National Response Framework: FEMA Needs Policies and Procedures  
to Better Integrate Non-Federal Stakeholders in the Revision	 
Process (11-JUN-08, GAO-08-768).				 
                                                                 
Hurricane Katrina illustrated that effective preparation and	 
response to a catastrophe requires a joint effort between	 
federal, state, and local government. The Department of Homeland 
Security (DHS), through the Federal Emergency Management Agency  
(FEMA), is responsible for heading the joint effort. In January  
2008, DHS released the National Response Framework (NRF), a	 
revision of the 2004 National Response Plan (2004 Plan), the	 
national preparation plan for all hazards. In response to the	 
explanatory statement to the Consolidated Appropriations Act of  
2008 and as discussed with congressional committees, this report 
evaluates the extent to which (1) DHS collaborated with 	 
non-federal stakeholders in revising and updating the 2004 Plan  
into the 2008 NRF and (2) FEMA has developed policies and	 
procedures for managing future NRF revisions. To accomplish these
objectives, GAO reviewed DHS and FEMA documents related to the	 
revision process, analyzed the relevant statutes, and interviewed
federal and non-federal officials who held key positions in the  
revision process.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-768 					        
    ACCNO:   A82327						        
  TITLE:     National Response Framework: FEMA Needs Policies and     
Procedures to Better Integrate Non-Federal Stakeholders in the	 
Revision Process						 
     DATE:   06/11/2008 
  SUBJECT:   Disaster planning					 
	     Disaster recovery plans				 
	     Emergency management				 
	     Emergency preparedness				 
	     Emergency preparedness programs			 
	     Emergency response plans				 
	     Emergency response procedures			 
	     Federal/state relations				 
	     Homeland security					 
	     Internal controls					 
	     Local governments					 
	     National policies					 
	     Policy evaluation					 
	     Program evaluation 				 
	     Reporting requirements				 
	     Standards						 
	     Strategic planning 				 
	     Written communication				 
	     Government information dissemination		 
	     Policies and procedures				 
	     National Response Framework			 
	     National Response Plan				 

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GAO-08-768

This is the accessible text file for GAO report number GAO-08-768 
entitled 'National Response Framework: FEMA Needs Policies and 
Procedures to Better Integrate Non-Federal Stakeholders in the Revision 
Process' which was released on June 11, 2008.

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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

June 2008: 

National Response Framework: 

FEMA Needs Policies and Procedures to Better Integrate Non-Federal 
Stakeholders in the Revision Process: 

GAO-08-768: 

GAO Highlights: 

Highlights of GAO-08-768, a report to congressional committees. 

Why GAO Did This Study: 

Hurricane Katrina illustrated that effective preparation and response 
to a catastrophe requires a joint effort between federal, state, and 
local government. The Department of Homeland Security (DHS), through 
the Federal Emergency Management Agency (FEMA), is responsible for 
heading the joint effort. In January 2008, DHS released the National 
Response Framework (NRF), a revision of the 2004 National Response Plan 
(2004 Plan), the national preparation plan for all hazards. In response 
to the explanatory statement to the Consolidated Appropriations Act of 
2008 and as discussed with congressional committees, this report 
evaluates the extent to which (1) DHS collaborated with non-federal 
stakeholders in revising and updating the 2004 Plan into the 2008 NRF 
and (2) FEMA has developed policies and procedures for managing future 
NRF revisions. To accomplish these objectives, GAO reviewed DHS and 
FEMA documents related to the revision process, analyzed the relevant 
statutes, and interviewed federal and non-federal officials who held 
key positions in the revision process. 

What GAO Found: 

While DHS included non-federal stakeholdersï¿½state, local, and tribal 
governments, nongovernmental organizations, and the private sectorï¿½in 
the initial and final stages of revising the 2004 Plan into the NRF, it 
did not collaborate with these stakeholders as fully as it originally 
planned or as required by the October 2006 Post-Katrina Emergency 
Management Reform Act (Post-Katrina Act). As the revision process began 
in 2006, DHS involved both federal and non-federal stakeholders by 
soliciting and incorporating their input in determining the key 
revision issues and developing the first draft in April 2007. However, 
after this first draft was completed, DHS deviated from its revision 
work plan by conducting a closed, internal federal review of the draft 
rather than releasing it for stakeholder comment because the draft 
required further modifications DHS considered necessary. DHS limited 
communication with non-federal stakeholders until it released a draft 
for public comment 5 months later on September 10, 2007. The following 
day, non-federal stakeholders testified at a congressional hearing that 
DHS had shut them out during that 5-month period. In addition, the Post-
Katrina Act required that DHS establish a National Advisory Council 
(NAC) for the FEMA Administrator by December 2006 to, among other 
things, incorporate non-federal stakeholdersï¿½ input in the revision 
process. However, FEMA stated the necessary time to select quality NAC 
members required additional time, and FEMA did not announce the NACï¿½s 
membership until June 2007. The NAC did not provide comments on a 
revision draft until one month before DHS publicly released the final 
NRF in January 2008. 

FEMA anticipates that the NRF will be revised in the future; however, 
FEMA does not have policies or procedures in place to guide this 
process or ensure a collaborative partnership with stakeholders. FEMA 
has emphasized the importance of partnering with relevant stakeholders 
to effectively prepare for and respond to major and catastrophic 
disasters, and the Congress, through the Post-Katrina Act, requires 
such partnership. In addition, the Standards for Internal Controls in 
the Federal Government calls for policies and procedures that establish 
regular communication with stakeholders and monitor performance over 
time as essential for achieving desired program goals. Furthermore, 
previous GAO work on the Department of Defenseï¿½s civil support plans 
and the administrationï¿½s national pandemic influenza implementation 
plan has shown the need for participation of state and local 
jurisdictions in emergency planning. Especially in view of a new 
administration, the experience of the previous revision process 
illustrates the importance of collaborating with stakeholders in 
revising a plan that relies on them for its successful implementation. 
While the NRF is published by DHS, it belongs to the nationï¿½s emergency 
response community. Developing such policies and procedures is 
essential for ensuring that FEMA attains the Post-Katrina Actï¿½s goal of 
partnering with non-federal stakeholders in building the nationï¿½s 
emergency management system, including the periodic review and revision 
of the NRF. 

What GAO Recommends: 

GAO recommends that FEMA develop policies and procedures that guide how 
future revision processes will occur, particularly for collaborating 
with non-federal stakeholders. 

FEMA concurred with our recommendation. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-768]. For more 
information, contact William Jenkins at (202) 512-8757 or 
[email protected]. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

DHS Did Not Collaborate with Non-Federal Stakeholders As Fully As 
Planned or Required in Developing the NRF: 

FEMA and the Post-Katrina Act Have Recognized the Importance of 
Including Non-Federal Stakeholders in Developing National Response 
Doctrine, but FEMA Lacks Guidance and Procedures for Future NRF 
Revisions: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: The 17 Key Revision Issues That DHS Identified for the 
2004 National Response Plan: 

Appendix III: The 12 Work Groups DHS Established during the Revision 
Process and Their Composition: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: The 224 Non-Federal Stakeholders Who Participated in the 
Revision Work Groups by Occupational Sector and by Level of Government, 
Nongovernmental Organization, and Private Sector: 

Figures: 

Figure 1: Significant Events and Documents in DHS's Revision of the 
2004 National Response Plan into the 2008 National Response Framework: 

Figure 2: Relationship among Entities within the September 2006 
Revision Work Plan: 

Figure 3: DHS's Revision Process as Planned by Its September 2006 Work 
Plan and as Required by the October 2006 Post-Katrina Act: 

Figure 4: Composition of the 710 Members of the 12 Work Groups by 
Federal, State, Local, and Tribal Government, Nongovernmental 
Organization, and Private Sector: 

Figure 5: DHS's Actual Revision Process Compared with Its Proposed 
Process: 

Abbreviations: 

2004 Plan: 2004 National Response Plan: 

DHS: Department of Homeland Security: 

FEMA: Federal Emergency Management Agency: 

FMFIA: Federal Managers' Financial Integrity Act of 1982: 

GAO: Government Accountability Office: 

NAC: National Advisory Council: 

NRF: 2008 National Response Framework: 

[End of section] 

United States Government Accountability Office: Washington, DC 20548: 

June 11, 2008: 

The Honorable Robert C. Byrd: 
Chairman: 
The Honorable Thad Cochran: 
Ranking Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
United States Senate: 

The Honorable David E. Price: 
Chair: 
The Honorable Harold Rogers: 
Ranking Member: 
Subcommittee on Homeland Security: 
Committee on Appropriations: 
House of Representatives: 

A common axiom in emergency management is that "All disasters are 
local." But a key lesson Hurricane Katrina dramatically emphasized was 
that major disasters can quickly overwhelm the capacity of local 
responders. Thus, preparing for, responding to, and recovering from 
major disasters requires partnerships between the federal government 
and non-federal stakeholders, such as state, local, and tribal 
governments, the private sector, and nongovernmental organizations. In 
summarizing the lessons learned from our nation's response to Katrina, 
we reported in September 2006 that these federal and non-federal 
partnerships were critical to improving catastrophic disaster response. 
[Footnote 1] The 2006 Post-Katrina Emergency Management Reform Act 
(Post-Katrina Act)[Footnote 2] specifically tasked the Federal 
Emergency Management Agency (FEMA) within the Department of Homeland 
Security (DHS) to partner with these non-federal stakeholders to build 
a national system of emergency management. In outlining his vision for 
a "New FEMA" and in testimonies before the Congress, the FEMA 
Administrator has acknowledged that FEMA's success depends on its 
ability to establish and maintain robust partnerships with non-federal 
stakeholders. 

