Disaster Response: Criteria for Developing and Validating Effective Response Plans
Published: 2010-09-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Among the lessons learned from the aftermath of Hurricane Katrina was that effective disaster response requires planning followed by the execution of training and exercises to validate those plans. The Federal Emergency Management Agency (FEMA) is responsible for disaster response planning. This testimony focuses on (1) criteria for effective disaster response planning established in FEMA's National Response Framework, (2) additional guidance for disaster planning, (3) the status of disaster planning efforts, and (4) special circumstances in planning for oil spills. This testimony is based on prior GAO work on emergency planning and response, including GAO's April 2009 report on the FEMA efforts to lead the development of a national preparedness system. GAO reviewed the policies and plans that form the basis of the preparedness system. GAO did not assess any criteria used or the operational planning for the Deepwater Horizon response.
section_title: What GAO Found
paragraphs: FEMA's National Response Framework identifies criteria for effective response and response planning, including (1) acceptability (meets the requirement of anticipated scenarios and is consistent with applicable laws); (2) adequacy (complies with applicable planning guidance); (3) completeness (incorporates major actions, objectives, and tasks); (4) consistency and standardization of products (consistent with other related documents); (5) feasibility (tasks accomplished with resources available); (6) flexibility (accommodating all hazards and contingencies); and (7) interoperability and collaboration (identifies stakeholders and integrates plans). In addition to the National Response Framework, FEMA has developed standards that call for validation, review, and testing of emergency operations plans. According to FEMA, exercises offer the best way, short of emergencies, to determine if such plans are understood and work. FEMA's guidance also suggests that officials use functional and full-scale emergency management exercises to evaluate plans. Other national standards reflect these practices as well. For example, the Emergency Management Accreditation Program standards call for a program of regularly scheduled drills, exercises, and appropriate follow-through activities, as a critical component of a state, territorial, tribal, or local emergency management program. GAO reported in April 2009 that FEMA lacked a comprehensive approach to managing the development of emergency preparedness policies and plans. Specifically, GAO reported that FEMA had completed many policy and planning documents, but a number of others were not yet completed. In February 2010, the Department of Homeland Security's (DHS) Office of Inspector General reviewed the status of these planning efforts and reported that the full set of plans for any single scenario had not yet been completed partly because of the time required to develop and implement the Integrated Planning System. The Integrated Planning System, required by Annex 1 to Homeland Security Presidential Directive 8 (December 2007), is intended to be a standard and comprehensive approach to national planning. Oil spills are a special case with regard to response. The National Response Framework has 15 functional annexes that provide the structure for coordinating federal interagency support for a federal response to an incident. Emergency Support Function #10--Oil and Hazardous Materials Response Annex--governs oil spills. Under this function, the Environmental Protection Agency is the lead for incidents in the inland zone, and the U.S. Coast Guard, within DHS, is the lead for incidents in the coastal zone. This difference underscores the importance of including clear roles, responsibilities, and legal authorities in developing operational response plans.
section_title: What GAO Recommends
paragraphs: GAO is not making any new recommendations in this testimony but has made recommendations to FEMA in previous reports to strengthen disaster response planning, including the development of a management plan to ensure the completion of key national policies and planning documents. FEMA concurred and is currently working to address this recommendation.

section_title: Letter
paragraphs: I am pleased to be here this morning to discuss the importance of  preparing, validating, and testing emergency operations plans for disaster  response. Among the lessons learned from the aftermath of Hurricane  Katrina was that effective disaster response requires planning followed by  the execution of training and exercises to validate those plans. The  development of detailed emergency operations plans and the validation of  those plans through testing and exercising is a key component of effective  disaster response planning. These plans are part of a broader cycle of  emergency preparedness that includes policy development, planning and  resource allocation, exercising and testing operational plans, and  assessment and reporting.
