Given the central role played by FEMA and other federal agencies, it is clear that ensuring efficient and effective executive branch policy and programs is critical for improving domestic disaster resilience. Most, if not all, relevant executive branch agencies have revised their disaster policies in recent years, reflecting in large part important lessons learned from major catastrophes such as Hurricane Katrina and Hurricane Sandy. While these reform efforts have streamlined many processes and helped communities better prepare for future disasters, additional efforts and initiatives are warranted.
Through authorization in key disaster legislation, congressionally funded resources, and presidential directives, federal agencies organize and execute numerous emergency management programs, from the national to the community level. Agencies must constantly assess the efficiencies and effectiveness of these programs in order to measure levels of preparedness and resilience. Assessments take many forms, including annual preparedness evaluations and after-action reports (AARs) from exercises and actual disasters. The risk, vulnerability, and capability factors analyzed in these assessments can influence federal grant funding, the development of general and incident-specific contingency plans, and the information shared with other jurisdictions and the private sector.
At the national level, Presidential Policy Directive 8: National Preparedness (PPD-8) guides efforts to improve collection, analysis, and distribution of disaster resilience data and information. This directive outlines requirements to formulate a national preparedness goal (NPG), a system to implement the goal, frameworks for each mission area, federal interagency operation plans, and public training and awareness efforts that support an all-hazards, all-of-nation approach to disasters.1 DHS subsequently published the first edition of the NPG, which identifies 31 core capabilities across five mission areas and establishes strategic-level targets or performance thresholds for each one.2 The national preparedness system works to achieve the NPG through different resources that help communities to identify and assess risk and to estimate, build, and improve capabilities.3 The results of risk assessments, as illustrated in Figure 3.1, directly affect how communities improve and validate their capabilities. Communities seeking federal emergency management and homeland security grants must complete a Threat and Hazard Identification and Risk Assessment (THIRA) in order to be considered for these funds. The end result of the system, before initiating a reassessment, is a set of State Preparedness Reports and a National Preparedness Report, which assesses the nation’s progress toward meeting the targets for each core capability in the NPG.4
FINDING #1: DHS HAS NOT DEVELOPED STANDARD, QUANTIFIABLE READINESS AND PERFORMANCE METRICS FOR STATE AND LOCAL GOVERNMENTS TO IDENTIFY GAPS AND ASSESS NEEDS FOR DISASTER PREPAREDNESS AND RESILIENCE.
While the NPG’s strategic-level capability targets and the THIRA guide’s recommended impact variables establish a basic framework of understanding, DHS has not developed standard metrics for jurisdictions to measure their capability levels. Although each jurisdiction has unique needs based on its location, population, and infrastructure, a standard set of quantifiable variables and target levels would help states assess relative preparedness to similar jurisdictions across the nation. The current THIRA guide fosters a self-determined assessment of national preparedness, which obfuscates the opportunity for objective, interstate comparisons.5 To date, DHS has proven unable to meet the requirements of PPD-8 to identify “clear, measurable, and prioritized” capability targets and measure readiness against those targets with “clear, objective, and quantifiable” performance metrics.6 Furthermore, Congress has reduced FEMA’s grant funding from its requested level over the past few years, due in part to the inability to demonstrate the effectiveness of grants in enhancing preparedness.7 Some have called for the development of a national preparedness assessment, separate from the NPG and National Preparedness Report, to identify clear capability requirements, measure ments, and gaps.8 However, adding another document requirement without recommending a method to identify metrics will likely only complicate the system.
One method for preparing metrics might be to first standardize existing impact measure ments. DHS measures potential consequences with six distinct variables9 in its Strategic National Risk Assessment, which identifies potential threats and hazards to the United States.10 Additionally, the THIRA guide recommends eight similar impact measure ments for jurisdictions to weigh risk and vulnerability. DHS should reconcile the differences in order to standardize the measure ments. Once DHS standardizes a set of measurable consequences, it can develop metrics for core capabilities with the goal of reducing the impact of disasters.
DHS can increase efficiency and productivity in determining the capability metrics by leveraging other sources—different elements of DHS, the interagency, and the private sector, for instance—that have more expertise than FEMA in certain sectors. For example, the Centers for Disease Control and Prevention, in coordination with the Robert Wood Johnson Foundation, developed the National Health Security Preparedness Index, which quantitatively measures a number of health-preparedness variables across states.11 Since many of the measure ments coincide with the health-related core capabilities in the NPG (e.g., public health and medical services), DHS could use the index as a model to establish the metrics for those capabilities.