DHS issued the National Response Plan in December 2004 (2004 Plan) to 
provide common principles and structures to align the efforts of 
stakeholders at the local, state, and federal level to ensure an 
effective national disaster response system. The events surrounding 
Hurricane Katrina in August 2005 and the resulting lessons-learned and 
after-action reports by the Congress and administration prompted DHS to 
revise the just issued 2004 Plan. DHS released an interim revision of 
elements of the 2004 Plan in May 2006 and developed a work plan for a 
more comprehensive revision in September 2006. Shortly thereafter, 
Congress passed the October 2006 Post-Katrina Act, which made the FEMA 
Administrator, through the National Integration Center, responsible for 
ongoing management and maintenance of the 2004 Plan, including periodic 
review and revision. In addition, the act required the DHS Secretary to 
establish a National Advisory Council of non-federal stakeholders to 
advise the FEMA Administrator in revising the 2004 Plan. During the 
summer of 2007 in the midst of the revision process, non-federal 
members of the emergency management community raised concerns over the 
extent to which DHS included them in the process. In September 2007, 
the House Committee on Transportation and Infrastructure held a hearing 
on DHS's management of the revision process and the involvement of non- 
federal stakeholders. DHS completed its revision efforts with the 
publication of the National Response Framework (NRF) on January 22, 
2008.[Footnote 3] The NRF is a guide for how the federal, state, local, 
and tribal governments, along with nongovernmental and private sector 
entities, will collectively respond to and recover from all disasters, 
particularly catastrophic disasters such as Hurricane Katrina, 
regardless of their cause. The NRF recognizes the need for 
collaboration among the myriad of entities and personnel involved in 
response efforts at all levels of government, nonprofit organizations, 
and the private sector. See figure 1 depicting the significant events 
and documents in the revision of the 2004 Plan into the 2008 NRF. 

Figure 1: Significant Events and Documents in DHS's Revision of the 
2004 National Response Plan into the 2008 National Response Framework: 

[See PDF for image] 

This figure is an illustration of significant events and documents in 
DHS's Revision of the 2004 National Response Plan into the 2008 
National Response Framework, as follows: 

December 2004: 
National Response Plan (2004 Plan). 

August 2005: 
Hurricane Katrina. 

February - May, 2006: 
Katrina after-action and lessons learned reports. 

May 2006: 
Interim changes to 2004 Plan through Notice of Change. 

September 2006: 
DHS Work Plan for 2004 Plan revision. 

October 2006: 
Post-Katrina Emergency Management Reform Act. 

October 2006 - January 2008: 
DHS's revision of the 2004 Plan[A]. 

January 2008: 
National Response Framework. 

Source: GAO analysis. 

[A] See figure 5 for a time line on DHS's revision process from October 
2006 to January 2008. 

[End of figure] 

In the explanatory statement accompanying the Consolidated 
Appropriations Act of 2008, the appropriations committees tasked GAO to 
review the process DHS used to update the NRF, including the process 
for including key stakeholders. We conducted our review to determine 
the extent to which (1) DHS collaborated with non-federal stakeholders 
in revising and updating the 2004 Plan into the 2008 NRF and (2) FEMA 
has developed policies and procedures for managing future revisions of 
the NRF, for which it is statutorily responsible. 

To address our objectives, we reviewed DHS and FEMA documents on the 
revision process and applicable statutes to determine the level to 
which the revision process was planned. To determine what happened 
during the process, we interviewed DHS and FEMA officials as well as 
non-federal stakeholders representing state and local levels of 
government, emergency management associations, and others who served in 
key positions in the revision process, such as the co-leaders of work 
groups and members of a steering committee. The statements and views of 
these stakeholders are not generalizable to the population of non- 
federal stakeholders involved in the revision process. However, we 
selected these stakeholders because of their assigned key roles and 
believe that their views provided us with a general indication of 
stakeholder perspectives on their involvement in the revision process. 
To address our objectives, we reviewed DHS and FEMA documents on the 
revision process and applicable statutes to determine the level to 
which the revision process was planned. In assessing DHS and FEMA 
actions related to these objectives, we used criteria from our prior 
work on results-oriented government as well as best practices for 
federal coordination and collaboration with stakeholders. We also used 
criteria in GAO's Standards for Internal Control in the Federal 
Government.[Footnote 4] These standards, issued pursuant to the 
requirements of the Federal Managers' Financial Integrity Act of 1982 
(FMFIA), provide the overall framework for establishing and maintaining 
internal control in the federal government. Also pursuant to FMFIA, the 
Office of Management and Budget issued Circular A-123, revised December 
21, 2004, to provide the specific requirements for assessing and 
reporting on internal controls. Internal control standards and the 
definition of internal control in Circular A-123 are based on GAO's 
Standards for Internal Control in the Federal Government. For more 
detailed information on our scope and methodology, see appendix I. 

We conducted this performance audit from September 2007 to June 2008, 
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. 

Results in Brief: 

While DHS included non-federal stakeholders during the initial and 
final months of the process of revising the 2004 Plan, it did not 
collaborate with them as fully as envisioned in its original work plan 
or as required by the 2006 Post-Katrina Act. DHS's management of the 
initial stages of the revision process was generally consistent with 
the work plan and involved state and local stakeholders in identifying 
key issues and developing draft segments of the revised 2004 Plan. 
However, DHS deviated from its work plan and did not provide the first 
full revision draft to non-federal stakeholders for their comments and 
suggestions before conducting an internal, federal review of the draft 
because it required further modifications. Instead, DHS sent the first 
draft for the internal, federal review for 5 months before requesting 
stakeholder comment and without communicating the change in plans with 
the non-federal stakeholders. At the end of the 5-month internal 
review, DHS released a revised draft in September 2007, providing an 
opportunity for non-federal stakeholders as well as the general public 
to comment and have access to all non-federal comments submitted. DHS's 
approach was also not in accordance with the Post-Katrina Act's 
requirement that DHS establish a National Advisory Council (NAC) to 
incorporate non-federal input into the revision of national response 
doctrine. Although the NAC was to be established within 60 days of the 
Act (i.e., December 4, 2006), FEMA, which assumed responsibility for 
selecting members, did not name NAC members until June 2007 because of 
the additional time needed to review hundreds of applications and 
select a high quality body of advisors, according to the FEMA 
Administrator. The NAC's first meeting took place in October 2007 after 
DHS issued the revised plan for public comment. 

While FEMA and the Congress, through the Post-Katrina Act, recognize 
the importance of partnering with non-federal stakeholders in disaster 
planning and response, FEMA has not yet developed guidance and 
procedures--elements specified as essential for planning and achieving 
effective results in Standards for Internal Control in the Federal 
Government--that describe how future revisions of the National Response 
Framework will be managed. The 2004 Plan included such guidance, 
including the circumstances that would lead to future revisions--such 
as changes in directives, laws, and lessons learned from exercises and 
actual events--and time frames for reviewing the plan. In addition, 
while these federal internal control standards state that communication 
with stakeholders is essential, FEMA has not articulated how it will 
involve stakeholders, or how the newly established NAC will be 
integrated into the revision process. Especially in view of a new 
administration, developing such policies and procedures is essential 
for ensuring that FEMA attains the Post-Katrina Act's goal of 
partnering with non-federal stakeholders in building the nation's 
emergency management system, including the periodic review and revision 
of the NRF. According to FEMA, it has not yet developed guidance and 
procedures because of the need to focus federal resources on creating 
training materials to assist all stakeholders in implementing the 
current NRF in anticipation of the pending 2008 hurricane season. 

As FEMA begins to implement and review the 2008 NRF, we recommend that 
the Administrator develop and disseminate policies and procedures 
describing the conditions and time frames under which the next NRF 
revision will occur and how FEMA will conduct the next NRF revision. 
These policies and procedures should clearly describe how FEMA will 
integrate all stakeholders, including the NAC and other non-federal 
stakeholders, into the revision process and the methods for 
communicating to these stakeholders. 

We requested comments on a draft of this report from DHS and FEMA. They 
concurred with our recommendations and had no other comments. 

Background: 

Several federal legislative provisions support preparation for and 
response to disasters. The Robert T. Stafford Disaster Relief and 
Emergency Assistance Act[Footnote 5] (Stafford Act) primarily 
establishes the programs and processes for the federal government to 
provide major disaster and emergency assistance to states, local 
governments, tribal nations, individuals, and qualified private 
nonprofit organizations. FEMA has responsibility for administering the 
provisions of the Stafford Act, and the Act provides the FEMA 
Administrator with the authority to prepare federal response plans and 
programs. In April 1992, FEMA issued a Federal Response Plan, which 
outlined how the federal government implements the Stafford Act. The 
Federal Response Plan described, among other things, the response and 
recovery responsibilities of each federal department and agency for 
saving lives and protecting public health and safety during an 
emergency or major disaster. 

After the events of September 11, 2001, and with the passage of the 
Homeland Security Act[Footnote 6] in November 2002, FEMA became part of 
the newly formed Department of Homeland Security (DHS).[Footnote 7] 
Under the Act, FEMA retained its authority to administer the provisions 
of the Stafford Act as well as its designation as the lead agency for 
the Federal Response Plan. The Homeland Security Act required DHS to 
consolidate existing federal government emergency response plans into a 
single, integrated, and coordinated national response plan. In December 
2004, DHS issued the 2004 Plan to integrate the federal government's 
domestic prevention, preparedness, response, and recovery plans into 
one plan that addressed all disaster situations, whether due to nature, 
terrorism, or other man-made activities. The 2004 Plan incorporated or 
superceded other federal interagency plans such as the Federal Response 
Plan and the Federal Radiological Emergency Response Plan. 

