Homeland Security: Process for Reporting Lessons Learned from	 
Seaport Exercises Needs Further Attention (14-JAN-05,		 
GAO-05-170).							 
                                                                 
Seaports are a critical vulnerability in the nation's defense	 
against terrorism. They are potential entry points for bombs or  
other devices smuggled into cargo ships and ports'		 
often-sprawling nature presents many potential targets for	 
attack. To assess the response procedures that would be 	 
implemented in an attack or security incident, officials conduct 
port-specific exercises. Many federal, state, and local agencies 
may potentially be involved. The Coast Guard has primary	 
responsibility for coordinating these exercises and analyzing the
results. GAO examined (1) the emerging framework for coordinating
entities involved in security responses, (2) legal and		 
operational issues emerging from exercises conducted to date, and
(3) Coast Guard management of reports analyzing exercises. GAO	 
reviewed reports on 82 exercises from fiscal year 2004 and	 
observed 4 exercises as they were being conducted.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-170 					        
    ACCNO:   A15500						        
  TITLE:     Homeland Security: Process for Reporting Lessons Learned 
from Seaport Exercises Needs Further Attention			 
     DATE:   01/14/2005 
  SUBJECT:   Counterterrorism					 
	     Defense contingency planning			 
	     Facility security					 
	     Harbors						 
	     National preparedness				 
	     Interagency relations				 
	     National defense operations			 
	     Reporting requirements				 
	     Strategic planning 				 
	     Terrorism						 
	     Homeland security					 
	     Timeliness 					 

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GAO-05-170

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

January 2005

HOMELAND SECURITY

Process for Reporting Lessons Learned from Seaport Exercises Needs Further
                                   Attention

GAO-05-170

[IMG]

January 2005

HOMELAND SECURITY

Process for Reporting Lessons Learned from Seaport Exercises Needs Further
Attention

                                 What GAO Found

The framework under which federal agencies would manage a port-terrorism
incident is still evolving. The primary guidance for response, the
National Response Plan, was just issued in January 2005, and the National
Incident Management System, the structure for multiagency coordination, is
still being put in place. As a result, it is too early to determine how
well the complete framework will function in an actual incident.

GAO's review of fiscal year 2004 terrorism-related reports and exercises
identified relatively few legal issues, and none of these issues produced
recommendations for statutory changes. Most issues have instead been
operational in nature and have surfaced in nearly every exercise. They are
of four main types: difficulties in sharing or accessing information,
inadequate coordination of resources, difficulties in coordinating
effectively in a command and control environment, and lack of knowledge
about who has jurisdictional or decision-making authority.

Reports on the exercises often do not meet the Coast Guard's standards for
timeliness or completeness. Sixty-one percent of the reports were not
submitted within 60 days of completing the exercise-the Coast Guard
standard. The Coast Guard has implemented a new system for tracking the
reports, but after a year of use, timeliness remains a concern. The Coast
Guard has requirements for what the reports should contain, but 18 percent
of the reports did not meet the requirement to assess each objective of
the exercise. The Coast Guard has cited several planned actions that may
allow for improving completeness. These actions are still in development,
and it is too early to determine how much they will help.

Port Terrorism Exercise Conducted at the Port of Los Angeles/Long Beach

                 United States Government Accountability Office

Contents

       Letter                                                               1 
                                        Background                          3 
                                         Results                            4 
                                       Conclusions                          8 
                           Recommendation for Executive Action              8 
                                     Agency Comments                        8 
     Appendix I      Briefing on Legal and Operational Issues Identified 
                            from U.S. Port Terrorism Exercises           

  Appendix II Objectives, Scope, and Methodology

Abbreviations

AAR after-action reports
CG Coast Guard
CONPLAN Interagency Domestic Concept of Operations Plan
CPS Contingency Preparedness System
DHS Department of Homeland Security
DOD Department of Defense
DOJ Department of Justice
FAA Federal Aviation Administration
FEMA Federal Emergency Management Agency
FBI Federal Bureau of Investigation
FRERP Federal Radiological Emergency Response Plan
FRP Federal Response Plan
HSPD-5 Homeland Security Presidential Directive-5
ICS Incident Command Structure
INRP Initial National Response Plan
NCP National Contingency Plan
NIMS National Incident Management System
NRP National Response Plan

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separately.

