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from Federal Guidance on Responding to Nuclear and Radiological 
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United States Government Accountability Office: 
GAO: 

Report to the Chairman, Committee on Homeland Security and 
Governmental Affairs, U.S. Senate: 

September 2013: 

Nuclear Terrorism Response Plans: 

Major Cities Could Benefit from Federal Guidance on Responding to 
Nuclear and Radiological Attacks: 

GAO-13-736: 

GAO Highlights: 

Highlights of GAO-13-736, a report to the Chairman, Committee on 
Homeland Security and Governmental Affairs, U.S. Senate. 

Why GAO Did This Study: 

A terrorist attack in a major city using an RDD or an IND could result 
not only in the loss of life but also have enormous psychological and 
economic impacts. Major cities are assumed to be preferred targets of 
such attacks, and local governments, along with their states, have 
primary responsibilities for early response (within the first 24 
hours), with assistance from federal sources, as necessary, coming 
later. A disjointed or untimely response could increase the impact and 
undermine public confidence in federal, state and local governments’ 
ability to respond to an attack. 

GAO was asked to review issues related to response preparedness for 
RDD and IND attacks. This report examines major cities’ (1) assessment 
of RDD and IND risks and development of response plans, (2) 
perceptions of their abilities to respond within the first 24 hours, 
and (3) perceptions of the need for federal support in early response 
to these attacks. GAO primarily relied on questionnaire responses from 
emergency managers of 27 of the 31 major cities that the Department of 
Homeland Security considers to be at high risk for terrorist attack, 
the review of pertinent federal guidance, and interviews with FEMA 
officials and others. 

What GAO Found: 

Many emergency managers from the 27 major cities responding to GAO’s 
questionnaire, although not all, reported that their city had assessed 
the risks of a terrorist attack using a radiological dispersal device 
(RDD) or improvised nuclear device (IND) and had ranked the risk of 
these attacks as lower than the risk of other hazards they face. Also, 
11 of the 27 reported that they had completed RDD response plans, and 
8 of the 27 reported that they had completed IND response plans. Some 
emergency managers for cities without specific RDD and IND response 
plans reported that they would rely on their city’s all hazards 
emergency operations plan or hazard management plan if attacked. Most 
cities that had RDD and IND response plans reported conducting 
exercises to validate the plans based on federal guidance. 

Major cities varied widely in perceptions of their abilities to 
respond within the first 24 hours of RDD and IND attacks (early 
response). For example, all 27 cities were perceived by their 
emergency managers as being able to conduct at least a few of the 
early response activities after an RDD attack, such as treating 
casualties, with assistance from other jurisdictions but not federal 
assistance. Ten of those cities were perceived as not being able to 
conduct any of the response activities for an IND attack without 
federal assistance. GAO analysis found that these perceptions were not 
necessarily related to a city having RDD and IND response plans but 
rather related to their understanding of nuclear and radiological 
incidents and the capabilities needed for response according to 
information obtained from Federal Emergency Management Agency (FEMA) 
officials. GAO found limited federal planning guidance related to the 
early response capabilities needed by cities for the large RDD attack 
depicted in the national planning scenarios. Federal guidance may not 
be needed, according to FEMA officials, because they expect cities to 
address a more likely but smaller RDD attack—-as they would a 
hazardous materials spill-—with limited federal assistance. More 
federal planning guidance applicable to cities has been developed for 
IND response, but this guidance does not detail the early response 
capabilities needed by cities in relation to other sources of 
assistance. Without greater awareness of and additional federal 
guidance on the capabilities needed by cities for early response to 
these attacks, cities may not have the information they need to 
adequately prepare for and respond to them. This could lead to 
complications that result in greater loss of life and economic impacts. 

Most emergency managers reported perceived needs for federal technical 
and resource assistance to support their cities’ early response to RDD 
(19 of 27 cities) and IND (21 of 27 cities) attacks. However, GAO 
found that federal guidance on the type and timing of such assistance 
is not readily available or understood by all emergency managers. This 
condition could lead to a disjointed and untimely response that might 
increase the consequences of either kind of attack. Emergency managers 
also reported a need for improved procedures and more information that 
FEMA is addressing. In addition, most emergency managers reported 
their city needed federal funding to maintain current capabilities to 
respond to RDD and IND attacks. According to DHS guidance, response 
capabilities are developed through planning, training, equipping, and 
exercising, which are essential elements of an integrated, capability-
based approach to preparedness. 

What GAO Recommends: 

GAO recommends that FEMA develop guidance to clarify the early 
response capabilities needed by cities for RDD and IND attacks. FEMA 
did not concur with this recommendation. GAO believes that gaps in 
early response abilities warrant federal attention and has clarified 
its recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-13-736]. For more 
information, contact David C. Trimble at (202) 512-3841 or 
trimbled@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Many Major Cities Assessed the Risk of RDD and IND Attacks as Lower 
Than Other Hazards They Face, and Few Had Developed Specific Response 
Plans: 

Major Cities Vary Widely in Perceptions of Their Abilities to Respond 
within 24 Hours of RDD and IND Attacks: 

Most Major Cities Expressed Need for Federal Support for Early 
Response to RDD and IND Attacks: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Questionnaire: 

Appendix III: Fiscal Year 2013 DHS Preparedness Grant Programs Funding 
Awarded: 

Appendix IV: Comments from the Department of Homeland Security: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Activities Associated with Each Core Capability for the 
Response Mission Area: 

Table 2: Radiological Dispersal Device (RDD) or Improvised Nuclear 
Device (IND) Attack Risk Assessment Approach for 27 Major Cities and 
the Percentage Ranking These Hazards as Lower Than Other Hazards They 
Face: 

Table 3: Number and Percentage of 27 Major Cities with Specific 
Radiological Dispersal Device (RDD) or Improvised Nuclear Device (IND) 
Response Plans 1: 

Table 4: Comparison of Characteristics of Radiological Dispersal 
Device (RDD) and Improvised Nuclear Device (IND) Attacks: 

Figures: 

Figure 1: Major Cities at High Risk for Terrorist Attack by FEMA 
Region: 

Figure 2: Conceptual Response Planning Framework for Radiological 
Dispersal Device (RDD) and Improvised Nuclear Device (IND) Attacks 
within the National Preparedness System: 

Figure 3: Amount of Perceived Early Response Ability of 27 Major 
Cities for Radiological Dispersal Device (RDD) and Improvised Nuclear 
Device (IND) Attacks: 

Figure 4: Anticipated Capability Requirements by Response Time: 

Figure 5: Anticipated Federal Technical and Resource Support for Core 
Capabilities Necessary for a Major City Early Response to an 
Improvised Nuclear Device (IND) Attack: 

Figure 6: Federal Radiological Dispersal Device (RDD) or Improvised 
Nuclear Device (IND) Response Topic Areas Identified by Major City 
Emergency Managers as Needed to Improve Early Response Capabilities: 

Abbreviations: 

DOD: Department of Defense: 

DOE: Department of Energy: 

DHS: Department of Homeland Security: 

FEMA: Federal Emergency Management Agency: 