In August 2005, Hurricane Katrina and, shortly after, hurricanes Wilma 
and Rita revealed a number of limitations in the 2004 Plan. Beginning 
in February 2006, reports by the House Select Bipartisan Committee to 
Investigate the Preparation for and Response to Hurricane Katrina, 
[Footnote 8] the Senate Homeland Security and Governmental Affairs 
Committee,[Footnote 9] the White House Homeland Security Council, 
[Footnote 10] the DHS Inspector General,[Footnote 11] and DHS and FEMA 
[Footnote 12] all identified a variety of failures and some strengths 
in the preparations for, response to, and initial recovery from 
Hurricane Katrina. After reviewing these reports, DHS concluded that 
the 2004 Plan required revision. In May 2006, DHS released immediate 
modifications to the 2004 Plan pending a more comprehensive review. In 
June 2006, Congress passed the Emergency Supplemental Appropriations 
Act for Defense, the Global War on Terror, and Hurricane Recovery, 
2006.[Footnote 13] In the conference report accompanying this act, the 
conferrees recommended that FEMA apply $3 million of its Preparedness, 
Mitigation, Response, and Recovery appropriation to immediately review 
and revise the 2004 Plan as well as its companion document, the 
National Incident Management System, which provides standard command 
and management structures that apply to response activities.[Footnote 
14] 

On October 4, 2006, the Post-Katrina Act was enacted. This act, among 
other things, made certain organizational changes within DHS to 
consolidate emergency preparedness and emergency response functions 
within FEMA, required that DHS maintain FEMA as a distinct entity 
within the department, and designated the FEMA Administrator--the new 
title of the official who will lead the agency--as the principal 
advisor to the President, the Homeland Security Council, and the 
Secretary for all matters relating to emergency management. Most of the 
organizational changes, such as the transfer of various functions from 
DHS's Directorate of Preparedness to FEMA, became effective as of March 
31, 2007. Others, such as the increase in the organizational autonomy 
for FEMA and the establishment of the National Integration Center, 
became effective upon enactment. The Post-Katrina Act specified that 
the FEMA Administrator, acting through the Center, "shall ensure 
ongoing management and maintenance of theï¿½National Response Plan," 
including periodic review and revision. The Post-Katrina Act also 
directed the Secretary to establish a National Advisory Council (NAC) 
by December 2006 to, among other things, incorporate state, local, and 
tribal government and private sector input in the development and 
revision of the 2004 Plan. As established by the Post-Katrina Act, the 
NAC is intended to be an ongoing advisory council that draws upon 
individuals with a broad body of expertise and geographic and 
substantive diversity. The Act requires the NAC to advise the 
Administrator on a variety of emergency management issues across the 
national preparedness spectrum, including the 2004 Plan. 

In January 2008, DHS issued the 2008 NRF, the product of the revision 
of the 2004 Plan. The NRF became effective in March 2008 and retained 
the basic structure of the 2004 Plan. For example, like the 2004 Plan, 
the NRF's core document describes the doctrine that guides national 
response actions and the roles and responsibilities of officials and 
entities involved in response efforts. Further, the NRF also includes 
Emergency Support and Incident Annexes. However, in contrast to the 
2004 Plan, FEMA plans to include four partner guides to the NRF that 
describe key roles and actions for local, tribal, state, federal and 
private sector entities involved in response activities. 

DHS Did Not Collaborate with Non-Federal Stakeholders As Fully As 
Planned or Required in Developing the NRF: 

While DHS included non-federal stakeholders at the initial and final 
stages in the process of revising the December 2004 Plan, it did not 
collaborate with them as fully as planned in its revision work plan or 
as required by the Post-Katrina Act. DHS based the work plan, which was 
approved by a White House Homeland Security Council-chaired policy 
committee, on a section in the 2004 Plan that provided procedural 
guidance for managing revisions of the document. DHS managed the 
initial stages of the revision process according to the work plan. 
However, DHS deviated from its work plan after the first draft was 
completed in April 2007. Instead of widely disseminating the first 
draft to all stakeholders, including non-federal stakeholders, for 
comment and modification, DHS retained the draft to make modifications 
that it felt were necessary and conducted an internal, federal review 
of the draft for a 5-month period. DHS delayed the release of the April 
2007 draft and provided limited communication to state and local 
stakeholders on the status of the review until after releasing the 
draft for public comment in September 2007. In addition, DHS did not 
manage the revision process in accordance with the Post-Katrina Act's 
provision that DHS establish FEMA's NAC by December 2006 and 
incorporate the NAC's non-federal input into the revision. 

DHS Created a Work Plan to Revise the 2004 National Response Plan, 
Specifying Revision Issues, Entities and Tasks, and a Time Line for 
Completing the Revision: 

Hurricane Katrina hit the Gulf Coast in August 2005 and the nation's 
response prompted DHS to revise the 2004 Plan. In May 2006, DHS issued 
an official Notice of Change[Footnote 15] to the 2004 Plan to 
incorporate lessons learned from the response to hurricanes Katrina, 
Wilma, and Rita as well as to incorporate organizational changes within 
DHS. This Notice of Change--which was distributed to all 
signatories[Footnote 16] of the 2004 Plan, DHS headquarters and 
regional offices, and state emergency management and homeland security 
offices--noted that DHS intended to initiate a comprehensive 
stakeholder review of the 2004 Plan in the fall of 2006. Accordingly, 
DHS developed a work plan to manage the revision of the 2004 Plan that 
established (1) the issues that were to be the focus of the revision 
process, (2) the entities to be created to implement the process and 
the tasks involved, and (3) a timeline for completing the revision 
process and issuing the final document. DHS based its work plan for 
revising the 2004 Plan on guidance found in the Plan itself. 
Anticipating that modifications or updates would arise when needed, the 
2004 Plan included a section specifying how DHS would conduct interim 
changes and full revisions, listing the time frames and circumstances-
-within the first year and every 4 years, or more frequently if the 
Secretary deems necessary, to incorporate new presidential directives, 
legislative changes, and procedural changes based on lessons learned 
from exercises and actual events. The Domestic Readiness Group, an 
interagency group that coordinates preparedness and response policy and 
is chaired by staff of the White House Homeland Security Council, 
approved DHS's work plan in September 2006. For the revision process, 
the Domestic Readiness Group was to provide strategic policy 
coordination, be a mechanism for vetting the revision at the federal 
level, and was to resolve conflicting policy issues. 

The work plan contained an initial list of 14 revision issues. 
According to FEMA officials, they compiled these issues by reviewing 
Hurricane Katrina after-action and lessons-learned reports from the 
White House, Congress, GAO, and the DHS Inspector General and 
identifying common issues that were raised in multiple reports. 
According to the work plan, DHS was to conduct meetings with selected 
stakeholders to review the initial list and identify other issues to be 
considered during the revision process. The result of these meetings 
was to be a finalized list of revision issues that would serve as the 
starting point for revising the 2004 Plan. 

Based on the 2004 Plan, DHS created three entities to facilitate the 
revision process: the Steering Committee, the Writing Team, and 12 Work 
Groups.[Footnote 17] DHS provided a copy of the approved work plan to 
all participants. The Steering Committee was to conduct the day-to-day 
management and oversight of the 2004 Plan revision process, which 
included managing the Work Groups and overseeing the Writing Team. The 
work plan assigned overall management of the 2004 Plan rewrite to the 
Writing Team, which was to assign issues to the Work Groups and track 
the Work Groups' progress on resolving the assigned issues. The Work 
Groups, which were chaired by designated co-leaders, were to examine 
the issues received from the Writing Team and determine if existing 
language in the 2004 Plan adequately addressed the issues. If the Work 
Groups determined that current language in the 2004 Plan did not 
adequately address the issue, they were required to provide 
recommendations to the Writing Team on how the issues should be 
addressed. Figure 2 shows the relationship between the entities 
involved in the revision process. 

Figure 2: Relationship among Entities within the September 2006 
Revision Work Plan: 

[See PDF for image] 

This figure is an illustration of relationship among entities within 
the September 2006 Revision Work Plan, as follows: 

Secretary of Homeland Security: Overall responsibility for 2004 Plan 
Revision: 
* FEMA Administrator[A]; 
* National Integration Center; 
* Undersecretary for Preparedness[B]. 

Homeland Security Council Chaired Domestic Readiness Group: 
* Provide strategic policy coordination; 
* Mechanism for vetting the revision at the federal level; 
* Resolve conflicting policy issues. 

Steering Committee: 
* Day to day management and oversight of the revision process; 
* Management of the Work Groups and oversight of the Writing Team. 

Writing Team: 
* Overall management of the rewrite; 
* Assigned and tracked writing issues to Work Groups. 

Work Groups: 
* Examined writing issues to determine if existing language in
document was adequate; 
* If existing language deemed inadequate, provided recommended
changes to Writing Team. 

Source: GAO analysis of DHS data. 

[A] The work plan referred to the FEMA Administrator by his former 
title, which was the Under Secretary for Federal Emergency Management. 

[B] Most of the DHS preparedness functions became part of FEMA as part 
of the Post-Katrina Act, and the transfer of these responsibilities 
became effective on March 31, 2007. 

[End of figure] 

The revision schedule in the work plan was to begin in December 2006 
with a goal to complete the revision process by June 2007. As a first 
step in the plan, the Writing Team was to provide the Work Groups with 
writing assignments. Once the Work Groups completed their writing 
assignments, the Writing Team was to review their recommendations and 
submit a draft of the revised NRF to the Steering Committee for its 
review and approval. The Steering Committee was to release the first 
draft of the revised NRF for stakeholder comment by the end of January 
2007 with an approximate 30-day review period. According to the work 
plan, the Steering Committee, Writing Team, and Work Groups would 
review comments on this first draft, make any needed modifications, and 
release a second draft at the end of March 2007 for the final of two 30-
day comment periods. Per the work plan, these two comment periods would 
ensure wide dissemination of the product to all stakeholders, including 
federal agencies, state and local governments, and major professional 
associations. The work plan schedule also included a 2- month internal, 
federal review process to take place beginning in May 2007, after which 
DHS would provide the final draft for approval to the Domestic 
Readiness Group and the signatories of the 2004 Plan, with the final 
issuance of the revised 2004 Plan targeted for June 2007. See figure 3 
for the proposed timeline for the revision process. 

