire on February 20, 2013. We received 27  completed questionnaires for an overall response rate of 87 percent— Phoenix and San Antonio did not return the questionnaire. Because we  attempted to collect data from each of the UASI major cities rather than a  sample of major cities, there was no sampling error. However, the  practical difficulties of conducting any questionnaire may introduce errors,  commonly referred to as nonsampling errors. For example, differences in  how a particular question is interpreted, the sources of information  available to respondents, how the responses were processed and  analyzed, or the types of people who do not respond can influence the  accuracy of the questionnaire results. We took steps in the development  of the questionnaire, the data collection, and the data analysis to  minimize these nonsampling errors and help ensure the accuracy of the  answers that were obtained. For example, a GAO social science  questionnaire specialist designed the questionnaire, in collaboration with  GAO staff with subject matter expertise. The draft questionnaire was  pretested to ensure that questions were relevant, clearly stated, and easy  to comprehend. The questionnaire was also reviewed by external experts  and a second GAO questionnaire specialist. Data were electronically  extracted from the Microsoft Word form questionnaires into a comma- delimited file that was then imported into a statistical program for  analyses. No manual data entry was performed, thereby removing an  additional potential source of error. We examined the questionnaire  results and performed computer analyses to identify inconsistencies and  other indications of error and addressed such issues as were necessary.  Additionally, we contacted respondents to clarify ambiguous responses  when necessary. Quantitative data analyses and the compilation of open- ended responses were conducted by the first GAO questionnaire  specialist using statistical software and working directly with GAO staff  with subject matter expertise. An independent GAO data analyst checked  the statistical computer programs for accuracy.
Responses to closed-ended (e.g., Yes/No) questions were summarized  as standard descriptive statistics. Responses to open-ended (i.e.,  narrative) questions were analyzed through content analysis. In  conducting the content analysis, one GAO analyst reviewed each open- ended response from each emergency manager to identify recurring  themes. Using the identified themes, the analyst then developed  categories for coding the responses. A second GAO analyst reviewed the  responses from each emergency manager and reviewed the first  analyst’s themes and categories to reach concurrence on the themes and  categories. Each of the two GAO analysts then independently reviewed  the answers to all open-ended questions and placed them into one or  more of the categories. The analysts then compared their coding to  identify any disagreements and reached agreement on all items through  discussion. For the analysis of the open-ended responses on the city’s  ability to respond to either an RDD or IND, we developed six categories  based on the number of early response activities a city stated it could  provide. Specifically, we reviewed the responses looking for whether the  city would be overwhelmed, the number of specific activities the city  stated it would conduct, and significant challenges it would face after the  attack.
To provide important context regarding current federal activities that  relate to our second and third objectives on RDD and IND response  planning and federal response capabilities, we traveled to Chicago to  meet with federal, regional, state, and city planners who had participated  in the interagency IND regional planning effort. In addition, we met with  Department of Homeland Security and FEMA officials to learn how they  may use insights gained from the interagency IND regional planning effort  in Chicago for use in other major cities and for developing a potential  nuclear and radiological annex to the draft federal interagency operational  plans for the response and recovery mission areas.
To obtain additional information for our third objective on the need and  availability of federal early response support, we interviewed officials  involved with federal research initiatives to close gaps in response  capabilities, as well as those who oversaw planning funds and federal  technical and resource assistance activities for RDD and IND attacks.  Specifically, we interviewed FEMA emergency management interagency  working groups, response planning, and grants officials; National Nuclear  Security Administration emergency management response operations  officials; Department of Energy national laboratory officials; and subject  matter experts. We also reviewed relevant federal guidance documents.
We conducted this performance audit from June 2012 to September 2013  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Questionnaire
section_title: Appendix III: Fiscal Year 2013 DHS Preparedness Grant Programs Funding Awarded
paragraphs: Appendix III: Fiscal Year 2013 DHS  Preparedness Grant Programs Funding  Awarded Grant programs purpose  For states and urban areas to prevent, protect against,  mitigate, respond to, and recover from acts of terrorism and  other threats.
FY 2013 funding  awarded  Over $968 million (HSGP)  Over $354 million (SHSP)  Over $558 million (UASI)  $55 million (OPSG)  Over $968 million (HSGP)
To support the implementation of state homeland security  strategies to build and strengthen preparedness capabilities  at all levels.
To enhance regional preparedness and capabilities in 31  high-threat, high-density areas.
To enhance cooperation and coordination among federal,  state, territorial, tribal and local law enforcement agencies to  jointly enhance security along the United States land and  water borders.
To assist state and local governments in enhancing and  sustaining all hazards emergency management capabilities.
Tribal Homeland Security Grant Program  To implement preparedness initiatives to help strengthen the  nation against risk associated with hazards including terrorist  attacks.
To support physical security enhancements for nonprofit  organizations determined to be at high risk of a terrorist  attack and located within one of the FY 2012 UASI-eligible  urban areas.
Intercity Passenger Rail (Amtrak) Program  To protect critical surface transportation infrastructure and  the traveling public from terrorism and increase Amtrak rail  system resilience.
To protect critical port infrastructure from terrorism, enhance  maritime domain awareness, and strengthen risk  management capabilities to protect against improvised  explosive devices and other nonconventional weapons.
To protect critical surface transportation and the traveling  public from acts of terrorism and to increase the resilience of  transit infrastructure.
subsections: section_title: Total Awarded
section_title: Appendix IV: Comments from the Department of Homeland Security
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Ned Woodward, Assistant  Director; Cheryl Arvidson; Thomas Laetz; Eli Lewine; David Lysy; Mike  Silver; Kathy Smith; and Kiki Theodoropoulos made key contributions to  this report.