FIOP: Federal Interagency Operational Plan: 

HHS: Department of Health and Human Services: 

IND: improvised nuclear device: 

NNSA: National Nuclear Security Administration: 

RDD: radiological dispersal device: 

UASI: Urban Areas Security Initiative: 

[End of section] 

September 30, 2013: 

The Honorable Thomas R. Carper: 
Chairman: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Dear Mr. Chairman: 

A terrorist attack in a major city using a weapon of mass destruction 
would result in not only the loss of life but also enormous 
psychological and economic impacts. Since the terrorist attacks of 
September 11, 2001, concerns have intensified over major cities' 
preparedness to respond to an attack using a radiological dispersal 
device (RDD)--a mechanism to deliberately release radioactive material 
in sufficient quantities to require protective actions--or an 
improvised nuclear device (IND)[Footnote 1]--a weapon fabricated using 
fissile material that produces a nuclear explosion.[Footnote 2] Urban 
centers of major cities are assumed to be preferred targets for a 
terrorist attack, and local governments, along with their states, 
would have primary responsibilities for early response--within the 
first 24 hours--until additional resources, if needed, arrive from the 
federal government.[Footnote 3] To prepare to respond early to an RDD 
or IND attack, cities will need to understand the risks and plan to 
respond if an attack occurs. According to a 2012 National Science and 
Technology Council report,[Footnote 4] the ability to prepare for such 
an attack and act decisively and appropriately in the first minutes 
and hours after an attack will require reliable information, 
capabilities, and tools to assist in planning and to effectively 
mitigate consequences. A disjointed or untimely response could put 
many additional lives at risk, increase economic consequences, and 
undermine the public's confidence in the federal, state, and local 
governments' ability to respond to such a crisis. 

In March 2011, the President directed the Secretary of Homeland 
Security, Department of Homeland Security (DHS), to develop a national 
preparedness goal and design a national preparedness system to address 
the threats posing the greatest risk to the security of the nation, 
and to issue an annual national preparedness report.[Footnote 5] The 
national preparedness goal defines the core capabilities necessary to 
prepare for specific types of incidents, including acts of terrorism, 
cyber attacks, pandemics, and catastrophic natural disasters.[Footnote 
6] In September 2011, DHS published the National Preparedness Goal, 
[Footnote 7] which stated that all levels of government and the whole 
community should present and assess risks in a similar manner to 
provide a common understanding of the threats and hazards confronting 
the country. Consistent with the National Preparedness Goal, the 
information gathered during a risk assessment will also enable a 
prioritization of preparedness efforts and provide an opportunity to 
identify capability requirements across all levels of government and 
the private sector. In this context, an RDD or IND attack would pose 
both a threat prior to the incident and a hazard after detonation. 

As directed by the President, the national preparedness system is 
intended to guide activities to achieve the national preparedness 
goal. Specifically, it is to provide guidance on the planning, 
organization, equipment, training, and exercises needed to develop and 
maintain domestic capabilities. The national preparedness system is to 
include a series of integrated national planning frameworks for five 
mission areas--prevention, protection, mitigation, response, and 
recovery--built on basic plans that support an all hazards approach to 
preparedness. The all hazards approach allows emergency planners at 
all government levels to address common operational functions in their 
basic plans instead of having unique plans for every type of hazard. 
Each national planning framework is directed to include guidance to 
support corresponding planning at other governmental levels, including 
cities. The directive called for the national preparedness system to 
include development of a Federal Interagency Operational Plan (FIOP) 
to support each of the five mission area planning frameworks, such as 
the one for the response mission area.[Footnote 8] In November 2011, 
DHS published the National Preparedness System and has been working to 
implement this system.[Footnote 9] 

The directive also recognizes that the national planning frameworks 
could include supplements, called annexes, describing additional 
planning guidance for particular hazard scenarios. DHS has previously 
prepared guidance in 2006 on planning assumptions for major attacks 
and natural disasters, including RDD and IND attacks, as a reference 
to help planners at all levels of government identify the potential 
scope, magnitude, and complexity of these events.[Footnote 10] DHS 
stated in this guidance that this was done to establish a range of 
response capabilities to facilitate preparedness planning and 
exercising these plans. The 2008 National Response Framework, under 
revision, already includes a nuclear and radiological incident annex. 
According to Federal Emergency Management Agency (FEMA) officials, the 
FIOPs will likely include operational details for most, if not all of 
the national planning framework annexes. 

The President also directed that the national preparedness system be 
consistent with the previously developed National Incident Management 
System, which provides a systematic and coordinated all hazards 
approach to incident management across all levels of 
government.[Footnote 11] The National Incident Management System sets 
forth a comprehensive national approach that recognizes that incidents 
typically begin and end locally and are managed on a daily basis at 
the lowest jurisdictional level. However, there are incidents in which 
successful management of operations will need the involvement of 
multiple jurisdictions, levels of government, functional agencies, and 
emergency responder disciplines. Effective response to an RDD or IND 
attack would require marshaling all available federal, state, and 
local resources to save lives and limit economic damage. 

DHS has lead federal coordinating responsibility for attacks involving 
nuclear or radiological materials, including RDDs and INDs. FEMA, 
within DHS, has responsibility to reduce the loss of life and 
property, and protect the nation from all hazards, including 
terrorism. FEMA has a leadership role to coordinate the overall 
federal response to these attacks in close coordination with many 
other federal agencies and departments.[Footnote 12] Among other 
agencies, these include the Department of Energy (DOE), Department of 
Defense (DOD), and the Department of Health and Human Services (HHS). 
Within DOE, the semiautonomous National Nuclear Security 
Administration (NNSA) would lead the early federal interagency 
response to characterize the nature and dispersal of radioactive 
material in the event of an RDD or IND attack. DOD may provide support 
in response to requests for assistance from DHS, other federal 
agencies, as well as state and local governments.[Footnote 13] HHS 
would lead all federal public health and medical response to 
supplement state and local resources during a public health and 
medical disaster. In addition, the National Guard can provide 
governors with a wide array of response capabilities in 
detection/identification, search and rescue, patient decontamination, 
and medical care to relieve or augment first responders. 

Since major cities are presumed to be preferred targets for terrorist 
attacks, you asked us to examine their concerns about RDD and IND 
attacks and how they perceive their ability to respond to them before 
federal assistance arrives. This report examines major cities' (1) 
assessment of the risks of RDD and IND attacks and the extent to which 
they have developed plans for responding to them, (2) perceptions of 
their abilities to respond to RDD and IND attacks in the first 24 
hours (early response), and (3) perceptions of their need for federal 
support in the early response to RDD and IND attacks. 