Figure 3: DHS's Revision Process as Planned by Its September 2006 Work 
Plan and as Required by the October 2006 Post-Katrina Act: 

[See PDF for image] 

This figure is an illustration of DHS's Revision Process as planned by 
Its September 2006 Work Plan and as required by the October 2006 Post-
Katrina Act, as follows: 

September 2006: 
Approved revision plan. 

October 2006: 
Post-Katrina Act enacted. 

October-November 2006: 
Hold stakeholder meetings. 

December 2006: 
Start revision process; 
Establish NAC. 

January 2007: 
Release first draft to stakeholders. 

March 2007: 
Release second draft to stakeholders. 

May - June, 2007: 
Conduct internal federal review. 

June 2007: 
Published revised plan. 

Source: GAO analysis of DHS data, and the Post-Katrina Act. 

[End of figure] 

DHS Included Non-Federal Stakeholders at the Beginning of the Revision 
Process: 

DHS included non-federal stakeholders in the early stages of the 2004 
Plan revision process in accordance with the work plan. For example, in 
October 2006, DHS hosted a meeting with approximately 90 non-federal 
stakeholders where DHS sought feedback on the 14 revision issues from 
participants using structured breakout groups. At this meeting, FEMA 
reported that non-federal stakeholders identified the need for 
enhancements to the 2004 Plan to further describe coordination 
processes with the private sector and volunteer organizations. DHS held 
a similar meeting with federal stakeholders in November 2006. According 
to DHS, it modified the scope of some of the 14 revision issues and 
added three additional issues. (See app. II for a listing of the 17 
revision issues.) 

DHS assigned non-federal stakeholders to serve as members of the 
Steering Committee and the Work Groups. Although the work plan called 
for the engagement of all levels of stakeholders in the revision 
process and described the Steering Committee and Work Groups, it did 
not specify the composition of the Work Groups but stated that one non- 
federal stakeholder would serve on the Steering Committee. In the 
spirit of the plan, DHS selected non-federal officials to serve on the 
Steering Committee and Work Groups. Of the 32 members on the Steering 
Committee, six members or 19 percent were non-federal officials, 
including representatives from state and local government emergency 
management associations as well as a local fire department and police 
associations. According to a FEMA official, the Steering Committee, led 
by FEMA and DHS co-chairs, generally met on a weekly basis via 
teleconferences throughout the revision process. 

Of the approximately 710 members who served on the 12 Work Groups, 224 
officials, or 32 percent, were non-federal officials, including 3 of 
the 27 Work Group co-leaders.[Footnote 18] These non-federal officials 
included representatives from state and local emergency management 
agencies and tribal governments as well as officials from the fire, law 
enforcement, and public health sector. See figure 4 for the composition 
of the 12 Work Groups members by level of government, nongovernmental 
organization, and private sector. See appendix III for a listing of the 
12 Work Groups and a table showing the occupational demographics of the 
non-federal stakeholders who served on the Work Group. 

Figure 4: Composition of the 710 Members of the 12 Work Groups by 
Federal, State, Local, and Tribal Government, Nongovernmental 
Organization, and Private Sector: 

[See PDF for image] 

This figure is a pie-chart depicting the following data: 

Federal government - approximately 486 members: 68%; 
Nongovernmental organization - 79 members: 11%; 
State government - 67 members: 9%; 
Local government - 35 members: 5%; 
Private sector - 34 members: 5%; 
Tribal government - 9 members: 2%. 

Source: GAO analysis of DHS data. 

Note: There was some uncertainty in the exact total number of Work 
Group members due to duplication and lack of identifying information in 
the data FEMA provided. However, because the inclusion of non-federal 
stakeholders is the focus of this report, we took steps to correctly 
determine the total number and composition of the non-federal Work 
Group members. 

[End of figure] 

The Writing Team, which consisted of 11 federal officials and private 
contractors for administrative support, did not include any non-federal 
stakeholders. DHS stated that they invited one non-federal stakeholder 
to be on the team but that they were not successful in their attempts 
to secure that person. 

The 12 Work Groups met in January and February 2007. During that time, 
and in accordance with the work plan, the Work Groups met to address 
the issues assigned to them by the Writing Team. Most Work Groups 
addressed their issues by submitting recommended language changes to 
the 2004 Plan, which generally consisted of inserting new language or 
clarifying existing language. The Work Groups supported a recommended 
language change by providing the rationale for such a change. For 
example, the Writing Team tasked the Roles and Responsibilities Work 
Group with clarifying and strengthening the role of state governments 
in the 2004 Plan. One recommended language change suggested by this 
Work Group was to describe the state government's role in the 
coordination of resources through the Emergency Management Assistance 
Compact, an interstate mutual aid compact that provides a legal 
structure through which affected states may request assistance from 
other states during a disaster.[Footnote 19] 

All Work Group recommendations were due to the Writing Team by the 
middle of February 2007. Although the work plan provided for the Work 
Groups' continued involvement after submitting their recommendations, 
this did not occur. 

DHS Departed from the Work Plan by Conducting an Internal Federal 
Review Rather Than Providing a Draft to Non-Federal Stakeholders for 
Comment: 

On March 13, 2007, DHS officials e-mailed stakeholders that the release 
of the first revision draft for the first 30-day comment period was 
being delayed. According to the message, DHS still planned to release 
the draft within the next several weeks and issue a final document by 
June 1, 2007. The message noted that once an updated timeline was 
approved, DHS would share the dates with the stakeholders. 

According to FEMA officials, the first draft of the revised 2004 Plan 
was completed in April 2007 and incorporated many of the Work Groups' 
recommendations. However, rather than sending this first draft to 
stakeholders for comment, DHS conducted its internal, federal review of 
the draft document for approximately 5 months until September 2007. 
FEMA officials said that DHS did not release this April 2007 draft for 
comment because the draft required further modifications DHS considered 
necessary. An April 11, 2007, notice subsequently posted on DHS's Web 
site described the status of the process and its plans to further 
revise the draft for comment. 

"As the NRP revision process unfolded, it became apparent that some 
important issues were more complex than we originally thought and 
require national-level policy decisions. We also came to the 
realization that creating a more user-friendly document that clearly 
addressed the roles and responsibilities of stakeholders and incident 
management structures would require substantial format changes to the 
NRPï¿½ An updated timeline has not been determined but we will share one 
with you quickly." 

FEMA officials said that the length of time for the review and approval 
process, about 3 months longer than planned, was unpredictable and that 
it took longer than they had expected. DHS did not modify or update the 
work plan to reflect this deviation from the approved revision process 
or propose how the revision process would now be completed. 

Certain non-federal stakeholders we interviewed who served on the 
Steering Committee and as co-leaders on the Work Groups reported 
receiving occasional or no communication from DHS on the decision not 
to release the first draft for comment or how the revision process 
would be completed during this internal, federal review process. FEMA's 
Deputy Administrator acknowledged that the federal government should 
have done a better job in communicating the status of the draft and the 
revision process to non-federal stakeholders while the document was 
undergoing the internal, federal review. 

During this internal, federal review, DHS and FEMA officials continued 
to revise the April 2007 draft. For example, FEMA officials said that 
they added a chapter to explain the need for all levels of government 
to plan for preparedness and response actions and additional language 
to clarify the role of state and local governments during disaster 
response. At this point in the process, around August 2007, DHS's 
Office of the Deputy Secretary[Footnote 20] decided to release a 
revised draft just to the Steering Committee and the Domestic Readiness 
Group for comment. Writing Team officials assumed that the Deputy 
Secretary would make the final decision on whether to incorporate the 
comments received while staff from his office would be responsible for 
completing any further edits. A draft of this document, dated July 
2007, was leaked to the press in August 2007. 

During a September 11, 2007, hearing before the House Transportation 
and Infrastructure Committee,[Footnote 21] officials representing state 
and local emergency management associations expressed their concerns 
that the July 2007 leaked draft had changed significantly from the 
April 2007 draft. The government affairs committee chair of the 
International Association of Emergency Managers[Footnote 22] testified, 
"The document we saw bore no resemblance to what we had discussed so 
extensively with FEMA and other stakeholders in the December 2006 
through February 2007 timeline." Additionally, the National Emergency 
Management Association[Footnote 23] representative, who served on the 
Steering Committee, expressed his concern that its association had been 
effectively shut out of the process, testifying that the collaborative 
process in rewriting the 2004 Plan "broke downï¿½with no stakeholder 
input, working group involvement, or steering committee visibility.": 

After the Internal, Federal Review, DHS Provided All Stakeholders an 
Opportunity to Comment before Final Publication and Considered All 
Comments in Finalizing the New Framework: 

After the approximate 5-month internal, federal review period, DHS 
released a draft of the newly renamed National Response Framework for 
public comment on September 10, 2007. However, as we stated earlier, 
the original work plan called for DHS to provide stakeholders with two 
30-day public comment periods before the internal, federal review; 
after the review, DHS was to publish the revised document without 
further comment by stakeholders. The public comment period starting on 
September 10 allowed for both federal and non-federal stakeholders to 
provide their reactions to the changes made during the internal federal 
review process. FEMA officials said they conducted this unplanned 
public comment period to address the work plan's requirement that the 
draft NRF be widely disseminated for all stakeholders to review. FEMA 
provided a 40-day public comment period for the NRF core document. FEMA 
received 3,318 comments on the core NRF. [Footnote 24] 

The Writing Team led the adjudication--review, analysis, and 
resolution--of the comments received during the public comment period. 
The Writing Team examined each comment, made an initial disposition 
recommendation--accepted, modified, rejected, or noted--and forwarded 
that recommendation to the FEMA leadership and the Domestic Readiness 
Group for review. In addition, FEMA posted a spreadsheet on [hyperlink, 
http://www.regulations.gov] that included, among other things, the 
comments made by non-federal stakeholders and the final disposition 
FEMA assigned to each of those comments. This allowed these 
stakeholders to see how FEMA did or did not incorporate their comments 
into the final NRF document. The Work Groups and Steering Committee, 
both of which contained non-federal stakeholders, were not involved in 
adjudicating the public comments, although this was called for by the 
work plan. A FEMA official said that the agency tried to recruit a non-
federal stakeholder to serve on the Writing Team, but that its efforts 
were unsuccessful. 

