	National Response Framework’s Criteria for Response Planning

The National Response Framework discusses several elements of  effective response and response planning. A plan is acceptable if it can meet the requirements of  anticipated scenarios, can be implemented within the costs and time  frames that senior officials and the public can support, and is  consistent with applicable laws. Adequacy. A plan is complete if it incorporates major actions,  objectives, and tasks to be accomplished. Consistency and standardization of products. Standardized  planning processes and products foster consistency, interoperability,  and collaboration, therefore, emergency operations plans for disaster  response should be consistent with all other related planning  documents. Feasibility. Flexibility. FEMA has developed standards—the Comprehensive  Preparedness Guide 101—that call for validation, review, and testing of  emergency operations plans (EOP),. Exercises  offer the best way, short of emergencies, to determine if an EOP is  understood and “works.” Further, conducting a “tabletop” exercise  involving the key representatives of each tasked organization can serve as  a practical and useful means to help validate the plan. FEMA’s guidance  also suggests that officials use functional and full-scale emergency  management exercises to evaluate EOPs. The Post-Katrina Emergency  Management Reform Act transferred preparedness responsibilities to  FEMA, and we recommended in April 2009 that FEMA should improve its  approach to developing policies and plans that define roles and  responsibilities and planning processes by developing a program  management plan, in coordination with DHS and other federal entities, to  ensure the completion of the key national preparedness policies and plans  called for in legislation, presidential directives, and existing policy and  doctrine; to define roles and responsibilities and planning processes; as  well as to fully integrate such policies and plans into other elements of the  national preparedness system. FEMA concurred with our  recommendation and is currently working to address this  recommendation. Other national standards reflect these practices as well. For example,  according to Emergency Management Accreditation Program (EMAP)  standards, the development, coordination and implementation of  operational plans and procedures are fundamental to effective disaster  response and recovery. EMAP standards  call for a program of regularly scheduled drills, exercises, and appropriate  follow-through activities—designed for assessment and evaluation of  emergency plans and capabilities—as a critical component of a state,  territorial, tribal or local emergency management program. Status of National Disaster Planning Efforts

We reported in April 2009 that FEMA lacked a comprehensive approach to  managing the development of emergency preparedness policies and  plans. Specifically, we reported that FEMA had completed many policy  and planning documents, but a number of others were not yet completed. In February 2010, DHS’s Office of Inspector General reviewed the status of  these planning efforts and reported that the full set of plans for any single  scenario had not yet been completed partly because of the time required  to develop and implement the Integrated Planning System. The  Integrated Planning System, required by Annex 1 to Homeland Security  Presidential Directive 8 (December 2007), is intended to be a st comprehensive approach to national planning. Operational Response Plans for Oil Spill Responses

Oil spills are a special case with regard to response. The National Response Framework has 15 functional annexes,  such as search and rescue, which provide the structure for coordinating  federal interagency support for a federal response to an incident. Emergency Support Function #10, the Oil and Hazardous Materials  Response Annex, governs oil spills. As described in Emergency Support  Function #10, in general, the Environmental Protection Agency is the lead  for incidents in the inland zone, and the U.S. Coast Guard, within DHS, is  the lead for incidents in the coastal zone. The difference in responding to  oil spills and the shared responsibility across multiple federal agencies  underscores the importance of including clear roles, responsibilities, and  legal authorities in developing operational response plans.
Why GAO Did This Study

Among the lessons learned from the aftermath of Hurricane Katrina was that effective disaster response requires planning followed by the execution of training and exercises to validate those plans. The Federal Emergency Management Agency (FEMA) is responsible for disaster response planning. This testimony focuses on (1) criteria for effective disaster response planning established in FEMA's National Response Framework, (2) additional guidance for disaster planning, (3) the status of disaster planning efforts, and (4) special circumstances in planning for oil spills. This testimony is based on prior GAO work on emergency planning and response, including GAO's April 2009 report on the FEMA efforts to lead the development of a national preparedness system. GAO reviewed the policies and plans that form the basis of the preparedness system. GAO did not assess any criteria used or the operational planning for the Deepwater Horizon response.

What GAO Found

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

What GAO Recommends

GAO is not making any new recommendations in this testimony but has made recommendations to FEMA in previous reports to strengthen disaster response planning, including the development of a management plan to ensure the completion of key national policies and planning documents. FEMA concurred and is currently working to address this recommendation.