United States Government Accountability Office Washington, DC 20548

January 14, 2005

The Honorable Bennie G. Thompson Ranking Minority Member Committee on
Homeland Security House of Representatives

The Honorable Robert E. Andrews House of Representatives

Seaports have emerged as a critical vulnerability in the nation's defense
against terrorism. More than 95 percent of the nation's overseas trade
passes through these ports, and the nation's economy is highly dependent
on an efficient transfer of goods flowing into and out of these gateways.
Seaports are vulnerable entry points for bombs or other devices smuggled
into cargo ships, and ports' often-sprawling nature presents many
potential targets for attack. But, the repercussions of such an attack go
far beyond the port immediately affected; an attack at one port could
disrupt the broader flow of goods, creating economic consequences in the
billions of dollars.

In the wake of the terrorist attacks of September 11, 2001, law
enforcement and other agencies have become more aware of the threats to
America's strategic targets and have taken steps to make ports more
secure. To assess coordination and response procedures that would be
implemented in the event of a terrorist attack, officials in U.S. ports
have conducted exercises that simulate a potential threat, attack, or
incident. These exercises have addressed such scenarios as the explosion
of a "dirty bomb" that releases radioactive materials, threats of an
approaching ship that may have a bomb or other hazardous material aboard,
or disruptive attacks on critical infrastructure or specific facilities
within a port. In fiscal year 2004, the United States Coast Guard, which
is the Department of Homeland Security agency with primary responsibility
for port security, conducted 85 port-based terrorism exercises.

Responding effectively in such exercise scenarios can be difficult.
Depending on the nature of the incident and the particular port involved,
dozens of federal, state, and local agencies may be involved. The incident
may also require close coordination across many jurisdictions, raising
issues about who has authority or how agency personnel can communicate
effectively when they have different chains of command,

operating procedures, and equipment. After these exercises are conducted,
the Coast Guard requires that the unit participating in the exercise
submit an "after-action" report describing the results and highlighting
any lessons learned. These reports are approved for content and lessons
learned by the commanding officer of that unit. Upon approval, each report
is electronically transmitted to Coast Guard headquarters for inclusion in
a master exercise database. Analysis of these reports presents an
opportunity to identify potential barriers to an effective response during
an actual threat or incident. These reports can also provide valuable
input for future exercises conducted by the Coast Guard or other agencies.

You asked that we examine what has been learned to date in the nation's
attempts to use such exercises to coordinate effective port security
procedures. Our specific objectives were to (1) describe the emerging
framework under which the federal government coordinates with state and
local entities to address a terrorist incident in a U.S. port; (2)
identify the issues, if any, regarding federal agencies' legal authority
that have emerged from port security exercises and what statutory actions
might address them; (3) describe the types of operational issues being
identified through these exercises; and (4) identify any management issues
related to Coast Guard-developed after-action reports. On December 8,
2004, we briefed your offices on the results of our work. Appendix I
contains the briefing slides we presented at that meeting.1

Our description of the emerging framework for coordinating an effective
response to a terrorist incident is based on our review of statutes,
regulations, directives, plans, and agency guidance, as well as interviews
with officials from various agencies at the federal, state, and local
levels. Our analysis of statutory and operational issues arising from
exercises is based on a review of 82 Coast Guard after-action reports on
terrorismrelated exercises conducted at U.S. ports in fiscal year 2004.2
In addition, to obtain a more in-depth understanding of exercise issues,
we attended

1On January 6, 2005, as this report was being finalized for printing, the
Department of Homeland Security issued the final version of the National
Response Plan, a plan discussed in several of the briefing slides. Some
details of the plan were changed in the final version and thus differ in a
few respects from the information presented in the slides. These
differences do not affect the conclusions or recommendations contained in
this report.

2As of December 1, 2004, all 85 after-action reports were required to be
submitted to the Coast Guard. Three reports had not been submitted by this
date. We conducted our content analysis on the 82 available reports.

four exercises at various locations around the country. Our evaluation of
management issues related to Coast Guard after-action reports included
interviews with officials at Coast Guard headquarters and in the field,
analysis of Coast Guard and Department of Homeland Security guidance, and
reliance on our prior work related to managing and evaluating exercises.
While our audit work allowed us to review a large number of exercises for
potential legal and operational issues, our analysis is limited to the
degree that, (1) for most exercises, we had to rely on
Coast-Guarddeveloped after-action reports rather than direct observation
and (2) the scope of the exercises themselves was designed around specific
plan elements and subject to resource constraints. Appendix II describes
our scope and methodology in more detail. We conducted our work from June
to December 2004 in accordance with generally accepted government auditing
standards.