DHS's Establishment of the National Advisory Council Did Not Meet Post- 
Katrina Act Deadlines, Which Also Limited Collaboration with Non- 
Federal Stakeholders: 

The Post-Katrina Act required the DHS Secretary to establish a National 
Advisory Council (NAC) by December 2006 to advise the FEMA 
Administrator on all aspects of emergency management. Among its 
specific responsibilities, the NAC was to incorporate input from state, 
local, and tribal governments as well as the private sector in the 
revision of the 2004 Plan. The Act stated that the membership of the 
NAC should represent a geographic and substantive cross-section of 
officials, emergency managers, and emergency response providers, such 
as law enforcement, fire service, health scientists, and elected 
officials. However, DHS did not incorporate the NAC by amending its 
approved September 2006 work plan for revising the 2004 Plan or 
establish the NAC in time for the Council to incorporate non-federal 
stakeholder input into the revision of the 2004 Plan, as directed by 
the October 2006 Post-Katrina Act. According to a FEMA official, DHS 
did not amend the work plan to incorporate the NAC because of the 
uncertainty surrounding the time it would take to establish the NAC. 
The official said FEMA expected that establishing the NAC would take 
more time than the Post-Katrina Act allowed because FEMA wanted to 
ensure that the NAC's membership complied with the requirements 
contained in the Post-Katrina Act while also providing adequate time to 
announce the NAC's creation, solicit applications for membership, and 
review and select applicants for membership. FEMA announced the 
membership of the NAC in June 2007, 6 months after the Post-Katrina Act 
deadline, and the NAC did not hold its inaugural meeting until October 
22, 2007, the last day of the public comment period for the base NRF. 
According to the FEMA Administrator, it was more important for the 
agency to invest the time needed to review hundreds of applications and 
create a high quality body of advisors than to rush the process to meet 
the 60-day statutory deadline for establishing the NAC. 

As a result, the NAC's only involvement in the NRF revision process 
occurred when FEMA provided it with a copy of a draft in December 2007, 
2 months after the public comment period closed. According to the NAC 
chairman, the NAC gathered and consolidated comments from individual 
members and provided these comments to the FEMA Administrator 
approximately one month before FEMA published the NRF in January 2008. 
[Footnote 25] The chairman noted that these comments were from 
individual members and did not reflect the official comments of the NAC 
as a whole. For the next NRF revision, the chairman stated that he 
expected the NAC to be actively involved with FEMA throughout the 
entire revision process. For example, he suggested that the NAC could 
have a role in the adjudication of public comments by representing non- 
federal stakeholders during the adjudication process to ensure FEMA is 
aware of issues that are critically important to state and local 
governments. The NAC is currently exploring its role in reviewing and 
implementing the 2008 NRF. For example, at the NAC's February 2008 
meeting the NAC Chairman approved a standing committee on the NRF that 
may focus on actions that can help FEMA implement and train 
stakeholders on the NRF. While the NAC filed a charter on February 6, 
2007, the charter reflects the NAC's broad array of statutory 
responsibilities, but does not detail any specific responsibilities the 
NAC would undertake relative to the NRF revision process. See figure 5 
for a comparison of DHS's actual revision process with its proposed 
process. 

Figure 5: DHS's Actual Revision Process Compared with Its Proposed 
Process: 

[See PDF for image] 

This figure is an illustration of DHS's actual Revision Process 
compared with Its Proposed Process, as follows: 

Date: September 2006; 
DHS's Actual Revision Process: Approved revision work plan; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Approved 
revision work plan. 

Date: October 2006; 
DHS's Actual Revision Process: 
DHS's Revision Process By Work Plan and Post-Katrina Act: 

Date: 
DHS's Actual Revision Process: Post-Katrina Act enacted; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Post-Katrina 
Act enacted. 

Date: October - November 2006; 
DHS's Actual Revision Process: Hold stakeholder meetings; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Hold 
stakeholder meetings. 

Date: December 2006; 
DHS's Revision Process By Work Plan and Post-Katrina Act: 
* Start revision process; 
* Establish NAC. 

Date: January 2007; 
DHS's Actual Revision Process: Started revision process; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Release first 
draft to stakeholders. 

Date: March 2006; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Release 
second draft to stakeholders. 

Date: April 2007; 
DHS's Actual Revision Process: Produced first draft but did not release 
to stakeholders. 

Date: April - August 2007: 
DHS's Actual Revision Process: Conducted internal federal review of 
first draft. 

Date: June 2007: 
DHS's Actual Revision Process: Announced NAC membership; 
DHS's Revision Process By Work Plan and Post-Katrina Act: Publish 
revised plan. 

Date: September 2007; 
DHS's Actual Revision Process: Congressional hearing of revision 
process. 

Date: September - October 2007: 
DHS's Actual Revision Process: Release first draft for public comments. 

Date: October - December 2007; 
DHS's Actual Revision Process: Adjudicated public comments. 

Date: December 2007: 
DHS's Actual Revision Process: NAC reviewed a draft NRF. 

Date: January 2008: 
DHS's Actual Revision Process: Published NRF. 

Source: GAO analysis of DHS data, and the Post-Katrina Act. 

[End of figure] 

The late establishment of the NAC also hindered FEMA from fully 
collaborating with non-federal stakeholders who were involved in the 
revision process established by the approved work plan. In particular, 
two non-federal Steering Committee members stated that after the August 
2007 leak of the draft NRF, FEMA stopped sharing drafts with non- 
federal officials. FEMA officials said that the reason for this 
decision was because FEMA had yet to establish the NAC, its official 
advisory committee. FEMA officials said that the absence of an official 
advisory committee raised fairness concerns about which members of the 
non-federal community should be allowed to provide input before the 
public comment period. As a result, FEMA stopped sharing pre-decisional 
drafts with non-federal members of the Steering Committee because FEMA 
did not plan to provide the same opportunity to other non-federal 
stakeholders until the public comment period. 

FEMA and the Post-Katrina Act Have Recognized the Importance of 
Including Non-Federal Stakeholders in Developing National Response 
Doctrine, but FEMA Lacks Guidance and Procedures for Future NRF 
Revisions: 

While FEMA has recognized the importance of partnering with non-federal 
stakeholders to achieve the nation's emergency management goals, both 
in congressional testimonies as well as in its January 2008 strategic 
plan, FEMA has not yet developed guidance and procedures for how future 
revisions of the NRF will be managed or how the newly established 
National Advisory Council will be integrated into the revision process 
in accordance with the Post-Katrina Act. Standards for Internal Control 
in the Federal Government state that management guidance, policies, and 
procedures are an integral part of any agency's planning for, and 
achieving, effective results.[Footnote 26] Developing such policies and 
procedures for how the NRF will be revised in the future and how FEMA 
will integrate the NAC and other non-federal stakeholders in the 
process is essential for helping to ensure that FEMA attains its goal 
of partnering with nonfederal stakeholders to help achieve the nation's 
emergency management goals. 

FEMA and the Post-Katrina Act Stress Partnership and Communication with 
Non-Federal Stakeholders in Achieving the Nation's Emergency Management 
Goals: 

FEMA has recognized the importance of including the input of non- 
federal stakeholders to help achieve the nation's emergency management 
goals. For example, in November 2006, the FEMA Administrator outlined 
his vision for a "New FEMA,"[Footnote 27] asserting FEMA's dedication 
to partnering with all states and the private sector because of FEMA's 
reliance on its partners to accomplish the national emergency response 
objectives. More recently, in congressional testimonies the FEMA 
Administrator has reaffirmed the need for FEMA to partner with both 
federal and non-federal stakeholders.[Footnote 28] In addition, one 
objective in FEMA's Strategic Plan for 2008-2013 is to engage public 
and private stakeholders in developing and communicating clear national 
doctrine and policy.[Footnote 29] To achieve this objective, the 
Strategic Plan identifies the need to engage stakeholders early and 
often in the process of developing national doctrine. This is in 
accordance with internal control standards for the federal government 
that state that information should be communicated to those who need it 
and in a form and within a time frame that enables them to carry out 
their responsibility for an agency to achieve its objectives.[Footnote 
30] For example, management should ensure there are adequate means of 
communicating with and obtaining information from external stakeholders 
who may have a significant impact on the agency's achieving its goals. 
In October 2005, we also reported that frequent communication among 
collaborating organizations and stakeholders is a means to facilitate 
working across boundaries, prevent misunderstanding, and achieve agency 
objectives.[Footnote 31] Frequent communication is one of a number of 
practices that enhance and sustain collaboration. 

Recognizing the importance of collaboration, the Post-Katrina Act 
requires that the FEMA Administrator partner with non-federal 
stakeholders from state, local, and tribal governments, the private 
sector, and nongovernmental organizations to build a national system of 
emergency management that can effectively and efficiently utilize the 
full measure of the nation's resources to respond to all disasters, 
including catastrophic incidents, and acts of terrorism.[Footnote 32] 
Specifically, the Post-Katrina Act directs the FEMA Administrator, 
through the National Integration Center, to periodically review and 
revise the National Response Plan and any successor to such plan and, 
as discussed above, to establish the NAC to incorporate non-federal 
stakeholder input in the revision and development of the Plan, among 
other things. The Post-Katrina Act further directs the FEMA 
Administrator to appoint council members who represent a geographic and 
substantive cross section of officials, emergency managers, and 
emergency response providers from the non-federal community. 