To conduct this work, we developed a questionnaire for the directors 
of emergency management of 31 major cities that DHS considers at 
highest risk for a terrorist act in fiscal year 2012. We were able to 
contact an emergency manager to receive the questionnaire in 29 of the 
31 cities.[Footnote 14] We selected city emergency managers to receive 
the questionnaire because they are in the best position to provide a 
city-wide perspective on the level of preparedness to respond to RDD 
and IND attacks. Emergency managers from 27 of the 29 major cities 
that received our questionnaire responded for a response rate of 87 
percent. This questionnaire asked city emergency managers to report on 
(1) how their city assessed the risk of RDD and IND attacks, and the 
availability of local response plans for these attacks; (2) their 
perceptions of their city's ability to respond within the first 24 
hours (early response); and (3) their perceptions of the need for 
federal support to prepare for and respond to these attacks. In 
addition, we reviewed federal guidance documents and other relevant 
reports. We also interviewed emergency managers or first responders in 
seven major cities selected for their geographic location and 
population size, and visited with emergency management planners who 
participated in an interagency IND response planning effort in 
Chicago. We also interviewed FEMA and NNSA emergency management 
planners, DOE national laboratory officials, and subject matter 
experts. We conducted these interviews to obtain information on the 
availability of federal technical and response assistance, initiatives 
to improve information and procedures, and the availability of federal 
funding to support preparedness efforts by major cities. Appendix I 
provides a more detailed description of our objectives, scope, and 
methodology. A copy of our questionnaire is found in appendix II. 

We conducted this performance audit from June 2012 to September 2013 
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. 

Background: 

This section provides information on the characteristics of RDD and 
IND attacks, major cities considered at high risk of terrorist act, 
core capabilities for all hazards preparedness, and response planning 
and associated federal guidance in the national preparedness system. 

Characteristics of RDD and IND Attacks: 

A radiological attack is defined as an event or series of events 
leading to the deliberate release, or potential release into the 
environment, of radioactive materials in sufficient quantity to 
require consideration of protective actions. Such an act would 
probably be executed with no advance warning. The typical means of 
dispersing radioactive material in an RDD is through a conventional 
explosion. There is a wide range of possible consequences from an RDD 
incident depending on the type and size of the device and the extent 
of dispersal. According to FEMA officials, the most likely RDD attack 
would impact a small area and not result in acutely harmful radiation 
doses to exposed individuals but could result in latent effects 
increasing the risk of cancer to exposed individuals. In contrast, an 
IND attack would produce a nuclear explosion from fissile material, 
which releases extreme heat and powerful shock waves, and disperses 
radiation that would be lethal for a significant distance. It also 
produces radioactive fallout, which would deposit radioactive material 
over a large area. If the fission of the radioactive material is not 
achieved, the effects of the explosion may resemble the impacts of an 
RDD. A 2011 Congressional Research Service report states that the use 
of an RDD is more likely than an IND because the radioactive material 
to construct an RDD is more accessible, and it would be more difficult 
for a terrorist to make an IND.[Footnote 15] In both cases, early 
response within the first hours includes initial actions to protect 
public health and welfare. 

Major Cities Considered at High Risk of Terrorist Attack: 

In 2003, DHS established an Urban Areas Security Initiative program to 
allocate homeland security grants to enhance and sustain the capacity 
to prevent, protect against, mitigate, respond to, and recover from 
acts of terrorism in high density urban areas, particularly the urban 
centers. The program identifies these high density urban areas by 
their major city. For example, the Chicago area includes 3 states, 14 
counties, and 10 principal cities. Figure 1 shows the 31 major cities 
in the Urban Areas Security Initiative program in fiscal year 2012 
within the 10 FEMA regions. 

Figure 1: Major Cities at High Risk for Terrorist Attack by FEMA 
Region: 

[Refer to PDF for image: illustrated U.S. map] 

Region 1: 
Boston. 

Region 2: 
Newark; 
New York. 

Region 3: Baltimore; 
Philadelphia; 
Washington, D.C. 

Region 4: 
Atlanta; 
Charlotte; 
Miami; 
Orlando. 

Region 5: 
Chicago; 
Detroit; 
Indianapolis; 
Minneapolis. 

Region 6: 
Dallas; 
Houston; 
New Orleans; 
San Antonio. 

Region 7: 
Kansas City; 
St. Louis. 

Region 8: 
Denver. 

Region 9: 
Anaheim; 
Las Vegas; 
Los Angeles; 
Phoenix; 
Riverside; 
San Diego; 
San Francisco. 

Region 10: 
Portland; 
Seattle. 

Sources: Copyright © Corel Corp. All rights reserved (map); GAO. 

[End of figure] 

Core Capabilities for All Hazards Preparedness: 

In the National Preparedness Goal, DHS identified core capabilities 
needed for each of the five national preparedness mission areas. These 
core capabilities are considered necessary for an all hazards, 
capability-based approach to preparedness planning across all levels 
of government, although each level of government does not have to 
possess all capabilities. The five mission areas have in common three 
core capabilities--planning, public information and warning, and 
operational coordination--in addition to other capabilities specific 
to each mission area. For the response mission area, there are 11 
additional core capabilities, for a total of 14. In compiling the list 
of core response capabilities, DHS based them on those capabilities 
that would be needed to respond to a large earthquake, major 
hurricane, and a weapon of mass destruction attack. Table 1 describes 
the activities for each of the 14 core capabilities in the response 
mission area that DHS considers necessary to save lives, protect 
property, and meet basic human needs after a catastrophic incident, 
such as an RDD or IND attack. 

Table 1: Activities Associated with Each Core Capability for the 
Response Mission Area: 

Core capability: Planning; 
Activities: Conduct a systematic process engaging the whole community, 
as appropriate, in the development of executable strategic, 
operational, and/or community-based approaches to meet defined 
objectives. 

Core capability: Public Information and Warning; 
Activities: Deliver coordinated, prompt, reliable, and actionable 
information to the whole community through the use of clear, 
consistent, accessible, and culturally and linguistically appropriate 
methods to effectively relay information regarding any threat or 
hazard and, as appropriate, the actions being taken and the assistance 
being made available. 

Core capability: Operational Coordination; 
Activities: Establish and maintain a unified and coordinated 
operational structure and process that appropriately integrates all 
critical stakeholders and supports the execution of core capabilities. 

Core capability: Critical Transportation; 
Activities: Provide transportation (including infrastructure access 
and accessible transportation services) for response priority 
objectives, including the evacuation of people and animals, and the 
delivery of vital response personnel, equipment, and services into the 
affected areas. 

Core capability: Environmental Response/Health and Safety; 
Activities: Ensure the availability of guidance and resources to 
address all hazards including hazardous materials, acts of terrorism, 
and natural disasters in support of the responder operations and the 
affected communities. 

Core capability: Fatality Management Services; 
Activities: Provide fatality management services, including body 
recovery and victim identification, working with state and local 
authorities to provide temporary mortuary solutions, sharing 
information with mass care services for the purpose of reunifying 
family members and caregivers with missing persons/remains, and 
providing counseling to the bereaved. 

Core capability: Infrastructure Systems; 
Activities: Stabilize critical infrastructure functions, minimize 
health and safety threats, and efficiently restore and revitalize 
systems and services to support a viable, resilient community. 

Core capability: Mass Care Services; 
Activities: Provide life-sustaining services to the affected 
population with a focus on hydration, feeding, and sheltering to those 
who have the most need, as well as support for reunifying families. 