Once impact variables and capability metrics are established, DHS can create scalable target levels for jurisdictions to compare relative preparedness and resilience levels across similar incidents and jurisdictions. The standardization of metrics for exercises and disasters in THIRAs and AARs will help jurisdictions measure relative success in closing the target-capability gap and more effectively cycle through each stage of the national preparedness system. This process can also help refine target levels unique to the destruction level of a threat/hazard and the size, location, and infrastructure and logistical capabilities of the jurisdiction. Furthermore, states and other jurisdictions can set priorities for grant requests and spending through the examination of their vulnerabilities in terms of the threats/hazards that pose the most risk to their communities.
FINDING #2: ROBUST ANALYSIS OF DISASTER PREPAREDNESS AND RESPONSE EFFORTS ACROSS DIFFERENT JURISDICTIONS DOES NOT EXIST.
To distribute information among different stakeholders in emergency management, DHS and FEMA maintain a Lessons Learned Information Sharing (LLIS) database with individual pages on different man-made and natural threats/hazards as well as core capabilities.12 However, this resource mainly provides access to third-party resources and a number of distinct AARs. Currently, only a limited number of analyses that synthesize data from multiple AARs exist in the database. The development of more trend analyses would enhance the database and effectively illustrate gaps and areas for improvement. In order for these analyses to provide a complete picture of national preparedness and response capabilities, more executive branch agencies need to conduct exercises, complete AARs on all exercises and disasters, and share the evaluations on LLIS. Access to a more robust dataset from all federal, state, and local partners will likely help jurisdictions make better evidence-based decisions through the examination of successes and failures in other places.13 To help achieve that goal, FEMA should provide access to newly developed THIRAs and State Preparedness Reports on the database as well. By analyzing and comparing the standardized core capability and impact measure ments from several sources, the LLIS database could guide executive branch policy and assessments across all levels of government and improve the preparedness of communities.
Continued pressures on the federal budget will place a premium on efficient use of preparedness and recovery dollars, a reality acknowledged by FEMA administrator Craig Fugate.14 Hazard mitigation offers just such an opportunity to create efficiencies by reducing recovery and response costs. Mitigation includes actions taken before a disaster strikes to reduce vulnerabilities for loss of life or property or the disruption of operations or functionality.15 Installing storm shutters, elevating home levels, updating building codes, and installing backup generators are all examples of mitigation. Increasing public awareness of the importance of disaster planning, including the effectiveness and cost-saving potential of hazard mitigation, can improve community resilience and reduce costs. The Multi-hazard Mitigation Council has determined that for every dollar spent on hazard mitigation, the nation reaps four dollars in future benefits.16 This finding further underscores the need to establish hazard mitigation as a priority in achieving resilience. One expert noted that spending on mitigation measures is often unpopular, however, due to the perception that support will be fleeting and because of the lack of immediate reward to taxpayers or investors.17
FINDING #3: WHILE FEDERAL EXECUTIVE BRANCH AGENCIES HAVE RECENTLY ENHANCED THEIR FOCUS ON HAZARD MITIGATION, MITIGATION EFFORTS ARE STILL UNDERREPRESENTED IN THE DISTRIBUTION OF GRANT FUNDING.
One of the primary tools used by the federal government to promote hazard mitigation is the National Flood Insurance Program (NFIP), which requires home and business owners to adopt certain building standards and floodplain management strategies in order to receive flood insurance.18 FEMA has received additional authority through recent legislation to assess mitigation efforts in determining premium rates; such assessments are intended to persuade home and business owners to exceed standard requirements.19 FEMA also provides annual grants through the Flood Mitigation Assistance (FMA) program to homes and businesses in order to reduce or eliminate NFIP claims through mitigation planning and projects.20 As updated, risk-based flood mapping starts to increase premiums, FEMA should continue to prioritize and inform insurance recipients of the cost-saving and damage-reducing potential of flood mitigation.