The FEMA Administrator's statements, the agency's latest strategic 
plan, and the Post-Katrina Act also reflect a key precept related to 
government performance and results--that stakeholders can have a 
significant effect in determining whether a federal agency's program or 
action will succeed or fail, and as such, stakeholders need to be 
involved in major planning efforts conducted by the agency.[Footnote 
33] Such involvement is important to help agencies ensure that their 
efforts and resources are targeted at the highest priorities and is 
particularly important in instances where federal agencies face a 
complex political environment, such as emergency management in which 
FEMA's successes depend on the actions of non-federal partners at the 
state and local levels. 

FEMA Has Not Yet Developed Guidance and Procedures for Managing Future 
Revisions or Integrating the National Advisory Council into the 
Revision Process: 

While FEMA officials and the National Response Framework acknowledge 
that the NRF will need to be revised in the future, FEMA has not 
developed guidance or policies on how it will manage future revisions 
or described how the NAC will be incorporated into the next NRF 
revision process. FEMA officials said that the agency has not yet 
developed guidance and procedures for any future NRF revisions because 
of the need to focus federal resources on creating training materials 
to assist all stakeholders in implementing the current NRF in 
anticipation of the pending 2008 hurricane season. As mentioned earlier 
in this report, the 2004 Plan included a section specifying the 
circumstances, such as lessons learned from exercises and actual 
events, and time frames under which it would need to be reviewed and 
revised. This section is in accordance with the federal internal 
control standard of monitoring operations to assess the quality of 
performance over time and ensure that the findings of reviews and 
evaluations are resolved. The 2008 NRF, while it states that it merits 
periodic review and revision, does not contain such language regarding 
the circumstances and time frames for its review and revision. In 
addition, FEMA officials said that the process established for the last 
revision (the 2006-approved work plan) would not be applicable for any 
future revisions because it did not consider the role of the NAC. The 
NAC has also not yet determined how it would like to be involved in the 
next NRF revision process. The NAC's charter, approved in February 
2007, does not provide specific procedures on how it is to be involved 
and, according to the chairman, the NAC's NRF subcommittee expects to 
focus its efforts on helping FEMA train non-federal stakeholders. 

Having such guidance and procedures in place is an important internal 
control, and we have identified this need for other agencies in similar 
circumstances to FEMA's management of future NRF revisions. As we 
discussed earlier in this report, control activities--such as guidance, 
policies, and procedures--are an integral part of an agency's planning 
for and achieving effective results.[Footnote 34] In addition, while 
internal controls should be flexible to meet an agency's needs, they 
should also be clearly documented, readily available, and properly 
maintained. We have also previously reported on the need to include 
state and local jurisdictions in the development of national response 
plans because they are key stakeholders and would be on the front lines 
if an incident occurs. 

* In April 2008, we reported on the need for the Department of 
Defense's Northern Command to collaborate and communicate with non- 
federal stakeholders and establish a process to guide such 
collaboration in accessing information on state emergency response 
plans and capabilities, noting that the absence of effective 
collaboration could impede intergovernmental planning for catastrophic 
incidents and overall coordination.[Footnote 35] Specifically, we 
reported that federal officials involved the states only minimally in 
the development of the Department of Defense's major homeland defense 
and civil support plans and that defense officials were generally not 
familiar with state emergency response plans and capabilities and had 
not established a process for gaining access to this information. We 
also reported that each agency's roles and responsibilities for 
planning for homeland defense and civil support during a catastrophic 
disaster were not clearly defined. We recommended, among other things, 
that the Department of Defense develop a thorough process to guide its 
coordination with the states. The department generally agreed with the 
recommendation and stated that it was coordinating with DHS to develop 
synchronized plans of integrated federal, state, and local operational 
capabilities to affect a coordinated national response. It is essential 
for both the Department of Defense and DHS to have such guidance in 
place, as both DHS's National Response Framework and the Northern 
Command's Concept of Operations emphasize coordination with non-federal 
stakeholders in order to prevent, prepare for, respond to, and recover 
from catastrophic natural and manmade disasters. 

* In August 2007, we reported on the administration's approach to 
preparing for a pandemic influenza by issuing, among other things, a 
National Strategy for Pandemic Influenza (Strategy) in November 2005, 
and a National Strategy for Pandemic Influenza Implementation Plan 
(Plan) in May 2006.[Footnote 36] We reported, among other things, that 
state and local jurisdictions were not directly involved in developing 
the Strategy and Plan. Neither the Strategy nor Plan described the 
involvement of key stakeholders, such as state, local, and tribal 
entities, in their development, even though these stakeholders would be 
on the front lines in a pandemic and the Plan identifies actions they 
should complete. Officials told us that while the drafters of the Plan 
were generally aware of their concerns, state, local, and tribal 
entities were not directly involved in reviewing and commenting on the 
Plan. We concluded that opportunities existed to improve the usefulness 
of the Plan because it was viewed as an evolving document and was 
intended to be updated on a regular basis to reflect ongoing policy 
decisions as well as improvements in domestic preparedness. However, 
time frames or mechanisms for updating the Plan were undefined. We 
recommended that the White House Homeland Security Council establish a 
specific process and time frame for updating the Plan and that the 
update process should involve key non-federal stakeholders and 
incorporate lessons learned from exercises and other sources, but the 
Homeland Security Council did not provide comments on this 
recommendation. 

Without similar policies and procedures documenting the circumstances 
and time frames under which it would review and revise the NRF and its 
process for collaborating with non-federal stakeholders, FEMA cannot 
ensure that future revision processes will be conducted in accordance 
with management's directives. 

Conclusions: 

All disasters occur locally, and the initial post-disaster response is 
local. However, large-scale disasters usually exceed local response 
capabilities. Effective preparation and response for major and 
catastrophic disasters require well-planned and well-coordinated 
actions among all those who would have a role in the response to such 
disasters. The 2008 NRF is a guide for the myriad of entities and 
personnel involved in response efforts at all levels. The NRF 
recognizes the need for collaboration among these stakeholders to 
collectively respond to and recover from all disasters, particularly 
catastrophic disasters such as Hurricane Katrina, regardless of their 
cause. 

To help ensure that the NRF meets the needs of all stakeholders who 
have a role in its effective implementation, it is essential that DHS 
fully collaborate with non-federal stakeholders in its development and 
revision. DHS initially involved non-federal stakeholders in the 
revision of the 2004 Plan but omitted a key step in its work plan by 
not obtaining and incorporating their comments on the first full draft. 
Instead, DHS undertook a closed, internal federal review of the draft 
that lasted about 5 months with little communication with the non- 
federal partners. The result was a breach of trust with DHS's non- 
federal partners in the drafting process. 

The Post-Katrina Act gives responsibility for maintaining and updating 
the NRF to FEMA and charges the Administrator's National Advisory 
Council with incorporating non-federal stakeholder input into the NRF's 
development and revision. Established too late to fulfill this role in 
the creation of the current NRF, the NAC is now functioning, and it is 
important that there be compatible policies and procedures for how the 
NAC will fulfill its statutory charge. 

Contrary to effective government internal control and management 
principles, FEMA has not yet developed policies and procedures for 
guiding future revisions of the NRF, including specifying the 
conditions and time frames under which FEMA would review and revise the 
NRF and how FEMA will involve the NAC and collaborate with other non- 
federal stakeholders. Especially in view of a new administration, non- 
federal stakeholder participation and ownership is essential in any 
revision of the NRF, and the lessons learned from the process for 
revising the 2004 Plan will apply in the future to FEMA's and DHS's 
efforts to develop and revise other national plans and policies that 
make up the national preparedness system. While the NRF is published by 
DHS, it belongs to the nation's emergency response community that is 
collectively responsible for effectively implementing the NRF's 
provisions should another catastrophic disaster like Hurricane Katrina 
occur. 

Recommendation for Executive Action: 

We recommend that the FEMA Administrator develop and disseminate 
policies and procedures that describe (1) the circumstances and time 
frames under which the next NRF revision will occur and (2) how FEMA 
will conduct the next NRF revision, including how its National Advisory 
Council and other non-federal stakeholders--state, local, and tribal 
governments; the private sector; and nongovernmental organizations-- 
will be integrated into the revision process and the methods for 
communicating with these stakeholders. 

Agency Comments: 

We requested comments on a draft of this report from DHS and FEMA. They 
concurred with our recommendations and had no other comments. 

We are sending copies of this report to the Secretary of Homeland 
Security, FEMA Administrator, and interested congressional committees. 
We will also provide copies to others on request. If you or your staff 
have any questions about this report or wish to discuss the matter 
further, please contact me at (202) 512-8777 or [email protected]. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. See appendix IV 
for a list of key contributors to this report. 

Signed by: 

William O. Jenkins, Jr. 
Director, Homeland Security and Justice Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

This report addresses the following questions: (1) To what extent did 
the Department of Homeland Security (DHS) collaborate with non-federal 
stakeholders in revising and updating the December 2004 National 
Response Plan into the January 2008 National Response Framework (NRF)? 
(2) To what extent has FEMA developed policies and procedures for 
managing future revisions of the NRF? 

To address these questions, we interviewed DHS, FEMA, and non-federal 
stakeholders who were directly involved in the revision and update of 
the 2004 Plan into the 2008 NRF, and we reviewed DHS and FEMA documents 
on the revision process. Because there were over 700 federal and non- 
federal officials who participated in the Steering Committee and Work 
Groups, we interviewed those who held key positions. The FEMA officials 
and non-federal stakeholders we interviewed held key positions in the 
revision process, such as the FEMA Administrator and Deputy 
Administrator and the two FEMA co-chairs of the Steering Committee. The 
non-federal stakeholders we interviewed included four of the five non- 
federal officials who served as Steering Committee members and all 
three of the non-federal officials who served as co-leaders of Work 
Groups; these non-federal stakeholders also held positions in state, 
county, and city governments and non-governmental organizations. 