Core capability: Mass Search and Rescue Operations; 
Activities: Deliver traditional and atypical search and rescue 
capabilities, including personnel, services, animals, and assets to 
survivors in need, with the goal of saving the greatest number of 
endangered lives in the shortest time possible. 

Core capability: On-scene Security and Protection; 
Activities: Ensure a safe and secure environment through law 
enforcement and related security and protection operations for people 
and communities located within affected areas and also for all 
traditional and atypical response personnel engaged in lifesaving and 
life-sustaining operations. 

Core capability: Operational Communications; 
Activities: Ensure the capacity for timely communications in support 
of security, situational awareness, and operations by any and all 
means available, among and between affected communities in the impact 
area and all response forces. 

Core capability: Public and Private Services and Resources; 
Activities: Provide essential public and private services and 
resources to the affected population and surrounding communities, to 
include emergency power to critical facilities, fuel support for 
emergency responders, and access to community staples (e.g., grocery 
stores, pharmacies, and banks) and fire and other first response 
services. 

Core capability: Public Health and Medical Services; 
Activities: Provide lifesaving medical treatment via emergency medical 
services and related operations and avoid additional disease and 
injury by providing targeted public health and medical support and 
products to all people in need within the affected area. 

Core capability: Situational Assessment; 
Activities: Provide all decision makers with decision-relevant 
information regarding the nature and extent of the hazard, any 
cascading effects, and the status of the response. 

Source: DHS, National Preparedness Goal, September 2011. 

[End of table] 

Response Planning and Associated Federal Guidance: 

Under the national preparedness system, FEMA has issued guidance to 
help planners at all levels of government develop and maintain viable, 
all hazards emergency operations plans. This guidance describes how to 
develop and maintain emergency operations plans and how to implement 
these plans.[Footnote 16] While the basic emergency operations plan is 
oriented around an all hazards approach, FEMA guidance states that 
special policies may be necessary to respond to catastrophic 
incidents, such as an RDD or IND attack. According to FEMA guidance, 
local governments have the discretion to address these attacks in 
specific plans that are annexed to a city's emergency operations plan, 
and the inclusion of these annexes will vary based on a jurisdiction's 
assessment of the risks it faces. DHS guidance establishing the 
national preparedness system recognizes that since local governments 
will focus their planning efforts on the more likely risks, federal 
planning must complement these planning efforts for low-probability, 
high-consequence risks, such as a terrorist attack using an RDD or 
IND.[Footnote 17] DHS issued preliminary guidance for RDD and IND 
response planning to federal, state, and local governments in 2008, 
through a Federal Register announcement, that was followed in 2010 
with additional federal guidance on responding to an IND attack. 
[Footnote 18] Some professional organizations have also published 
guidance covering measures that state and local government should 
consider in responding to RDD and IND attacks.[Footnote 19] Figure 2 
illustrates the conceptual response planning framework, including 
possible nuclear or radiological attack annexes as supplements to all 
hazards operational or emergency operations plans supporting national 
preparedness. 

Figure 2: Conceptual Response Planning Framework for Radiological 
Dispersal Device (RDD) and Improvised Nuclear Device (IND) Attacks 
within the National Preparedness System: 

[Refer to PDF for image: framework illustration] 

Direct relationship between jurisdictional levels unless otherwise 
indicated: 

Jurisdictional levels have the discretion to include a nuclear and 
radiological annex to their operational or operations plan. 

Top level: 
Presidential Policy Directive (PPD) 8 (2011). 

Second level: 
Integrated National Planning Frameworks (by mission area): 
Prevention; 
Protection; 
Mitigation; 
Response[A]; 
Recovery. 

Framework under Response: 
Federal Interagency Operational Plan (FIOP) - Response (All Hazards): 
Collaborative planning effort with: 
FEMA Regional Operational Plan - Response (All Hazards)[C]; 
Collaborative planning effort with: 
State Emergency Operations Plan (All Hazards)[E]; 
Collaborative planning effort with: 
Local Emergency Operations Plan (All Hazards)[E]. 

Nuclear and Radiological Annex[B]: Jurisdictional discretion with: 
Federal Interagency Operational Plan (FIOP) - Response (All Hazards); 
Collaborative planning effort with: 

Nuclear and Radiological Annex[D]: Jurisdictional discretion with: 
FEMA Regional Operational Plan - Response (All Hazards); 
Collaborative planning effort with: 

Nuclear and Radiological Annex[D]: Jurisdictional discretion with: 
State Emergency Operations Plan (All Hazards); 
Collaborative planning effort with: 

Nuclear and Radiological Annex[F]: Jurisdictional discretion with: 
Local Emergency Operations Plan (All Hazards). 

Source: GAO. 

Note: An alternative to supplementing an all hazards plan with a 
nuclear and radiological annex to account for changes in objectives 
and tasks might be to amend the all hazards plan itself. 

[A] DHS issued its first National Response Framework in 2008 that 
included emergency support functions, incident annexes, and the 
partner guides. A new response framework is under development. 

[B] FEMA is considering the need to revise the existing nuclear and 
radiological incident annex to the National Response Framework as an 
annex to a forthcoming FIOPs for the response and recovery mission 
areas. 

[C] This plan is based on FEMA's Regional Planning Guide, which 
outlines the means to implement the planning process consistent with 
FEMA's Comprehensive Preparedness Guide (CPG) 101. 

[D] State governments have the option to develop specific plans that 
are annexed to their emergency operations plans based on their 
assessment of the hazard risk, such as a nuclear and radiological 
annex. As of 2012, all regional offices, states, and Urban Areas 
Security Initiative locations must use the Threat and Hazard 
Identification and Risk Assessment process. 

[E] This plan is based on FEMA's Comprehensive Preparedness Guide 
(CPG) 101. 

[F] Local governments have the option to develop specific plans that 
are annexed to their emergency operations plans based on their 
assessment of the hazard risk, such as a nuclear and radiological 
annex. Local governments often use the Hazard Identification and 
Vulnerability Assessment process to develop their Hazard Mitigation 
Plans. 

[End of figure] 

Many Major Cities Assessed the Risk of RDD and IND Attacks as Lower 
Than Other Hazards They Face, and Few Had Developed Specific Response 
Plans: 

Many major city emergency managers, although not all, responded to our 
questionnaire that their city had assessed the risks of RDD and IND 
attacks and had ranked the risk of these attacks as lower than the 
risk of other hazards their city faces. The results of our 
questionnaire also show that fewer than half of the major cities that 
responded had developed specific RDD and IND response plans. Most of 
the major cities that reported having RDD and IND response plans also 
reported having conducted exercises to validate those plans. 