                                   Background

On November 25, 2002, the President signed into law the Homeland Security
Act,3 which created the new federal Department of Homeland Security, and
the Maritime Transportation Security Act,4 which created a consistent
security program specifically for the nation's seaports. Since that time,
and in keeping with the provisions of these new laws, the federal
government has been developing a variety of new national policies and
procedures for improving the nation's response to domestic emergencies.
These policies and procedures are designed to work together to provide a
cohesive framework for preparing for, responding to, and recovering from
domestic incidents.

A key element of this new response framework is the use of exercises to
test and evaluate federal agencies' policies and procedures, response
capabilities, and skill levels. The Coast Guard has primary responsibility
for such testing and evaluation in the nation's ports and waterways, and
as part of its response, it has added multiagency and multicontingency
terrorism exercises to its training program. These exercises vary in size
and scope and are designed to test specific aspects of the Coast Guard's
terrorism response plans, such as communicating with state and local
responders, raising maritime security levels, or responding to incidents
within the port. For each exercise the Coast Guard conducts, an after

3Pub.L. 107-296. 4Pub.L. 107-295.

action report detailing the objectives, participants, and lessons learned
must be produced within 60 days.

  Results

    Coordination Framework Is Still Evolving

The framework under which federal agencies would coordinate with state and
local entities to manage a port-terrorism incident is still evolving. As
directed by Homeland Security Presidential Directive/HSPD-5, issued in
February 2003, this framework is designed to address all types of
responses to national emergencies, not just port-related events. Key
elements of the framework have been released over the past 2 years. For
example, the Department of Homeland Security released the Interim National
Response Plan in September 2003 and was in the final approval stage for a
more comprehensive National Response Plan in November 2004, as our work
was drawing to a close. DHS announced the completion of the National
Response Plan on January 6, 2005, too late for a substantive review to be
included in this report. However, the finalized plan is designed to be the
primary operational guidance for incident management and, when fully
implemented, will incorporate or supersede existing federal interagency
response plans. According to the updated implementation schedule in the
National Response Plan, federal agencies will have up to 120 days to bring
their existing plans, protocols, and training into accordance with the new
plan. In March 2004, the department also put in place a system, called the
National Incident Management System, which requires common principles,
structures, and terminology for incident management and multiagency
coordination. Although the framework that will be brought about by the
final plan, the management system, and other actions is still in the
implementation phase, some of the protocols and procedures contained in
this framework were already evident at the port exercises we observed.
However, it is still too early to determine how well the complete
framework will function in coordinating an effective response to a
port-related threat or incident.

Exercises Identified Few Port security exercises have identified
relatively few issues related to

Legal Issues 	federal agencies' legal authority, and none of these issues
were statutory problems according to exercise participants and agency
officials. Our review of fiscal year 2004 after-action reports and
observation of specific exercises showed that exercise participants
encountered seven legal issues, but exercise participants and agency
officials we interviewed did not recommend statutory changes to address
these issues. In three

instances, exercise participants made nonstatutory recommendations (such
as policy clarifications) to assist agencies in better exercising their
authority, but did not question the adequacy of that authority. In the
other four instances, no recommendations were made either because
statutory authority was deemed sufficient or, in one case, because the
issue involved a constitutional restraint (i.e., under the Fourth
Amendment, police are prohibited from detaining passengers not suspected
of terrorism).

While the exercises were conducted to examine a wide range of issues and
not specifically to identify gaps in agencies' legal authority, the
results of the exercises are consistent with the information provided by
agency officials we interviewed, who indicated that sufficient statutory
authority exists to respond to a terrorist attack at a seaport. Moreover,
when Department of Homeland Security officials reviewed the issue of
statutory authority, as required by Homeland Security Presidential
Directive/HSPD5, they concluded that federal agencies had sufficient
authority to implement the National Response Plan and that any
implementation issues could be addressed by nonstatutory means, such as
better coordination mechanisms.