To determine the extent to which DHS collaborated with non-federal 
stakeholders, we first determined the revision process that DHS had 
planned to follow to revise the 2004 Plan. We reviewed DHS's September 
2006 revision work plan that had been approved by the Domestic 
Readiness Group of White House's Homeland Security Council and 
interviewed FEMA and non-federal officials who served in key positions 
in the revision process. We also reviewed applicable statutes, 
primarily the October 2006 Post-Katrina Emergency Management Reform 
Act, for statutory requirements related to the revision process. To 
determine what happened during the revision process and the extent to 
which DHS involved non-federal stakeholders in that process, we 
interviewed FEMA officials and non-federal stakeholders who served in 
key positions in the revision process and the chairman of FEMA's 
National Advisory Council (NAC). Further, we reviewed DHS documentation 
citing the roles provided to non-federal stakeholders in the revision 
process and explaining how the actual revision process was conducted, 
FEMA documentation on the process and time frames related to the NAC's 
establishment, NAC documentation regarding its role in the revision 
process, and congressional testimony from non-federal stakeholders on 
how DHS conducted and included them in the revision process. To 
determine the extent to which FEMA had policies and procedures in place 
for future revisions of the NRF, we interviewed FEMA officials. 

The non-federal officials we interviewed represented state and local 
levels of government, emergency management associations, and other non- 
federal entities. While the statements and views of the stakeholders we 
interviewed are not generalizable to the some 230 non-federal 
stakeholders involved in the revision process, we chose to speak to 
them because of their assigned key roles. 

There is some uncertainty in our determination of the total number of 
non-federal members in the 12 Work Groups, and thus the total number of 
Work Group members, due to duplication or the lack of adequate 
information identifying a member as federal in the data provided by 
FEMA. However, because DHS's inclusion of non-federal members in the 
revision process is the focus of this report, we took steps to 
correctly determine the number and composition of the 224 non-federal 
members. Based on our analysis of FEMA's data for federal members, we 
believe the total of 486 federal members is a reasonable approximation, 
and therefore, the grand total of 710 Work Group members is also a 
reasonable approximation. 

[End of section] 

Appendix II: The 17 Key Revision Issues That DHS Identified for the 
2004 National Response Plan: 

In the 2004 National Response Plan revision work plan approved by the 
Domestic Readiness Group, a White House Homeland Security Council- 
chaired policy committee, in September 2006, DHS identified 14 key 
issues that it wanted the revision process to address. According to 
FEMA officials, these issues were compiled by reviewing Hurricane 
Katrina after-action and lessons-learned reports from the White House, 
Congress, GAO, and DHS's Inspector General and identifying common 
issues that were raised in multiple reports. The work plan directed DHS 
to conduct meetings with stakeholders to review the initial list and 
identify other issues to be considered during the revision process. 
These issues were to serve as the starting point from which the 2004 
Plan revision would be conducted. DHS held meetings with non-federal 
stakeholder and federal stakeholders in October and November 2006 
respectively. After these meetings, DHS identified three additional 
revision issues to its initial list contained in the approved work 
plan. The 17 key revision issues are listed below--the 3 issues added 
after the stakeholder meetings are indicated with a note. 

The revision issues are categorized by whether they were to be 
addressed in either the 2004 Plan base document or its annexes. The 
2004 Plan comprised four major components: the Base Plan, Emergency 
Support Function Annexes, Support Annexes, and Incident Annexes. The 
Base Plan provided an overview of the structure and processes 
comprising a national approach to domestic response actions. The 15 
Emergency Support Function Annexes detailed the missions, policies, 
structures, and responsibilities of federal agencies for coordinating 
resource and programmatic support, such as mass care and shelter, to 
states, tribes, and other federal agencies or other jurisdictions and 
entities. The nine Support Annexes provided guidance and described the 
functional processes and administrative requirements necessary to 
ensure the 2004 Plan's efficient and effective implementation. The 
seven Incident Annexes addressed contingency or hazard situations 
requiring specialized application of the 2004 Plan, such as biological, 
catastrophic, and nuclear/radiological incidents. 

The key revision issues identified for the 2004 National Response Plan 
base document were: 

* clarify roles and responsibilities of key structures, and positions, 
and levels of government; 

* strengthen role of states and private sector; 

* integrate National Incident Management System concepts, principles, 
terminology, systems, and organizational processes into the revised 
National Response Plan; 

* review Joint Field Office structure and operations, to include 
Unified Command; and: 

* incorporate proactive planning for incidents that render state and 
local governments incapable of an effective response. 

The key revision issues identified for the annexes to the 2004 National 
Response Plan base document were: 

* examine all existing National Response Plan annexes and proposed new 
annexes; 

* strengthen External Affairs and Public Affairs Annexes; 

* review logistics management issues; [Footnote 37] 

* examine evacuation and sheltering issues; [Footnote 38] 

* ensure the integration of all search and rescue assets; 

* review the scope of public safety and security missions; 

* incorporate companion animal issues; 

* improve process for identifying and accepting donated goods and the 
integration of volunteers; 

* clarify international support mechanisms; 

* ensure consistency with National Emergency Communication Strategy; 

* refine the Catastrophic Incident Supplement to include the review of 
a possible increased Department of Defense responsibility, and; 

* review federal incident management plans and determine their 
appropriate linkage to the National Response Plan.[Footnote 39] 

[End of section] 

Appendix III: The 12 Work Groups DHS Established during the Revision 
Process and Their Composition: 

The 2004 National Response Plan revision work plan approved by the 
Domestic Readiness Group in September 2006 directed DHS to establish 
Work Groups to rewrite portions of the 2004 Plan. While the work plan 
did not specify the number of Work Groups that should be established, 
DHS formed 12 Work Groups that were co-led by federal officials or a 
combination of federal and non-federal officials. The 12 Work Groups 
were: 

* Catastrophic Planning; 

* Communications; 

* Companion Animals; 

* Evacuations and Sheltering (co-led by non-federal stakeholder); 

* Functions; 

* Incident Management and Coordination; 

* International Support; 

* National Incident Management System; 

* Roles and Responsibilities (co-led by non-federal stakeholder); 

* Special Needs; 

* Training and Implementation, and; 

* Volunteer and Donation Management (co-led by non-federal 
stakeholder). 

Of the 709 members who served on the 12 Work Groups, 224 officials, or 
32 percent, were non-federal. These non-federal stakeholders included 
representatives from state, tribal, and local government as well as the 
private sector and nongovernmental organizations. Further, the non- 
federal stakeholders came from various occupational sectors. See table 
1 for a description of these 224 non-federal stakeholders. 

Table 1: The 224 Non-Federal Stakeholders Who Participated in the 
Revision Work Groups by Occupational Sector and by Level of Government, 
Nongovernmental Organization, and Private Sector: 

Occupational sector[A]: Animal, plant and food[B]; 
Level of government: Local: 2; 
Level of government: Tribal: [Empty]; 
Level of government: State: 5; 
Nongovernmental organization: 12; 
Private sector: 2; 
Total: 21. 

Occupational sector[A]: Critical infrastructure[C]; 
Level of government: Local: 1; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: 3; 
Private sector: 11; 
Total: 15. 

Occupational sector[A]: Disaster assistance services[D]; 
Level of government: Local: [Empty]; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: 24; 
Private sector: 
-; Total: 24. 

Occupational sector[A]: Elected government officials; 
Level of government: Local: [Empty]; 
Level of government: Tribal: 1; 
Level of government: State: [Empty]; 
Nongovernmental organization: [Empty]; 
Private sector: [Empty]; 
Total: 1. 

Occupational sector[A]: Emergency management and homeland security[E]; 
Level of government: Local: 7; 
Level of government: Tribal: 7; 
Level of government: State: 40; 
Nongovernmental organization: 8; 
Private sector: 4; 
Total: 66. 

Occupational sector[A]: Emergency medical providers and health 
sector[F]; 
Level of government: Local: 5; 
Level of government: Tribal: [Empty]; 
Level of government: State: 8; 
Nongovernmental organization: 9; 
Private sector: [Empty]; 
Total: 22. 

Occupational sector[A]: Fire and search and rescue; 
Level of government: Local: 4; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: 3; 
Private sector: [Empty]; 
Total: 7. 

Occupational sector[A]: General business[G]; 
Level of government: Local: [Empty]; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: [Empty]; 
Private sector: 12; 
Total: 12. 

Occupational sector[A]: General government[H]; 
Level of government: Local: 3; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty];
Nongovernmental organization: [Empty]; 
Private sector: [Empty]; 
Total: 3. 

Occupational sector[A]: Logistics and transportation[I]; 
Level of government: Local: 1; 
Level of government: Tribal: [Empty]; 
Level of government: State: 1; 
Nongovernmental organization: 2; 
Private sector: 3; 
Total: 7. 

Occupational sector[A]: Military and national security related[J]; 
Level of government: Local: [Empty]; 
Level of government: Tribal: [Empty]; 
Level of government: State: 3; 
Nongovernmental organization: [Empty]; 
Private sector: 2; 
Total: 5. 

Occupational sector[A]: Police and corrections; 
Level of government: Local: 10; 
Level of government: Tribal: [Empty]; 
Level of government: State: 3; 
Nongovernmental organization: 2; 
Private sector: [Empty]; 
Total: 15. 

Occupational sector[A]: Special needs populations[K]; 
Level of government: Local: 1; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: 7; 
Private sector: [Empty]; 
Total: 8. 

Occupational sector[A]: Standards and accreditation bodies; 
Level of government: Local: [Empty]; 
Level of government: Tribal: [Empty]; 
Level of government: State: [Empty]; 
Nongovernmental organization: [Empty]; 
Private sector: [Empty]; 
Total: 0. 

Occupational sector[A]: Volunteerism and voluntary organizations[L]; 
Level of government: Local: [Empty]; 
Level of government: Tribal: [Empty]; 
Level of government: State: 7; 
Nongovernmental organization: 8; 
Private sector: [Empty]; 
Total: 15. 