Many of the Major Cities Assessed the Risk of RDD and IND Attacks as 
Lower Than Other Hazards: 

Emergency managers of many of the major cities responding to our 
questionnaire reported that their city assessed the risk of RDD and 
IND attacks and ranked those risks as lower than other hazards their 
city faces. We asked emergency managers to refer to their city's most 
recently completed Hazard Identification and Vulnerability Assessment, 
[Footnote 20] and report whether they assessed the risk of RDD or IND 
attacks and, if so, where those risks ranked relative to the other 
hazards assessed by their city, such as hurricanes, tornadoes, and 
flooding. All 27 cities responded to our question regarding their 
assessment of the risks of RDD and IND attacks. Three major cities 
reported that they had not completed a Hazard Identification and 
Vulnerability Assessment, or a similar assessment, and 6 cities 
reported that while they did have a recent assessment, they did not 
include either RDD or IND attacks in this assessment. Of the remaining 
18 cities, 7 combined RDD and IND attacks into a single risk in their 
assessments, 9 assessed the risk of RDD and IND attacks separately, 
and 2 assessed the risk of an RDD attack but did not assess the risk 
of an IND attack. Of the 11 cities that assessed the risk of an RDD 
attack separately, 7 ranked the risk as lower than most or all other 
hazards their city faces. Of the 9 cities that separately assessed the 
risk of an IND attack, 7 ranked the risk as lower than most or all 
other hazards their city faces. In general, most cities that conducted 
a separate risk assessment for both RDD and IND reported that the risk 
of an RDD attack was higher than the risk of an IND attack. Table 2 
shows the approach taken by the major cities responding to our 
questionnaire for assessing the risks of RDD and IND attacks, as well 
as the percentage of cities for each approach that ranked these risks 
lower than most or all other hazards they face. 

Table 2: Radiological Dispersal Device (RDD) or Improvised Nuclear 
Device (IND) Attack Risk Assessment Approach for 27 Major Cities and 
the Percentage Ranking These Hazards as Lower Than Other Hazards They 
Face: 

Type of hazard assessed: RDD attack separately; 
Cities assessing the hazard as lower than most or all other hazards 
they face: 
Number: 7 of 11 cities that reported doing an assessment of an RDD 
attack[A]; 
Percentage: 64%. 

Type of hazard assessed: IND attack separately; 
Cities assessing the hazard as lower than most or all other hazards 
they face: 
Number: 7 of 9 cities that reported doing an assessment of an IND 
attack; 
Percentage: 78%. 

Type of hazard assessed: RDD/IND attacks combined; 
Cities assessing the hazard as lower than most or all other hazards 
they face: 
Number: 5 of 7 cities that reported doing an assessment of RDD/IND 
attacks combined; 
Percentage: 71%. 

Source: GAO questionnaire results. 

[A] One of the 11 cities that separately assessed the risk of an RDD 
attack incorrectly skipped the question of where the risk of RDD 
attacks ranked relative to all other hazards their city faces. 

[End of table] 

Fewer Than Half of Major Cities Have Specific Response Plans for RDD 
and IND Attacks: 

According to the responses to our questionnaire, fewer than half of 
the major cities have response plans[Footnote 21] that specifically 
address RDD and IND attacks, although some emergency managers 
indicated that their city had these plans in development. Of the 27 
major cities that responded to our questionnaire, 11 (41 percent) of 
the emergency managers reported that their city had completed RDD 
response plans, and 8 (30 percent) had completed IND response plans. 
Some emergency managers for cities that did not have specific RDD and 
IND response plans reported that they would rely on other plans in the 
event of such an attack, including their city's emergency operations 
plan or hazard management plan. Table 3 identifies the extent to which 
major cities have hazard-specific RDD or IND response plans. 

Table 3: Number and Percentage of 27 Major Cities with Specific 
Radiological Dispersal Device (RDD) or Improvised Nuclear Device (IND) 
Response Plans: 

Type of hazard: RDD; 
Hazard-specific plans completed: 11 (41%); 
Hazard-specific plans in development: 6 (22%); 
No hazard-specific plans completed or in development: 10 (37%); 
Planning for this hazard is not-applicable: 0 (0%). 

Type of hazard: IND; 
Hazard-specific plans completed: 8 (30%); 
Hazard-specific plans in development: 8 (30%); 
No hazard-specific plans completed or in development: 10 (37%); 
Planning for this hazard is not-applicable: 1 (3%). 

Source: GAO questionnaire results. 

Note: All 27 cities that responded to the questionnaire provided 
information on whether they had specific plans for RDD or IND attacks. 

[End of table] 

The questionnaire results regarding the number of cities with specific 
response plans for RDD and IND attacks are generally consistent with 
prior analyses conducted by FEMA. In 2010, FEMA conducted a national 
review of the contents of state and urban area emergency operations 
plans.[Footnote 22] FEMA found that more than 80 percent of urban 
areas reported that their emergency operations plans were well-suited 
to meet the challenges presented during large-scale or catastrophic 
incidents; however, fewer than half expressed confidence that specific 
RDD and IND response plans annexed to their emergency operations plans 
were adequate to manage such attacks. Forty percent of the urban areas 
had confidence in their RDD response plans, with 10 percent providing 
no response. Thirty percent said they had confidence in their IND 
response plans, with 20 percent providing no response. 

Most Major Cities That Have Specific RDD and IND Response Plans Have 
Also Exercised These Plans: 

Most emergency managers responding to our questionnaire who reported 
having specific RDD or IND response plans also reported having 
conducted exercises to validate those plans based on federal guidance. 
According to FEMA, a response plan should not be considered complete 
until exercises are conducted to validate it. Of the 11 cities that 
have specific RDD response plans, 9 of their emergency managers 
reported that their city had participated in RDD exercises from 2010 
to 2012. Of the 8 cities that have specific IND response plans, 5 of 
their emergency managers reported that their city had participated in 
IND exercises over this same time period. These results are comparable 
to FEMA's 2010 national review of emergency operations plans that 
found that plans were frequently exercised. Specifically, 95 percent 
of all states and urban areas (including the major cities in our 
questionnaire) had conducted exercises using their basic plans, an 
increase from the previous review in 2006, and the response planning 
annexes subject to the most exercises included those involving the 
response to the release of hazardous materials, which can include the 
dispersal of radioactivity from RDD and IND attacks. 

Major Cities Vary Widely in Perceptions of Their Abilities to Respond 
within 24 Hours of RDD and IND Attacks: 

Major city emergency managers responding to our questionnaire varied 
widely in their perception of their cities' abilities to respond 
within the first 24 hours (early response) to an RDD or IND attack. 
Limited DHS guidance exists that is applicable to major cities on the 
capabilities needed for early response to an RDD attack, but more such 
guidance exists for the early response to an IND attack. According to 
FEMA officials, the agency is considering developing additional 
guidance on nuclear and radiological incidents to be annexed to the 
forthcoming FIOPs for the response and recovery mission areas that may 
help guide the preparation of specific response plans to supplement 
the all hazards emergency operations plans of cities interested in 
doing so. 