To help guide federal emergency response planning, the Federal  Emergency Management Agency (FEMA) developed the National  Response Framework, in conjunction with a variety of stakeholders, as a  blueprint for how the nation conducts response to hazards of any type,  regardless of cause. The National Response Framework, which was  issued in January 2008, describes planning as the cornerstone of national  preparedness and a critical element for response to a disaster or  emergency. Response plans define the roles and responsibilities of all  those who will have a role in the response and the capabilities they will  contribute to the effort and provide a blueprint for how the response will  be directed, managed, and coordinated.  In addition, in June 2010, as part  of its Voluntary Private Sector Preparedness Accreditation and  Certification Program, FEMA adopted three private sector standards for  use by U.S. companies in emergency planning and response. These  standards provide that organizations should test and evaluate the  appropriateness and efficacy of their emergency response plans.
My comments are based on our previously issued work on emergency  planning and response over the last several years, including our April 2009  report on FEMA’s efforts to lead the development of a national  preparedness system. Specifically, my testimony today focuses on (1) the  criteria for effective disaster response planning established in FEMA’s  National Response Framework, (2) additional guidance for disaster  response planning, (3) the status of national disaster response planning  efforts, and (4) the special circumstances related to operational response  planning for oil spills.
To address these objectives, we reviewed the policies and plans that form  the basis of the preparedness system. These policies and plans include,  among others, the National Response Framework and National  Preparedness Guidelines, as well as the national integrated planning  system and preliminary versions of related guidance to develop and  integrate plans across federal, state, tribal, and local governments. We also  reviewed the Department of Homeland Security’s (DHS) Office of  Inspector General report on the status of FEMA’s disaster response  planning efforts. For the purposes of this testimony, we did not assess any  criteria used or the operational planning for the Deepwater Horizon response.   More detailed information about our scope and methodology is included in  our April 2009 report. We conducted this work in accordance with  generally accepted government auditing standards.
subsections: section_title: National Response Framework’s Criteria for Response Planning
paragraphs: The National Response Framework discusses several elements of  effective response and response planning. The term response, as used in  the National Response Framework, includes the immediate actions to  save lives, protect property and the environment, and meet basic human  needs. Response also includes the execution of emergency plans and  actions to support short-term recovery. An effective, unified national  response—including the response to any large-scale incident—requires  layered, mutually supporting capabilities—governmental and  nongovernmental. Indispensable to effective response is an effective  unified command, which requires a clear understanding of the roles and  responsibilities of each participating organization.
The National Response Framework employs the following criteria to  measure key aspects of response planning:
Acceptability. A plan is acceptable if it can meet the requirements of  anticipated scenarios, can be implemented within the costs and time  frames that senior officials and the public can support, and is  consistent with applicable laws.
Adequacy. A plan is adequate if it complies with applicable planning  guidance, planning assumptions are valid and relevant, and the  concept of operations identifies and addresses critical tasks specific to  the plan’s objectives.
Completeness. A plan is complete if it incorporates major actions,  objectives, and tasks to be accomplished. The complete plan addresses  the personnel and resources required and sound concepts for how  those will be deployed, employed, sustained, and demobilized. It also  addresses timelines and criteria for measuring success in achieving  objectives and the desired end state. Including all those who could be  affected in the planning process can help ensure that a plan is  complete.
Consistency and standardization of products. Standardized  planning processes and products foster consistency, interoperability,  and collaboration, therefore, emergency operations plans for disaster  response should be consistent with all other related planning  documents.
Feasibility. A plan is considered feasible if the critical tasks can be  accomplished with the resources available internally or through  mutual aid, immediate need for additional resources from other  sources (in the case of a local plan, from state or federal partners) are  identified in detail and coordinated in advance, and procedures are in  place to integrate and employ resources effectively from all potential  providers.
Flexibility. Flexibility and adaptability are promoted by decentralized  decisionmaking and by accommodating all hazards ranging from  smaller-scale incidents to wider national contingencies.