Occupational sector[A]: Unidentified[M]; 
Level of government: Local: 1; 
Level of government: Tribal: 1; 
Level of government: State: [Empty]; 
Nongovernmental organization: 1; 
Private sector: [Empty]; 
Total: 3. 

Occupational sector[A]: Total non-federal stakeholders; 
Level of government: Local: 35; 
Level of government: Tribal: 9; 
Level of government: State: 67; 
Nongovernmental organization: 79; 
Private sector: 34; 
Total: 224. 

Source: GAO analysis of FEMA data. 

[A] We developed this list of occupational sectors based on our 
analysis and categorization of the entities these 224 non-federal 
stakeholders represented. 

[B] Includes agriculture, animal control, animal health & welfare, food 
production and security, and veterinary associations. 

[C] Includes communications, cybersecurity, information technology, 
public works, and water. 

[D] Includes emergency food support, Red Cross, and religion-based 
assistance services. 

[E] Includes business continuity, contingency planning, crisis 
management, and risk analysis. 

[F] Includes emergency medical technicians, health officials, 
pharmacists and physicians associations; health departments and 
systems; and medical aviation. 

[G] Includes Chambers of Commerce, commodities trading, general 
consulting firms, public relations, and trade associations. 

[H] Includes cities association, city managers association, and city 
officials. 

[I] Includes package delivery services, revenue collection, supply- 
chain management, and mass transit. 

[J] Includes civilian air patrol, military affairs, and a national 
security related business association. 

[K] Includes children, disabilities, and low income housing. 

[L] Includes national, state, and local agencies that coordinate 
individual volunteers or coordinate voluntary organizations. 

[M] Unidentified means that we were able to determine the non-federal 
stakeholder's level of government, nongovernmental organization, or the 
private sector, but we could not determine the stakeholder's 
occupational sector. We excluded one unidentified non-federal 
stakeholder from this table for whom we could neither determine the 
individual's occupational sector nor level of government, a 
nongovernmental organization, or the private sector. 

[End of table] 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

William O. Jenkins, Jr., (202) 512-8777 or [email protected]: 

Acknowledgments: 

The following teams and individuals made key contributions to this 
report: Pille Anvelt, Patrick Bernard, Sam Hinojosa, Christopher 
Keisling, David Lysy, Sally Williamson, and Candice Wright, Homeland 
Security & Justice Team; Michele Fejfar, Applied Research & Methods; 
and Christine Davis, Jan Montgomery, and Janet Temko, General Counsel. 

[End of section] 

Footnotes: 

[1] GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and 
Accountability Controls Will Improve the Effectiveness of the Nation's 
Preparedness, Response, and Recovery System, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-618] (Washington, D.C.: Sept. 
6, 2006). 

[2] The Post-Katrina Act was enacted as Title VI of the Department of 
Homeland Security Appropriations Act, 2007, Pub. L. No. 109-295, 120 
Stat. 1355 (2006). 

[3] The new National Response Framework became effective on March 22, 
2008. 

[4] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[5] 42 U.S.C. 5121 et. seq. 

[6] Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

[7] Our report will refer to individual DHS components such as FEMA 
where the component has a defined, specific authority or can be 
identified as being specifically responsible for a particular action or 
decision. Otherwise, any reference to DHS will refer to DHS as a whole 
unless clearly specified otherwise. 

[8] U.S. House of Representatives, House Select Bipartisan Committee to 
Investigate the Preparation for and Response to Hurricane Katrina, A 
Failure of Initiative: Final Report of the House Select Bipartisan 
Committee to Investigate the Preparation for And Response to Hurricane 
Katrina (Washington, D.C.: Feb. 15, 2006). 

[9] U.S. Senate Committee on Homeland Security and Governmental 
Affairs, Hurricane Katrina: A Nation Still Unprepared (Washington, 
D.C.: May 2006). 

[10] White House Homeland Security Council, The Federal Response to 
Hurricane Katrina: Lessons Learned (Washington, D.C.: Feb. 23, 2006). 

[11] Department of Homeland Security Office of Inspector General, A 
Performance Review of FEMA's Disaster Management Activities in Response 
to Hurricane Katrina, OIG-06-32 (Washington, D.C.: Mar. 31, 2006). 

[12] Federal Emergency Management Agency, DHS/FEMA Initial Response 
Hotwash: Hurricane Katrina in Louisiana, DR-1603-LA (Feb. 13, 2006). 

[13] Pub. L. No. 109-234, 120 Stat. 418 (2006). 

[14] H.R. Conf. Rep. No. 109-494, at 118 (2006). 

[15] According to the December 2004 National Response Plan, a Notice of 
Change for updates to the Plan must specify the date, number, subject, 
purpose, background, and action required and provide the change 
language on one or more numbered and dated insert pages that would 
replace the modified pages in the Plan. Once published, the 
modifications were to be considered part of the Plan for operational 
purposes pending a formal revision and reissuance of the entire 
document. 

[16] There were 32 signatories to the 2004 National Response Plan--the 
heads of 15 federal departments, plus the Central Intelligence Agency, 
Environmental Protection Agency, FBI, Federal Communications 
Commission, General Services Administration, NASA, National 
Transportation Safety Board, Nuclear Regulatory Commission, Office of 
Personnel Management, Small Business Administration, Social Security 
Administration, Tennessee Valley Authority, U.S. Agency for 
International Development, U.S. Postal Service, American Red Cross, 
Corporation for National and Community Service, and National Voluntary 
Organizations Active in Disaster. 

[17] The work plan also established a fourth entity, the Interagency 
Task Force. The work plan primarily charged the Task Force with 
resolving conflicts in preparedness and response policy before these 
conflicts were presented to the Domestic Readiness Group for 
resolution. 

[18] Some Work Groups had one leader and others had two or three co- 
leaders. 

[19] GAO reported on this state-level compact in GAO, Emergency 
Management Assistance Compact: Enhancing EMAC's Collaborative and 
Administrative Capacity Should Improve National Disaster Response, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-854] (Washington, 
D.C.: June 29, 2007). 

[20] The DHS Deputy Secretary at the time resigned from his position in 
October 2007. 

[21] Readiness in the Post-Katrina and Post-9/11 World, Hearing of U.S. 
House Representatives, Committee on Transportation and Infrastructure, 
Subcommittee on Economic Development, Public Buildings, and Emergency 
Management, Sept. 11, 2007. The purpose of this hearing was to explore 
the process for revising the 2004 National Response Plan. 

[22] The International Association of Emergency Managers is a non- 
profit educational organization of emergency managers and disaster 
response professionals from all levels of government, as well as the 
military, the private sector and volunteer organizations in 58 
countries, with the mission to serve its members by providing 
information, networking and professional opportunities, and to advance 
the emergency management profession. 

[23] The National Emergency Management Association is a nonprofit, 
nonpartisan association of emergency management and homeland security 
professionals with a mission to provide national leadership and 
expertise in comprehensive emergency management; serve as a vital 
emergency management information and assistance resource; and advance 
continuous improvement in emergency management through strategic 
partnerships, innovative programs, and collaborative policy positions. 

[24] FEMA also released NRF's supplemental materials--including the 
Emergency Support Function Annexes, the Support Annexes, and the 
Incident Annexes--for a 30-day public comment period and received 2,385 
comments on these documents. See appendix II for descriptions of these 
NRF supplemental materials. 

[25] NAC submitted comments by using the form that FEMA asked the 
public to use when submitting comments on [hyperlink, 
http://www.regulations.gov]. 

[26] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1]. 

[27] Federal Emergency Management Agency, Director Paulison Lays Out 
Vision for "New FEMA," Press Release FNF-06-019 (November 2006). 

[28] "Reforming FEMA: Are We Making Progress?" R. David Paulison 
statement for the record before the United States House of 
Representatives, House Homeland Security Committee, Subcommittee on 
Emergency Communications, Preparedness, and Response and Subcommittee 
on Management, Investigations, and Oversight, February 28, 2007; and 
"The 2007 Hurricane Season: Are We Prepared?" R. David Paulison Oral 
Statement Before the United States House of Representatives, House 
Homeland Security Committee, Subcommittee on Emergency Communications, 
Preparedness, and Response, May 15, 2007. 

[29] Federal Emergency Management Agency, FEMA Strategic Plan Fiscal 
Years 2008-2013: The Nation's Preeminent Emergency Management and 
Preparedness Agency, FEMA P-422 (January 2008). 

[30] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1]. 

[31] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: October 
2005). 

[32] The Post-Katrina Act, Pub. L. No. 109-295, ï¿½ 611, 120 Stat. 1355, 
1396-1397 (amending the Homeland Security Act, ï¿½ 503(b)(2)(B). 

[33] GAO, Executive Guide: Implementing the Government Performance and 
Results Act, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/GGD-96-
118] (Washington, D.C.: June 1996). 

[34] GAO, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-
21.3.1]. 

[35] GAO, Homeland Defense: Steps Have Been Taken to Improve U.S. 
Northern Command's Coordination with States and National Guard Bureau, 
but Gaps Remain, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-
252] (Washington, D.C.: Apr. 16, 2008). 

[36] GAO, Influenza Pandemic: Further Efforts are Needed to Ensure 
Clearer Federal Leadership Roles and Effective National Strategy, 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-781] (Washington, 
D.C.: Aug. 14, 2007). See also GAO, Influenza Pandemic: Opportunities 
Exist to Clarify Federal Leadership Roles and Responsibilities and 
Improve Pandemic Planning, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-1257T] (Washington, D.C.: Sept. 26, 2007). 

[37] . This issue was added after DHS presented the initial 14 key 
revision issues identified in the work plan at stakeholder meetings 
with non-federal and federal stakeholders in October and November 2006. 

[38] See footnote 1. 

[39] See footnote 1. 

[End of section] 

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