Major Cities Vary Widely in Perceptions of Their Ability to Respond 
within 24 Hours of RDD and IND Attacks, but Perceive More Ability to 
Respond to an RDD Attack: 

Our analysis of the questionnaire responses from major city emergency 
managers showed a wide variation in their perceptions regarding their 
cities' abilities to respond within the first 24 hours to the RDD or 
IND attack depicted in the National Planning Scenarios, but most 
perceived that their city has more ability to conduct the early 
response for an RDD attack than for an IND attack. To gather this 
information, we obtained the emergency managers' self-assessments of 
their cities' abilities for early response to the national planning 
scenarios for RDD and IND attacks, but we did not ask them to assess 
their level of ability for each of the 14 federal core response 
capabilities.[Footnote 23] We also asked them to consider mutual aid 
from other jurisdictions in estimating their early response abilities, 
but not to consider assistance from federal sources. Our analysis of 
emergency manager responses showed a wide variation in perceived early 
response abilities across the major cities. For example, 7 of 27 
cities were perceived by their emergency managers as being able to 
conduct all of the activities needed for early response to an RDD 
attack without federal assistance--such as treating casualties--while 
2 cities were perceived as being able to conduct all of the activities 
needed for an IND attack, without federal assistance. Moreover, all 
cities were perceived by their emergency managers as being able to 
conduct at least a few early response activities for an RDD attack, 
while 10 cities were perceived as not being able to conduct any early 
response activities for an IND attack. Overall, our analysis concluded 
that more emergency managers perceived that their city was able to 
conduct some, almost all, or all of the early response activities 
needed for an RDD attack (22 of 27 cities) compared with an IND attack 
(7 of 27 cities). Ten major cities reported not having any ability to 
conduct the early response after an IND attack, even considering 
assistance from the surrounding jurisdictions and their states, which 
would suggest a high expectation for federal assistance during early 
response. For RDD, emergency managers from 20 major cities reported 
perceiving that their city was not able to conduct all of the 
necessary early response activities, which may also suggest some 
expectation for federal assistance. Figure 3 shows the distribution of 
major cities among five categories of early response activities 
following an RDD or IND attack based on emergency manager perceptions 
of their city's early response abilities including mutual aid from 
other jurisdiction but not federal assistance. 

Figure 3: Amount of Perceived Early Response Ability of 27 Major 
Cities for Radiological Dispersal Device (RDD) and Improvised Nuclear 
Device (IND) Attacks: 

[Refer to PDF for image: 2 pie-charts] 

Radiological dispersal device: 
All: 7 cities; 
Almost all: 10 cities; 
Some: 5 cities: 
Few: 5 cities; 
None: 0 cities. 

Improvised nuclear device: 
All: 2 cities; 
Almost all: 2 cities; 
Some: 3 cities: 
Few: 10 cities; 
None: 10 cities. 

Source: GAO analysis of questionnaire data. 

Note: Early response in an RDD or IND attacks refers to the abilities 
of major cities to respond to such an attack within the first 24 
hours. The statements made by emergency managers of 27 cities 
regarding the response activities they would provide included mutual 
aid from their state, as well as surrounding jurisdictions, but not 
response assistance from the federal government. 

[End of figure] 

The wide variation among emergency manager perceptions of their 
cities' abilities to conduct the early response to RDD and IND attacks 
is not necessarily related to whether or not a city had specific 
response plans. Our analysis found that 10 of the 17 major cities 
perceived by their emergency managers as being able to conduct all or 
almost all the necessary response activities for an RDD attack did not 
have specific RDD response plans. For IND attacks, three of the four 
major city perceived by their emergency managers as able conduct all 
or almost all of the necessary response activities for an IND attack 
did not have specific IND response plans. Regarding the wide 
differences in emergency managers' perceptions of their cities' 
abilities to respond, FEMA officials told us that some cities will 
tend to overestimate the risks of an RDD attack due to their lack of 
understanding about dispersed radioactive material and underestimate 
their actual abilities to conduct responses across the federal core 
response capabilities. They told us that cities in states with nuclear 
power plants are likely to have a greater understanding of the 
possible effects of a radiological attack and thus might be able to 
assess the risks and their cities' abilities to respond better than 
other cities. These cities would have access to state technical and 
resource assistance developed and exercised to respond to a 
radiological dispersal incident at a nuclear power plant, which would 
have some characteristics of the dispersal of radioactive material by 
an RDD. Moreover, FEMA officials told us that cities closer to federal 
offices and facilities tend to have more interaction with FEMA and 
NNSA subject matter experts and are likely to have a greater 
understanding of the nature of an RDD attack. In regard to IND 
attacks, FEMA officials told us that they would expect that emergency 
managers would claim that such an attack would overwhelm their city 
response resources and that their city would need federal assistance 
across most federal core response capabilities. 

Limited Federal Guidance Available on Early Response Capabilities 
Needed by Major Cities for RDD Attacks, but More Available for IND 
Attacks: 

DHS has provided limited guidance on the early response capabilities 
needed by cities for a large RDD attack based on the planning 
assumptions contained in the National Planning Scenarios, but more 
such guidance exists for the IND attack substantially based on the 
planning assumptions contained in the National Planning Scenarios. DHS 
has identified the core capabilities needed to respond to any 
catastrophic incident but generally not the specific capabilities 
needed by cities for early response to these attacks.[Footnote 24] DHS 
guidance contained in an annex to the 2008 National Response 
Framework[Footnote 25] states that an RDD or IND attack directed at a 
major city can have consequences that overwhelm the capabilities of 
state and local governments and may also seriously challenge existing 
federal response capabilities. In regard to RDD response, this DHS 
guidance states that major cities should be able to respond to small 
radiological releases with only occasional federal assistance but does 
not address the large RDD attack depicted in the National Planning 
Scenarios. According to FEMA and NNSA officials, additional federal 
guidance may not be necessary because they expect major cities to have 
the abilities to respond to a more likely smaller scale RDD attack 
than the large RDD attack, as they would a hazardous materials spill. 
If needed, the federal response to a hazardous materials release is 
described in an emergency support function covering oil and hazardous 
materials releases that is annexed to the National Response Framework. 
[Footnote 26] DHS has also issued guidance on protective actions that 
should be taken at various phases of response, including early 
response to the dispersal of radioactive materials, such in an RDD 
attack.[Footnote 27] However, the only detailed planning assumptions 
in current federal guidance for an RDD attack are those in the 
National Planning Scenarios and this is for a large RDD attack. 
[Footnote 28] DHS has not provided guidance on the early response 
capabilities needed by major cities for such an attack. According to 
NNSA officials, cities are likely to reach out for federal support in 
the case of either a large or small-scale RDD attack due to the rarity 
of the event and the high profile of any radiological emergency. 