Of the other two mitigation grant programs administered by FEMA, the Pre-Disaster Mitigation (PDM) program represents DHS’s only purely preventative program for building infrastructure.21 At $25 million in FY 14 funds, the PDM program has been significantly smaller than grant programs for emergency management and homeland security.22 These larger programs can be used by jurisdictions to acquire assets to prevent and protect against man-made disasters and increase response and recovery capabilities. However, the PDM program provides invaluable support for hardening building infrastructure before a disaster strikes, which helps prevent loss of life and property and aids continuity of business operations. In President Obama’s FY 15 budget request, the Opportunity, Growth, and Security Initiative includes $400 million for the PDM program, a 1,500 percent increase over the current funding level.23 This proposed increase is accompanied by a broadening in the scope of PDM funding to include “climate adaptation” projects.24 It will be critical to ensure this broadening helps rather than hinders community investment in infrastructure improvements aimed at decreasing the cost of future natural disasters.
There are many other opportunities for DHS and other federal agencies to promote cost savings through mitigation investment. For example, the Hazard Mitigation Grant Program (HMGP), although ex post facto in nature, provides assistance for enhancing building infrastructure to eligible jurisdictions and private nonprofit organizations after a presidentially declared major disaster.25 However, this program only received about 4 percent of all funding for federally declared disasters from FYs 2004–2011 and is expected to only account for just 2 percent of Hurricane Sandy spending through FY 2014.26 The Department of Housing and Urban Development’s Community Development Block Grant (HUD’s CDBG) provides about $3 billion annually for housing and economic development and disaster recovery assistance to low-and moderate-income communities.27 For the additional $5.4 billion appropriated for Hurricane Sandy recovery efforts, HUD has outlined minimum mitigation requirements for applicants.28 However, HUD could improve the cost-saving effects of the program by making mitigation a more important factor in the allocation of all CDBG funds.
DHS and other agencies should reexamine their priorities for resource and fund allocation in an effort to promote mitigation efforts. Such an examination will require the development and prioritization of long-term goals and cost considerations. To create such a strategy, agencies can learn from the risks and vulnerabilities revealed through the THIRA and AAR processes. Additionally, DHS can utilize knowledge gained from the Quadrennial Homeland Security Review (QHSR) process to align “programs, assets, capabilities, budget, policies, and authorities of the Department.”29 Focusing on risk mitigation as part of a long-term strategy could reduce costs and increase community resilience.
FINDING #4: FEDERAL EXECUTIVE BRANCH AGENCIES HAVE NOT DEVELOPED A CLEAR FRAMEWORK FOR WAIVING REGULATORY AND OTHER REQUIREMENTS BEFORE, DURING, AND AFTER DISASTERS.
Among the most important authorities of executive branch agencies—especially immediately before and after a disaster—is the waiver or suspension of certain conditions for the administration of assistance programs. Depending on the authority designated in the statute, the president, Congress, or the administrator of the federal agency can waive specific regulatory requirements or extend deadlines on certain reports or applications.30 For example, after both Hurricane Katrina and Hurricane Sandy, federal agencies waived several regulatory and other restrictions, including the transportation of petroleum by non-U.S. vessels between U.S. ports, fuel standards, low-income housing tax credits, filing deadlines, and trucker hours.31 While the federal executive branch and Congress have the authority to independently suspend or modify the majority of requirements available for waivers, some require requests by states and municipalities. Under the Stafford Act, federal agencies can only waive or modify administrative conditions that prevent the provision of federal assistance programs if state or local authorities request such waivers or modifications.32 However, jurisdictions are often unaware of the assistance programs that require waiver requests. Furthermore, jurisdictions have indicated a lack of knowledge over the specific conditions for the implementation of waivers.33 This lack of awareness stems from their ad hoc nature. Developing a clear framework for the modification or suspension of regulatory and other requirements—a framework that includes thresholds for enactment of general and incident-specific waivers, the need for a request, and any limitations or exceptions (e.g., duration)—could better inform jurisdictions of the specific conditions associated with each potential waiver. With such a source to provide awareness for planning for waivers and preparing requests, jurisdictions could improve their readiness in advance of disasters or immediately following no-notice events and reduce barriers to response and recovery.
FINDING #5: STATE AND LOCAL GOVERNMENTS’ WAIVER AND CREDENTIALING POLICIES REQUIRE MORE FLEXIBILITY FOR ESSENTIAL RESPONSE MISSIONS. MISSION ASSIGNMENTS AMONG ALL EXECUTIVE BRANCH AGENCIES MAY ALSO BENEFIT FROM FLEXIBILITY.