Interoperability and collaboration. A plan is interoperable and  collaborative if it identifies other stakeholders in the planning process  with similar and complementary plans and objectives, and supports  regular collaboration focused on integrating with those stakeholders’  plans to optimize achievement of individual and collective goals and  objectives in an incident.
section_title: Additional Guidance and Policy regarding Operational Plans and Testing
paragraphs: Under the Post-Katrina Emergency Management Reform Act, FEMA has  responsibility for leading the nation in developing a national preparedness  system. FEMA has developed standards—the Comprehensive  Preparedness Guide 101—that call for validation, review, and testing of  emergency operations plans (EOP),. According to the Comprehensive  Preparedness Guide 101, plans should be reviewed for conformity to  applicable regulatory requirements and the standards of federal or state  agencies (as appropriate) and for their usefulness in practice. Exercises  offer the best way, short of emergencies, to determine if an EOP is  understood and “works.” Further, conducting a “tabletop” exercise  involving the key representatives of each tasked organization can serve as  a practical and useful means to help validate the plan. FEMA’s guidance  also suggests that officials use functional and full-scale emergency  management exercises to evaluate EOPs. Plan reviews by stakeholders  also allow responsible agencies to suggest improvements in an EOP based  on their accumulated experience.
We also identified the need for validated operational planning in the  aftermath of Hurricane Katrina, noting that to be effective, national  response policies must be supported by robust operational plans. In  September 2006, we recommended, among other things, that DHS take the  lead in monitoring federal agencies’ efforts to meet their responsibilities  under the National Response Plan (now the National Response  Framework) and the National Preparedness Goal (now the National  Preparedness Guidelines), including the development, testing, and  exercising of agency operational plans to implement their responsibilities.  DHS concurred with our recommendation. The Post-Katrina Emergency  Management Reform Act transferred preparedness responsibilities to  FEMA, and we recommended in April 2009 that FEMA should improve its  approach to developing policies and plans that define roles and  responsibilities and planning processes by developing a program  management plan, in coordination with DHS and other federal entities, to  ensure the completion of the key national preparedness policies and plans  called for in legislation, presidential directives, and existing policy and  doctrine; to define roles and responsibilities and planning processes; as  well as to fully integrate such policies and plans into other elements of the  national preparedness system. FEMA concurred with our  recommendation and is currently working to address this  recommendation.
Other national standards reflect these practices as well. For example,  according to Emergency Management Accreditation Program (EMAP)  standards, the development, coordination and implementation of  operational plans and procedures are fundamental to effective disaster  response and recovery. EOPs should identify and assign specific areas of  responsibility for performing essential functions in response to an  emergency or disaster. Areas of responsibility to be addressed in EOPs  include such things as evacuation, mass care, sheltering, needs and  damage assessment, mutual aid, and military support. EMAP standards  call for a program of regularly scheduled drills, exercises, and appropriate  follow-through activities—designed for assessment and evaluation of  emergency plans and capabilities—as a critical component of a state,  territorial, tribal or local emergency management program. The  documented exercise program should regularly test the skills, abilities,  and experience of emergency personnel as well as the plans, policies,  procedures, equipment, and facilities of the jurisdiction. The exercise  program should be tailored to the range of hazards that confronts the  jurisdiction.
section_title: Status of National Disaster Planning Efforts
paragraphs: We reported in April 2009 that FEMA lacked a comprehensive approach to  managing the development of emergency preparedness policies and  plans. Specifically, we reported that FEMA had completed many policy  and planning documents, but a number of others were not yet completed.  For example, while DHS, FEMA, and other federal entities with a role in  national preparedness have taken action to develop and complete some  plans that detail and operationalize roles and responsibilities for federal  and nonfederal entities, these entities had not completed 68 percent of the  plans required by existing legislation, presidential directives, and policy  documents as of April 2009.
Specifically, of the 72 plans we identified, 20 had been completed (28  percent), 3 had been partially completed (that is, an interim or draft plan  has been produced—4 percent), and 49 (68 percent) had not been  completed. Among the plans that have been completed, FEMA published  the Pre-Scripted Mission Assignment Catalog in 2008, which defines roles  and responsibilities for 236 mission assignment activities to be performed  by federal government entities, at the direction of FEMA, to aid state and  local jurisdictions during a response to a major disaster or an emergency.  Among the 49 plans that had not been completed were the National  Response Framework incident annexes for terrorism and cyberincidents  as well as the National Response Framework’s incident annex  supplements for catastrophic disasters and mass evacuations. In addition,  operational plans for responding to the consolidated national planning  scenarios, as called for in Homeland Security Presidential Directive 8,  Annex 1, remained outstanding.