The federal government has issued more guidance pertaining to early 
response to an IND attack substantially based on the National Planning 
Scenario.[Footnote 29] In 2009, DHS issued an interim concept of 
operations plan for the federal response to the IND attack.[Footnote 
30] This federal operations plan states that the federal priority in 
the first 24 hours is to assist in saving lives and reducing 
casualties, while providing advice to those in the incident area to 
shelter in the nearest structure and listen for instructions from 
authorities. This federal operations plan also directs the states and 
local governments to delineate control zones, coordinate evacuations, 
make shelter-in-place decisions, issue protective action 
recommendations, initiate decontamination procedures, and use the 
National Guard to assist with environmental monitoring, but it 
provides limited information on the capabilities needed to complete 
these actions. In 2010, a federal interagency task force issued 
planning guidance to all levels of government that expanded on the 
2008 DHS planning guidance by addressing gaps in IND response, 
expanding the discussion of needed capabilities, and examining other 
IND scenarios beyond the one identified in the National Planning 
Scenario.[Footnote 31] This 2010 guidance presents general background 
information that builds a foundation for specific planning 
recommendations on response to an IND attack during the first 24 to 72 
hours prior to the arrival of significant federal resources. This 
guidance states that other recommendations would be forthcoming, such 
as for establishing critical communications among first responders. 
This guidance recognizes that response planning must be done on a city-
specific basis using city-specific impact assessments.[Footnote 32] 
However, this guidance also points out that response to an IND will 
largely be provided from neighboring jurisdictions, which would 
require advanced planning to establish mutual aid and response 
protocols. Notwithstanding the specific planning recommendations, the 
2010 planning guidance does not detail the early response capabilities 
needed by major cities to an IND attack in relation to other sources 
of assistance. Without greater awareness of and additional federal 
guidance on the capabilities needed by cities for early response to 
both RDD and IND attacks, cities may not have the information they 
need to adequately prepare for and respond to them. Any gaps in 
response capabilities could lead to complications that result in 
greater loss of life and economic impacts. Figure 4 provides a simple 
illustration of the capability requirements for increasing levels of 
incident effects, with an IND attack likely to be the highest level of 
incident effect.[Footnote 33] 

Figure 4: Anticipated Capability Requirements by Response Time: 

[Refer to PDF for image: illustrated matrix] 

Level of incident effect plotted against time: 

Depicts: 
Federal resources; 
State resources; 
Local resources; 
Capability requirements. 

Source: GAO. 

[End of figure] 

FEMA Is Considering Developing Additional Guidance for Response to RDD 
and IND Attacks That May Help Guide Development of Specific Response 
Plans by Major Cities: 

FEMA is considering the need to develop a nuclear and radiological 
annex, as depicted in figure 2, to help guide federal response 
activities and possibly assist in the development of specific response 
plans for RDD and IND attacks as supplements to city emergency 
operations plans. This federal nuclear and radiological annex would be 
attached to the forthcoming FIOPs--currently under review for approval-
-for the all hazards planning framework for the response and recovery 
mission areas. FEMA officials told us that a nuclear and radiological 
annex may be needed to supplement these FIOPs because their all 
hazards orientation would not address several unique requirements and 
concepts of operations specifically tailored to the needs for nuclear 
and radiological incidents. The need for such an annex is also 
supported by a 2012 DHS report that found the response and recovery 
needs after a radiological attack differ from traditional all hazards 
incidents due to the need for decontamination activities, heightened 
public anxiety, long-term risk management, and substantial disruption 
to citizen's lives and the economy.[Footnote 34] FEMA officials said 
that if they decide to develop a nuclear and radiological annex it 
could help guide adjustments to FEMA regional operational plans. They 
also told us that these adjustments to the regional operational plans 
may help encourage major cities in FEMA regions to develop annexes to 
their all hazards emergency operations plans covering specific RDD and 
IND response plans. 

FEMA has not determined what it might include in the nuclear and 
radiological annex or how to address RDD and IND response planning. 
FEMA officials told us that this annex is expected to address RDD and 
IND attacks, as well as a broader spectrum of radiological dispersal 
incidents, such as nuclear power plant accidents. According to FEMA 
guidance, separate hazards can be grouped under a more general 
category, such as terrorist acts, but FEMA recognizes that problems 
can arise that will affect subsequent analysis when grouping hazards 
with a wide range of consequences under a single category, such as 
might be the case with RDD and IND attacks.[Footnote 35] FEMA 
officials provided information to compare the characteristics of RDD 
and IND attacks, as shown in table 4. One of the characteristics is 
the magnitude of the RDD and IND attacks. FEMA officials told us that 
if they decided to develop the nuclear and radiological annex, they 
would also consider the need to clarify the planning assumptions for 
these incidents, particularly the RDD attack scenario. 

Table 4: Comparison of Characteristics of Radiological Dispersal 
Device (RDD) and Improvised Nuclear Device (IND) Attacks: 

Category: Magnitude; 
RDD characteristics: Small scale destruction with wide range of 
possible magnitudes across city blocks with few deaths; 
IND characteristics: Large-scale destruction affecting the entire 
metropolitan area with thousands of deaths. 

Category: Time sensitivity; 
RDD characteristics: Right early decisions can reduce social and 
economic impacts; 
IND characteristics: Right early decisions can save lives. 

Category: Radioactive exposure risk; 
RDD characteristics: Limited number of people exposed to higher doses 
of radiation in various ways depending on the radioactive material; 
IND characteristics: Large number of people having acute exposure in 
blast zone with widespread exposure to significant and/or lethal 
levels of radiation primarily downwind from fallout through gross 
exposure. 

Category: Immediate health effects; 
RDD characteristics: Possible latent effects from radiation exposure; 
IND characteristics: Immediate acute and latent effects from radiation 
exposure. 

Category: Protective Actions; 
RDD characteristics: Avoid surfaces that have been contaminated; 
IND characteristics: Shelter in buildings that have higher protection 
from radiation exposure. 

Source: GAO from FEMA information. 

[End of table] 

An additional FEMA consideration in developing the nuclear and 
radiological annex to the FIOPs is the information recently gained 
from the agency's participation in a multigovernmental initiative to 
develop an IND regional operations plan for Chicago, which is intended 
to guide development of other regionally based IND operations plans. 
[Footnote 36] For example, FEMA found that the development of this IND 
regional operations plan provided information on needed early response 
capabilities, coordination of stakeholder groups, the type and timing 
of federal assistance, and the level of effort to complete the plan. 
The IND planning team determined that the most feasible course of 
action to save the greatest number of lives during early response 
involved concentrating on a limited number of activities around public 
information and warning, operational coordination and communications, 
on-scene security and protection, situational assessment, and shelter-
in-place and evacuation. These activities are covered by 7 of the 14 
federal core response capabilities in the national preparedness goal. 
In addition, IND planning team members told us that the planning 
effort gave them a greater appreciation of the communication and 
coordination activities needed across stakeholder groups to respond to 
an IND attack. The planning effort involved more than 300 local, 
state, and federal emergency management offices and private entities. 
Moreover, the IND planning team was able to develop a detailed 
spreadsheet containing the type and timing of assistance that might be 
available and needed--at the three response phases--for an IND attack 
on Chicago. The development of the plan has taken time and substantial 
funding. The IND planning process has been under way since 2010, 
costing about $7.6 million, as of 2012, when the plan was completed. 
This cost includes the project work of the city, the state of 
Illinois, neighboring states, and federal agencies that contributed to 
the development of the overall plan. 