In addition to waivers for certain federal statutes and regulations, states and other jurisdictions may need to waive their own guidelines to expedite delivery of supplies and services across borders. For instance, each state’s transportation department sets unique weight limits for vehicles. States may be reticent to waive these limits due to the liability from any potential accidents.34 While calculating limits based on risk and vulnerability remains important to ensuring safety, states can transfer a degree of risk to the federal level through available assistance. The knowledge that the federal government would cover 75 percent of the liability may help ease burdensome restrictions and permit quicker flows of supplies.35
Jurisdictions also often need support from professionals in certain industries that require licenses or credentials to perform tasks, such as delivering medical services or restoring power. However, these incident managers and emergency responders invariably hold separate licenses and credentials depending on their jurisdiction of origin. For instance, emergency medical service personnel from Georgia attempting to support hurricane response in Florida may not possess the required credentials to perform medical service in Florida. Federal employees and contractors have specific processing standards for personal identity verification, but state, local, and private-sector employees must often rely on other mechanisms of authentication.36 FEMA maintains a guide that outlines the process for each state to approve credentials for assistance provided through the Emergency Management Assistance Compact (EMAC), a mutual aid agreement among all U.S. states and territories for the sharing of resources in the wake of disasters.37 However, waiting on credential processing may hinder relief efforts. States can increase response time and services delivered through EMAC by developing memorandums of understanding (MOUs) that allow temporary credential approval for essential missions.
Before interagency or interstate support efforts can begin, the supporting agencies or personnel also require written mission orders or assignments from the lead agency. A Hurricane Sandy AAR found that 40 percent of federal mission assignments took longer than 24 hours to process, which prevented the execution of crucial tasks.38 In some instances, when supporting agencies proved willing, FEMA utilized pre-scripted and verbal mission assignments to lessen the impact of these delays.39 The use of these alternative forms of mission assignments can help improve the efficiency and effectiveness of inter-agency and interstate support in disaster response and help prevent further loss of life and property in affected communities.
1. Obama, “PPD-8.”
2. DHS, “National Preparedness Goal,” 1.
3. DHS, “National Preparedness System,” November 2011, 1, http://www.fema.gov/pdf/prepared/nps_description.pdf.
4. DHS, “National Preparedness Report,” March 30, 2014, 1, http://www.fema.gov/media-library-data/1409688068371-d71247cabc52a55de78305a4462d0e1a/2014%20NPR_FINAL_082914_508v11.pdf.
5. David C. Maurer, “National Preparedness: FEMA Has Made Progress, but Additional Steps Are Needed to Improve Grant Management and Assess Capabilities,” GAO-13-637T (Washington, DC: U.S. Government Accountability Office, June 25, 2013), 12, http://www.gao.gov/assets/660/655392.pdf.
6. Obama, “PPD-8.”
7. Maurer, “National Preparedness,” 9.
8. Ibid., 5.
9. The variables include loss of life, injuries and illnesses, direct economic costs, social displacement, psychological distress, and environmental impact.
10. DHS, “The Strategic National Risk Assessment in Support of PPD-8: A Comprehensive Risk-Based Approach toward a Secure and Resilient Nation,” December 2011, http://www.dhs.gov/xlibrary/assets/rma-strategic-national-risk-assessment-ppd8.pdf.
11. Study participant, one-on-one, not-for-attribution interview, April 2014.
12. DHS, “Lessons Learned Information Sharing (LLIS),” www.llis.dhs.gov.
13. Study participant, one-on-one, not-for-attribution interview, May 2014.
14. Craig Fugate, “Written Testimony of Federal Emergency Management Agency Administrator Craig Fugate for Senate Committee on Appropriations, Subcommittee on Homeland Security hearing titled ‘Rebuilding after Hurricane Sandy,’ ” March 1, 2013, www.dhs.gov/news/2013/03/01/written-testimony-fema-administrator-craig-fugate-senate-committee-appropriations.
15. FEMA, “What Is Mitigation?,” last updated September 26, 2013, http://www.fema.gov/what-mitigation#1.
16. Multihazard Mitigation Council, “Natural Hazard Mitigation Saves: An Independent Study to Assess the Future Savings from Mitigation Activities: Volume 1—Findings, Conclusions, and Recommendations” (Washington, DC: National Institute of Building Sciences, 2005), 5, http://c.ymcdn.com/sites/www.nibs.org/resource/resmgr/MMC/hms_vol1.pdf.