    Exercises Identified Four Main Types of Operational Issues

Most of the issues identified in port security exercises have been
operational rather than legal in nature. Such issues appeared in most
afteraction reports we reviewed and in all four of the exercises we
observed. While such issues are indications that improvements are needed,
it should be pointed out that the primary purpose of the exercises is to
identify matters that need attention and that surfacing problems is
therefore a desirable outcome, not an undesirable one. The operational
issues can be divided into four main categories, listed in descending
order of frequency with which they were reported:

o  	Communication-59 percent of the exercises raised communication issues,
including problems with interoperable radio communications among first
responders, failure to adequately share information across agency lines,
and difficulties in accessing classified information when needed.

o  	Adequacy or coordination of resources-54 percent of the exercises
raised concerns with the adequacy or coordination of resources, including
inadequate facilities or equipment, differing response procedures or
levels of acceptable risk exposure, and the need for additional training
in joint agency response.

o  	Ability of participants to coordinate effectively in a command and
control environment-41 percent of the exercises raised concerns related to
command and control, most notably a lack of knowledge or training in the
incident command structure.

o  	Lack of knowledge about who has jurisdictional or decision-making
authority-28 percent of the exercises raised concerns with participants'
knowledge about who has jurisdiction or decision-making authority. For
example, agency personnel were sometimes unclear about who had the proper
authority to raise security levels, board vessels, or detain passengers.

After-Action Reports Show Our review of the Coast Guard's fiscal year 2004
after-action reports from Problems Related to port terrorism exercises
identified problems with timeliness in completing Timeliness and the
reports and limitations in the information they contained. Specifically,

Completeness  o  	Timeliness: Coast Guard guidance states that
after-action reports are an extremely important part of the exercise
program, and the guidance requires that such reports be submitted to the
after-action report database (Contingency Preparedness System) within 60
days of completing the exercise. However, current practice falls short: 61
percent of the 85 afteraction reports were not submitted within this
60-day time frame. Late reports were submitted, on average, 61 days past
the due date. Exercises with late reports include large full-scale
exercises designed to identify major interagency coordination and response
capabilities. Not meeting the 60-day requirement can lessen the usefulness
of these reports. Coast Guard guidance notes, and officials confirm, that
exercise planners should regularly review past after-action reports when
planning and designing future exercises, and to the extent that reports
are unavailable, such review cannot be done. In previous reviews of
exercises conducted by the Coast Guard and others, we found that timely
after-action reports were necessary to help ensure that potential lessons
can be learned and applied after each counterterrorism exercise.5 The main
problem in producing reports on a more timely basis appeared to be one of
competing priorities: Coast Guard field personnel indicated that other
workload priorities were an impediment to completing reports, but most of
them also said 60 days is a sufficient amount of time to develop and
submit an after-action report.

5See GAO, Combating Terrorism: Selected Challenges and Related
Recommendations, GAO-01-822 (Washington, D.C.: Sept 20, 2001).

Officials cited the development of the Contingency Preparedness System,
which is the program for managing exercises and after-action reports, as a
step allowing for a renewed emphasis on timeliness. Headquarters planning
staff are able to run reports using this system and regularly notify key
Coast Guard officials of overdue after-action reports. However, this
system was implemented more than 1 year ago, in August 2003, and was,
therefore, in place during the period in which we found a majority of
afteraction reports were late. We did not compare our results with
timeliness figures for earlier periods, and we, therefore, do not know the
extent to which the system may have helped reduce the number of reports
that are submitted late. Even if the new system has produced improvement,
however, the overall record is still not in keeping with the Coast Guard's
60-day requirement.

o  	Content and quality: Coast Guard guidance also contains criteria for
the information that should be included in an after-action report. These
criteria, which are consistent with standards identified in our prior
work,6 include listing each exercise objective and providing an assessment
of how well each objective was met. However, 18 percent of the
after-action reports we reviewed either did not provide such an
objective-by-objective assessment or identified no issues that emerged
from the exercise. While the scope of each exercise may contribute to a
limited number of issues being raised, our past reviews found that
after-action reports need to accurately capture all exercise results and
lessons learned; otherwise, agencies may not be benefiting fully from
exercises in which they participate. Similarly, officials at the
Department of Defense, which like the Coast Guard conducts a variety of
exercises as part of its training, said that if their after-action reports
lack sufficient fundamental content, they cannot be used effectively to
plan exercises and make necessary revisions to programs and protocols. Our
review indicated that, in addition to the pressure of other workload
demands, two additional factors may be contributing to limitations in
report content and quality-current review procedures and a lack of
training for planners. Headquarters planning officials noted that local
commands have primary responsibility for reviewing after-action reports
and that limited criteria exist at headquarters for evaluating the content
of reports submitted by these commands. At the field level, many planners
with whom we spoke said they were unaware of any written documentation or
exercise-planning guidance they could refer to when developing an
after-action report.

