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March 2012 Archives
March 12, 2012

Recently, DHS, through FEMA, released the National Preparedness Grant Program (NPGP) Vision Document as part of its plan to overhaul federal preparedness grants beginning in FY 2013. While FEMA deserves credit for recognizing that changes are needed to the current suite of homeland security grant programs, the NPGP as it is currently envisioned raises serious questions. The following summarizes a few of the key issues facing the proposed NPGP and offers some suggestions for strengthening the proposal.

Streamlining the Grants

In FY 2011, there were 13 independently funded State and local homeland security grant programs (not including Emergency Management Performance Grants and the Assistance to Firefighters Grant). These 13 programs should be consolidated. Among these programs only two were and remain enterprise wide programs that cover all aspects of homeland security within the framework of Presidential Policy Directive No. 8 (National Preparedness) consisting of prevention, protection, mitigation, response and recovery – the Urban Areas Security Initiative (UASI) and the State Homeland Security program (SHSP). All of the other programs are niche programs that essentially cover a critical infrastructure sector, response discipline, hazard type, etc. By consolidating the grants under these two programs, which would make up the NPGP, the NPGP will better integrate the activities of the critical infrastructure sectors, and public health and safety personnel in the States and Urban Areas. 

Building National Capacity

The UASI and SHSP have been effective over the years in strengthening national preparedness. FEMA recognized this fact in its NPGP Vision Document where it states:

Over the past nearly 10 years, we have seen how federal investments in state, territory, tribal and local preparedness capabilities have developed significant national capacity to prevent, protect against, respond to and recover from all kinds of disasters and threats (emphasis added).

Thus, these two programs are already achieving one of the stated goals of the NPGP, to “build a robust national preparedness capacity based on cross-jurisdictional and readily deployable state and local assets.” A text book example of this occurred in 2011 where UASI funded cross jurisdictional equipment and training played a critical role in life saving search and rescue operations following the tornado in Joplin, MO.

The NPGP’s emphasis on building “nationally deployable” capabilities versus those that are not (with some exceptions) creates some confusion, insofar as no definition for what constitutes a nationally deployable asset has ever been provided, and tries to fix a problem that does not exist as evidenced by the Joplin response.  The NPGP approach may lead to the creation of certain assets that do not have a day-to-day role to play as these assets will sit in a “glass case” to be broken only during a “national emergency” that may or may not occur. The current approach of building capabilities and assets that are scalable - ones that can be used for local threats and incidents and can be deployed for regional and national threats and incidents – is the better and more cost effective method.  This approach was strengthened already by FEMA in the FY 2012 grant requirements with the mandate that every State be a member of the Emergency Management Assistance Compact (EMAC), a mutual aid system among the States, in order to be eligible for grant funds.

Preparedness Grant Governance

Grants designed to build regional, statewide and national capacity must have a governance model attached to them to be truly effective. Otherwise, grants simply become checks funding one-off projects not tied to assessments, strategies and implementation plans. Unfortunately, the NPGP proposal moves away from the current strategic governance based approach to a competitive and individual project based approach. In fact, the current SHSP and UASI required regional governance structure and regional strategy would no longer be required under the NPGP as it stands.

It is this regional governance structure that has done more to enhance and build regional and national capacity than perhaps anything else since 9/11.  It is this structure that has set the foundation for local jurisdictions across the country to act regionally as opposed to each individual jurisdiction and agency planning and acting on its own. This regional collaboration and partnership approach must be strengthened and supported by FEMA, not dropped in place of a yet to be defined competitive grant program that will likely favor those who have the best grant writers as opposed to projects that best enhance regional and national preparedness.

A purely competitive program will likely pit cities, counties, and states against each other when they should be focused on working together to invest where the risk is greatest and the investments are most effective as many are doing under the current UASI governance structure in particular.  For example, under the NPGP will Kansas City, Missouri have to compete with Johnson County, Kansas even though both are in the same Urban Area under the UASI program today? We are already seeing such an outcome in the FY 2012 Port Security Grant Program (PSGP), which has moved away from area wide security and planning among ports in a region to a purely competitive program allowing single facilities in the same port, let alone region, compete with each other for funding.

Rather than doing away with effective governance models that have been developed and calibrated over the last decade, upon consolidation of the programs under UASI and SHSP, FEMA should develop requirements for better integration of and within the States, Urban Areas and FEMA regions concerning the governance and planning process. For example, the Transit Security Grant Program (TSGP) and PSGP should be rolled-up under the UASI program (as was done under the FY 2003 Supplemental Appropriation) with the Regional Transit Security Working Group (RTSWG) and the Area Maritime Security Committee serving as required subcommittees under applicable UASI Urban Area Working Groups.

The ports and transit agencies in and around major Urban Areas are key factors in determining where risk is highest across Urban Areas in the first place. Therefore, better integration among these critical infrastructure sectors and the Urban Areas of which they are a part should be a priority. To ensure their equities are protected, as is the case currently with the intelligence fusion centers in the States and Urban Areas under SHSP and UASI, investments in port and transit security from each State and/or Urban Area should be required based upon risk and effectiveness.