17. Study participant, one-on-one, not-for-attribution interview, April 2014.
18. U.S. Government Accountability Office (GAO), “Flood Insurance: Strategies for Increasing Private Sector Involvement,” GAO-14-127 (Washington, DC: January 2014), 4, http://www.gao.gov/assets/670/660309.pdf.
19. Homeowner Flood Insurance Affordability Act of 2014, Public Law No: 113-89, 128 STAT. 1026 (2014).
20. FEMA, Hazard Mitigation Assistance Unified Guidance (Washington, DC: DHS, July 12, 2013), 3, http://www.fema.gov/media-library-data/1381842520166-4d0b88314cfaa2b7e114391ce6ff2d73/508_FINAL_Guidance_09112013.pdf.
21. The other program, the Flood Mitigation Assistance (FMA) grant program, focuses primarily on repetitive loss buildings and structures. FEMA, “FY 2014 Flood Mitigation Assistance (FMA) Grant Program Fact Sheet,” May 9, 2014, 1, http://www.mass.gov/eopss/docs/mema/mitigation/fy14-fma-fact-sheet-final-4-3-14-final.pdf.
22. By comparison, in FY 2014, the Emergency Management Performance Grants (EMPG) program was funded at approximately $350 million and the Homeland Security Grant Program (HSGP) at $1.2 billion. DHS, Congressional Budget Justification FY 2015, 10, http://www.dhs.gov/sites/default/files/publications/DHS-Congressional-Budget-Justification-FY2015.pdf.
23. DHS, “Budget-in-Brief: Fiscal Year 2015,” 131, http://www.dhs.gov/sites/default/files/publications/FY15BIB.pdf.
24. David Miller, “The Role of Mitigation in Reducing Federal Expenditures for Disaster Response,” statement before Senate Homeland Security and Government Affairs, Subcommittee on Emergency Management, Intergovernmental Relations, and the District of Columbia, May 14, 2014, http://www.hsgac.senate.gov/subcommittees/emdc/hearings/the-role-of-mitigation-in-reducing-federal-expenditures-for-disaster-response.
25. Ibid., 1.
26. Staff of the GAO, “Federal Disaster Assistance: Improved Criteria Needed to Assess a Jurisdiction’s Capability to Respond and Recover on Its Own,” GAO-12-838 (Washington, DC: September 2012), http://www.gao.gov/assets/650/648162.pdf.
27. U.S. Department of Housing and Urban Development (HUD), “Community Planning and Development: Community Development Fund—2015 Summary Statement and Initiatives,” http://portal.hud.gov/hudportal/documents/huddoc?id=fy15cj_comm_dvlpt_fnd.pdf.
28. HUD, “Clarifying Guidance, Waivers, and Alternative Requirements for Hurricane Sandy Grantees in Receipt of Community Development Block Grant Disaster Recovery Funds,” Federal Register 78, no. 76 (April 19, 2014): 23578–23581, https://www.federalregister.gov/articles/2013/04/19/2013-09228/clarifying-guidance-waivers-and-alternative-requirements-for-hurricane-sandy-grantees-in-receipt-of#h-10.
29. Quadrennial Homeland Security Review, 6 U.S.C. § 347 (2011), www.gpo.gov/fdsys/pkg/USCODE-2011-title6/html/USCODE-2011-title6-chap1-subchapVII-sec347.htm.
30. Curtis W. Copeland, “Regulatory Waivers and Extensions Pursuant to Hurricane Katrina,” CRS Report for Congress, September 13, 2005, 1, www.au.af.mil/au/awc/awcgate/crs/rs22253.pdf.
31. Ibid., 2–6; FEMA, “Hurricane Sandy: Timeline,” last updated October 28, 2013, http://www.fema.gov/hurricane-sandy-timeline.
32. Stafford Act, Title III, § 301.
33. Study participant, one-on-one, not-for-attribution interview, April 2014.
34. Study participant, one-on-one, not-for-attribution interview, April 2014.
35. Study participant, one-on-one, not-for-attribution interview, May 2014.
36. DHS, “National Incident Management System: Guideline for the Credentialing of Personnel,” August 2011, http://www.fema.gov/pdf/emergency/nims/nims_cred_guidelines_report.pdf.
37. Ibid., 17.
38. FEMA, “Hurricane Sandy FEMA After-Action Report,” July 1, 2013, 11, https://www.llis.dhs.gov/sites/default/files/Sandy%20FEMA%20AAR.pdf.
39. Ibid., 12.