6See GAO-01-822.

  Conclusions

Recommendation for Executive Action

  Agency Comments

The Coast Guard has cited several planned actions that may allow for
improved content and quality in after-action reports. These actions
include updating exercise management guidance and promulgating new
instructions related to preparing after-action reports and collecting
lessons learned. While these initiatives may address issues of content and
quality in after-action reports, they are currently still in the
development phase.

A successful response to a terrorist threat or incident in a seaport
environment clearly requires the effective cooperation and coordination of
numerous federal, state, local, and private entities-issues that exercises
and after-action reports are intended to identify. Complete and timely
analyses of these exercises represent an important opportunity to identify
and correct barriers to a successful response. The Coast Guard's inability
to consistently report on these exercises in a timely and complete manner
represents a lost opportunity to share potentially valuable information
across the organization. The Coast Guard's existing requirements, which
include submitting these reports within 60 days and assessing how well
each objective has been met, appear reasonable but are not being
consistently met. Coast Guard officials cited a new management system as
their main effort to making reports more timely, but this system has been
in place for more than a year, and timeliness remains a problem. It is
important for Coast Guard officials to examine this situation to determine
if more needs to be done to meet the standard. The Coast Guard has several
other steps under development to address issues of report content and
completeness, and it is too early to assess the effect these actions will
have. For this set of actions, it will be important for the Coast Guard to
monitor the situation to help ensure that exercises can achieve their full
and stated purpose.

To help ensure that reports on terrorism-related exercises are submitted
in a timely manner that complies with all Coast Guard requirements, we are
making one recommendation, that the Commandant of the Coast Guard review
the Coast Guard's actions for ensuring timeliness and determine if further
actions are needed.

We provided DHS, DOJ, and DOD with a draft of this report for review and
comment. The Coast Guard generally concurred with our findings and
recommendation and did not provide any formal comments for inclusion in
the final report. DOJ and DOD also did not have any official comments.

DOD provided two technical clarifications, which we have incorporated to
ensure the accuracy of our report.

As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from
its issue date. At that time, we will send copies of this report to the
Secretary of Homeland Security, the Commandant of the Coast Guard,
appropriate congressional committees, and other interested parties. The
report will also be available at no charge on GAO's Web site at
http://www.gao.gov.

If you or your staffs have any questions about this report, please contact
me at (415) 904-2200 or by email at [email protected], or Steve Caldwell,
Assistant Director, at (202) 512-9610 or by email at [email protected], or
Steve Calvo, Assistant Director, at (206) 287-4839 or by email at
[email protected]. Other key contributors to this report were Christine
Davis, Wesley Dunn, Michele Fejfar, Lynn Gibson, Dawn Hoff, David Hudson,
Dan Klabunde, Ryan Lambert, and Stan Stenersen.

Margaret T. Wrightson Director, Homeland Security

and Justice Issues

Appendix II: Objectives, Scope, and Methodology

The objectives of this report were to (1) describe the emerging framework
under which the federal government coordinates with state and local
entities to address a terrorist incident in a U.S. port; (2) identify the
issues, if any, regarding federal agencies' legal authority that have
emerged from port security exercises and what statutory actions might
address them; (3) describe the types of operational issues being
identified through these exercises; and (4) identify any management issues
related to Coast Guarddeveloped after-action reports. To address these
objectives, we reviewed relevant legislation, regulations, directives and
plans, analyzed agency operational guidance and Coast Guard after-action
reports (AARs), interviewed a variety of federal officials, and observed
several port security exercises.

To identify the emerging framework to address a terrorist incident in a
U.S. port, we reviewed relevant statutes such as the Homeland Security Act
of 2002 and the Maritime Transportation Security Act of 2002 and
implementing maritime regulations at 33 CFR, parts 101 to 106. We also
reviewed Homeland Security Presidential Directive/HSPD- 5 and Presidential
Decision Directive 39. Operational plans that were included in our
analysis included the Initial National Response Plan, the Interagency
Domestic Terrorism Concept of Operations plan (CONPLAN), Interim Federal
Response Plan, and the National Response Plan "Final Draft." We also
reviewed agency guidance related to exercise planning and evaluation such
as the Coast Guard Exercise Planning Manual and Contingency Preparedness
Planning Manual, as well as the Department of Homeland Security/ Office of
Disaster Preparedness' Exercise and Evaluation Program. Findings were
supplemented with interviews of key officials in federal agencies,
including the Coast Guard (CG), the Department of Homeland Security (DHS),
Department of Defense (DOD), Department of Justice (DOJ), and related
federal maritime entities such as Project Seahawk.