In February 2010, DHS’s Office of Inspector General reviewed the status of  these planning efforts and reported that the full set of plans for any single  scenario had not yet been completed partly because of the time required  to develop and implement the Integrated Planning System. The  Integrated Planning System, required by Annex 1 to Homeland Security  Presidential Directive 8 (December 2007), is intended to be a st comprehensive approach to national planning. The Directive calls for the  Secretary of Homeland Security to lead the effort to develop, in  coordination with the heads of federal agencies with a role in homeland  security, the Integrated Planning System followed by a series of related  andard and  planning documents for each national planning scenario. The Homeland  Security Council compressed the 15 National Planning Scenarios into 8  key scenario sets in October 2007 to integrate planning for like events and  to conduct crosscutting capability development.  The redacted version of  the Inspector General’s report noted that DHS had completed integrated  operations planning for 1 of the 8 consolidated national planning  scenarios—the terrorist use of explosives scenario.  FEMA officials  reported earlier this month that the agency’s efforts to complete national  preparedness planning will be significantly impacted by the  administration's pending revision to Homeland Security Presidential  Directive-8.  Once the new directive is issued, agency officials plan to  conduct a comprehensive review and update to FEMA’s approach to  national preparedness planning.
In addition to FEMA’s planning efforts, FEMA has assessed the status of  catastrophic planning in all 50 States and the 75 largest urban areas as part  of its Nationwide Plan Review. The 2010 Nationwide Plan Review was  based on the 2006 Nationwide Plan Review, which responded to the need  both by Congress and the President to ascertain the status of the nation’s  emergency preparedness planning in the aftermath of Hurricane Katrina.   The 2010 Nationwide Plan Review compares the results of the 2006 review  of states and urban areas' plans, functional appendices and hazard-specific  annexes, on the basis of:
Consistency with Comprehensive Preparedness Guide 101,
Date of last plan update,
Date of last exercise, and
A self-evaluation of the jurisdiction’s confidence in each planning  document’s adequacy, feasibility and completeness to manage a  catastrophic event.
FEMA reported in July 2010 that more than 75 percent of states and more  than 80 percent of urban areas report confidence that their overall basic  emergency operations plans are well-suited to meet the challenges  presented during a large-scale or catastrophic event.
section_title: Operational Response Plans for Oil Spill Responses
paragraphs: Oil spills are a special case with regard to response. For most major  disasters, such as floods or earthquakes, a major disaster declaration  activates federal response activities under the provisions of the Robert T.  Stafford Disaster Relief and Emergency Assistance Act. However, for oil  spills, federal agencies may have direct authority to respond under specific  statutes.  Response to an oil spill is generally carried out in accordance  with the National Oil and Hazardous Substances Pollution Contingency  Plan. The National Response Framework has 15 functional annexes,  such as search and rescue, which provide the structure for coordinating  federal interagency support for a federal response to an incident.  Emergency Support Function #10, the Oil and Hazardous Materials  Response Annex, governs oil spills. As described in Emergency Support  Function #10, in general, the Environmental Protection Agency is the lead  for incidents in the inland zone, and the U.S. Coast Guard, within DHS, is  the lead for incidents in the coastal zone. The difference in responding to  oil spills and the shared responsibility across multiple federal agencies  underscores the importance of including clear roles, responsibilities, and  legal authorities in developing operational response plans.
In conclusion, Mr. Chairman, emergency preparedness is a never-ending  effort as threats evolve and the capabilities needed to respond to those  threats changes as well. Realistic, validated, and tested operational  response plans are key to the effective response to a major disaster of  whatever type. Conducting exercises of these plans as realistically as  possible is a key component of response preparedness because exercises  help to identify what “works” (validates and tests) and what does not.  This concludes my statement. I will be pleased to respond to any questions  you or other members of the committee may have.
section_title: Contacts and Acknowledgments
paragraphs: For further information on this statement, please contact William O.  Jenkins, Jr. at (202) 512-8757 or JenkinsWO@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found on  the last page of this statement.
Key contributors to this statement were Stephen Caldwell, Director, Chris  Keisling, Assistant Director, John Vocino, Analyst-In-Charge, Linda Miller,  Communications Analyst.
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