Finally, the consolidated grants should better outline the roles of FEMA and the States in the governance and planning process. This should include a requirement that FEMA regions and the States participate and sit on key committees in the Urban Area to continuously assist in assessments, planning and investing based on an agreed upon risk and capabilities based strategy and implementation plan. This is already occurring to some extent under the TSGP, which requires that TSA and the State participate in and co-chair the RTSWG respectively.

Assessments and Plans

While the NPGP’s emphasis on the threat and hazard identification and risk assessment (THIRA) is a positive step insofar as each State (and Urban Area) should be required to conduct a THIRA, developing projects based on a THIRA alone is not enough. Understanding risk outside the context of understanding capabilities needed to mitigate that risk presents an incomplete picture (the NPGP is vague on the role capabilities assessments should play). Moreover, it is the combination of the two data sets (risk and capability levels) that should then lead to developing strategies and implementation plans formed under a regional collaborative governance structure that has and will produce the best results – regional projects to sustain critical capability levels along with projects to close critical capability gaps.  A THIRA is no more a homeland security plan than a hazard identification and risk assessment (HIRA) is a hazard mitigation plan. In both cases the THIRA and HIRA inform each relevant plan.

Today, many States and Urban Areas across the country are engaged in continuous and sophisticated risk and capabilities assessments that drive strategic planning and investing. FEMA has not yet released the THIRA guidance, but hopefully States and Urban Areas will be given an opportunity to comment on it prior to its becoming final since so much work has already gone into risk assessments at the State and Urban Area level.  Finally, the Department of Homeland Security has not issued guidance on updating State and Urban Area homeland security strategies since 2005. With the new National Preparedness Goal in place, now is the time to develop such guidance in collaboration with States and Urban Areas. 

Management and Administration

In doing away with the all the current grant programs and their related governance and administration structures, the NPGP provides no alternative framework other than to have the States manage the process. While greater coordination and collaboration among Urban Areas and States (and FEMA regions) can and should occur through a UASI and SHSP based NPGP, the States’ ability to effectively manage such a massive and yet to be defined budget process as outlined by the current NPGP is dubious at best. States have undergone large cut backs over the last several years and simply don’t have the resources to manage this new responsibility effectively. Rather than imposing all the responsibility on the States, maintaining the UASI structure in particular will alleviate much of this burden and allow administration responsibilities to continue to be shared at the Urban Area and State levels through a modified and improved grant governance, planning and administration structure.

The Role of Risk

The NPGP Vision Document states that the program will be “risk informed” when it comes to allocating funding among the States, but is unclear as to what that will mean in actual practice. The NPGP does not specify if risk will be limited to terrorism risk or if an all hazards risk assessment will be used or possibly even both methods. The NPGP notes that, “priorities will vary by region according to the risks and hazards therein (i.e. hurricane risk for Gulf and East Coast states, terrorism for large urban areas, flooding in the Mid- West and earthquakes and wildfires on the West Coast).”

SHSP and UASI are currently allocated based upon terrorism risk with the understanding that capabilities developed through either program may be dual use – designed primarily for terrorism but applicable to other hazards as well. This approach strikes the appropriate balance and reflects many years-worth of negotiations and compromise. A potential move to an all hazards risk assessment by FEMA in determining how to allocate funds will have an impact on how funds are distributed with the most likely outcome being funds moving away from jurisdictions that face a high risk from terrorism to those jurisdictions that face a high risk from natural hazards such as hurricanes. 

Performance Metrics and Measures

Congress and the American people have a right to demand that FEMA, States and Urban Areas measure the effectiveness of the homeland security grant programs. Several national and Urban Area level reports on UASI and SHSP have been issued over the last year to begin this process. Such measuring and reporting must continue based on the Core Capabilities in the National Preparedness Goal through a partnership between FEMA, the States and Urban Areas. FEMA has made progress in this area in both the FY 2011 and FY 2012 grant guidance by outlining specific priorities and associated metrics and reporting requirements. A core element for building upon this is to ensure that State and Urban Area homeland security strategies are aligned with the National Preparedness Goal and for FEMA to better use the strategies and implementation plans to monitor investments after funding is awarded.

The FEMA required investment justifications, which outline how grantees intend to spend their grant funds, must be tied directly to those strategies and implementation plans and FEMA should ensure that actual spending, with some room for modifications, takes place as outlined in the investment justifications. Investment justifications should be designed and viewed as the culmination of a planning process in which THIRAs and capabilities assessment have occurred, which then help drive strategies and implementation plans with the investment justifications serving as the final phase of implementation for a particular fiscal year. 

The investment justification process should be a collaborative one involving DHS, the FEMA regions, the States and Urban Areas. Such investments should then be peer reviewed, not as part of a competitive grant program, but rather, to determine if the investments adequately tie to the implementation plans upon which they must be based.  Reporting to DHS by States and Urban Areas should occur through a modified and enhanced (Bi-annual Strategy Implementation Report), the tool currently used for reporting, but which seems to have no place in the proposed NPGP.

Summary

FY 2013 presents an opportunity to better streamline and integrate the multiple homeland security grants by using the SHSP and UASI as anchors for doing so. Changes to the current construct must be based on preserving and strengthening that which is working and refining or discarding that which is not. Under such an approach, the NPGP can become an effective instrument of national policy designed to implement the National Preparedness Goal in order to strengthen homeland security.


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