To provide a framework for evaluating agencies' legal authority in
responding to a terrorist incident in a U.S. port, we adopted a case study
methodology because it afforded a factual context for the emergence of
legal issues that could confront agencies in the exercise of their
authority. Our efforts included attending four U.S. port based terrorism
exercises (Los Angeles, Calif.; Hampton Roads, Va.; Charleston, S.C.;
Philadelphia, Pa.), reviewing CG AARs for fiscal year 2004, and conducting
in-person and telephone interviews with DHS, CG, DOJ, DOD, and Project
Seahawk. The port exercises we selected to visit were geographically
diverse and each was conducted in either August or September of fiscal
year 2004. Additional criteria for exercise selection included the
strategic importance

Appendix II: Objectives, Scope, and Methodology

of the port (as defined by the Maritime Administration), the variety of
terrorism scenarios to be exercised, and the federal, state, and local
players involved. The AARs we reviewed were based on a list of all fiscal
year 2004 exercises provided to us by the CG. We focused on any
contingency that included terrorism and then requested AARs for those
completed exercises from the CG. According to CG guidance, AARs are
required to be submitted within 60 days of exercise completion. To
ascertain compliance with this guidance, CG personnel provided us with the
dates that AARs for terrorism-related exercises were received at
headquarters. We used this information, in conjunction with the exercise
start and stop dates, to determine which reports were on time, which were
late, and the average time late reports were submitted beyond the 60-day
requirement.

While issues of a legal nature did surface during our observation of
exercises and analysis of AARs, exercise participants and agency officials
did not recommend statutory changes for these issues. We generally relied
upon the agency's position as to whether legislation was necessary and did
not independently assess the need for legislation by auditing the specific
issues identified in the exercises.

To identify operational issues that occurred during port terrorism
exercises, we relied extensively on perspectives gained through our
observations at the four port terrorism exercises as well as a
comprehensive review of the available AARs for operational issues based on
criteria we developed. In order to determine the frequency of various
operational issues identified in the CG's AARs, we noted instances that
each subcategory within the major category appeared. These categories and
subcategories were chosen through exercise observation and an initial
review of available AARs by two independent analysts. This allowed us to
identify operational issues that were consistent across the terrorism
exercises. We used the following major categories and subcategories (which
appear in parentheses)

o  	Communication (communication interoperability issues, communication
policy or protocols between or within agencies, information sharing
between agencies),

o  	Command and Control/ Incident Command Structure (NIMS/ICS training,
UC/IC information flow),

Appendix II: Objectives, Scope, and Methodology

o  	Unclear Decision Making/ Jurisdictional Knowledge (unclear decision
making authority, unclear lead authority, unclear
authorities/jurisdictions of other agencies), and

o  	Resource Coordination/ Capabilities (response capabilities, response
coordination/joint tactics).

To analyze the reports, two GAO analysts independently reviewed each
report and coded operational issues based on the above subcategories. The
results of each analysis were then compared and any discrepancies were
resolved. Overall percentages for the major categories were determined
based on whether any of the issues were identified under the respective
subcategories. The maximum number of observations for any major category
was equal to one, regardless of the number of times a subcategory was
recorded.

To identify management concerns regarding the CG's AARs, we reviewed our
previous studies on this issue as well as CG and DHS issued guidance on
exercise management, such as the Coast Guard's Exercise Planning Manual
and Contingency Preparedness Planning Manual Volume III. Our analysis also
included in-person interviews with CG exercise management officials from
headquarters and CG planners in the field to gain additional information
on how terrorism exercises are planned and evaluated as well as how
lessons learned are cataloged and disseminated. To ascertain the effect of
untimely CG AARs (CG AARs are required to be completed within 60 days of
exercise completion), we also interviewed exercise management experts from
DOD. We conducted a content analysis of the available AARs to determine
the weaknesses in the reports and where deviations from CG protocol were
taking place.

We conducted our work from June to December 2004 in accordance with
generally accepted government auditing standards.

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