As a result of the IND planning effort in Chicago, FEMA officials told 
us that they plan to use the information gained to assist other major 
cities seeking to develop similar operations plans with regional 
partners. FEMA officials told us that they also plan to undertake this 
planning initiative in Boston, the District of Columbia, and Houston 
during fiscal year 2013, with planning initiatives in Los Angeles, New 
York and Philadelphia to follow. In addition, FEMA officials told us 
that they plan to look for geographic and infrastructure similarities, 
such as common building structures and transportation systems in each 
region in order to expedite the planning process and reduce planning 
costs for other cities in a region. FEMA's Response Planning Division 
has allocated about $3.8 million for IND planning activities for 
fiscal year 2013. FEMA officials also told us that they thought that 
an IND response plan would be sufficient to address most of the 
response needs after an RDD attack as well. 

Most Major Cities Expressed Need for Federal Support for Early 
Response to RDD and IND Attacks: 

Emergency managers of major cities responding to our questionnaire 
reported varying levels of need for federal support in early response 
to RDD and IND attacks in the form of technical and resource 
assistance, procedures and information for early response activities, 
and preparedness funding. Emergency managers identified a number of 
areas for federal technical and resource assistance, but we found 
limitations in the federal guidance applicable to major cities on the 
type and timing of this assistance. Emergency managers of major cities 
also reported the need for federal government research that could 
improve procedures and information for their early response to RDD and 
IND attacks. DHS has supported working groups of subject matter 
experts to help mitigate shortcomings in response capabilities for IND 
attacks, which may have applications for improving RDD response 
capabilities. In addition, emergency managers reported that a decrease 
in federal funding would affect their abilities to conduct early 
response to RDD and IND attacks. 

Major Cities Reported Need for Guidance on the Type and Timing of 
Federal Technical and Resource Assistance for Early Response to RDD 
and IND Attacks: 

Most emergency managers from major cities responding to our 
questionnaire reported that they need federal technical and resource 
assistance to support their early response to RDD and IND attacks, but 
federal guidance on the type and timing of this assistance is not 
found in a single document and may not be well understood by emergency 
managers. Nineteen of 27 emergency managers perceive a need for 
federal technical and resource assistance for early response to an RDD 
attack, and 21 of them perceive a need for this assistance in early 
response to an IND attack. Our analysis of questionnaire responses 
determined that of the 14 core response capabilities, emergency 
managers indicated that the capability most needing federal technical 
and resource assistance for both RDD and IND attacks (11 of 27 cities 
each) was situational assessment. Situational assessment provides 
decision makers with technical information such as the nature and 
extent of the hazard, its cascading effects, and the status of the 
response. For RDD attacks, after situational assessment, the emergency 
managers' next most frequently cited federal assistance needs were the 
following: 

* public health and medical services (8 of 27 cities), 

* operational coordination (5 of 27 cities), and: 

* on-scene security and protection (5 of 27 cities).[Footnote 37] 

For IND attacks, after situational assessment, the emergency managers' 
next most frequently cited federal assistance needs were as follows: 

* on-scene security and protection (5 of 27 cities), and: 

* public health and medical services (5 of 27 cities). 

We also obtained several responses from emergency managers regarding 
actions, such as planning, that the federal government should take to 
help sustain and improve early response capabilities. For example, one 
emergency manager commented that integrated RDD and IND plans of 
local, state, and federal government roles and responsibilities are 
nonexistent. Another emergency manager stated that the federal 
government should provide a model RDD and IND response plan and 
templates to assist local jurisdictions' efforts. 

The type and timing of federal assistance to major cities during the 
early response to an RDD or IND attack may not be well understood by 
all major city emergency managers, even though some guidance is 
available but in different documents. For example, in 2008, DHS issued 
guidance on federal agency responsibilities for responding to 
incidents involving the release of nuclear, radiological, and 
hazardous materials in the National Response Framework, and introduced 
the concept of phases of response in planning guidance for RDD and IND 
attacks. However, these and other guidance documents do not contain 
complete information on the type and timing of federal technical and 
resource assistance by response phases. For RDD attacks, DHS has not 
provided specific operational guidance on the type and timing of 
federal assistance that might be made available to cities for early 
response, although some information is available in an emergency 
support function annex to the National Response Framework. For IND 
attacks, DHS identified the technical and resource activities that 
federal agencies could provide to respond to an IND attack in a 2009 
federal interim concept of operations plan and more recently in the 
2012 IND regional operations plan for Chicago. In addition, federal 
agencies have provided various descriptions of the type and timing of 
the federal assistance that might be available on their websites. 
However, FEMA officials told us that the type and timing of the 
federal response would depend on the proximity of the city to federal 
offices. Confusion over the type and timing of assistance, such as 
federal assistance in the case of an IND attack, could produce a 
disjointed and untimely early response to the attack that might 
increase its consequences. 

Based on information from a variety of sources, some of which may not 
be readily available to major cities, we developed an illustration of 
the federal agencies most likely to assist these cities during early 
response with activities associated with the core capabilities they 
claim they can support after an IND attack. While other federal 
agencies are involved through their emergency support functions under 
the National Response Framework, a senior FEMA official told us that 
the four federal agencies we identified in figure 5 would be the most 
involved during the first 24 hours after an IND attack. Figure 5 
provides an illustration of the federal technical and resource support 
for the core capabilities necessary for major city early response to 
an IND attack. 

Figure 5: Anticipated Federal Technical and Resource Support for Core 
Capabilities Necessary for a Major City Early Response to an 
Improvised Nuclear Device (IND) Attack: 

[Refer to PDF for image: illustration of concentric circles] 

Inner circle: 
Major City (Location of attack). 

Next circle: 
Surrounding Jurisdictions (Support to city). 

Next circle: 
State(s) (Support to city). 

Outer circle: 
Federal Government Support: 
NNSA: 
* Public Information and Warning; 
* Operational Coordination; 
* Environmental Response/Health and Safety; 
* Public Health and Medical Services; 
* Situational Assessment. 
FEMA: 
* Public Information and Warning; 
* Operational Coordination; 
* Critical Transportation; 
* Infrastructure Systems; 
* Mass Care Services; 
* Mass Search and Rescue Operations; 
* Operational Communications; 
* Situational Assessment. 
HHS: 
* Environmental Response/Health and Safety; 
* Fatality Management; 
* Mass Care Services; 
* Public Health and Medical Services. 
DOD: 
* Operational Coordination; 
* Mass Search and Rescue Operations; 
* On-scene Security and Protection; 
* Public Health and Medical Services; 
* Situational Assessment. 

Source: GAO. 

Note: This figure includes the four major agencies (DOE/NNSA, 
DHS/FEMA, HHS, and DOD) that would have primary responsibility for 
providing technical and resource assistance to a major city within the 
first 24 hours after an IND attack, although other federal agencies 
may be present. The need for core response capabilities from the 
federal government may differ for an RDD attack. This figure is based 
on our review of documents, such as DHS, Emergency Support Functions 
Annex to the National Response Framework (2008), DHS, Federal 
Interagency Improvised Nuclear Devices Concept of Operations Plan 
(2009), FEMA, IND Regional Operations Plan for Chicago (2012), and 
interviews with FEMA and NNSA officials. 

[End of figure] 

Major Cities Reported Need for Improved Procedures and Information for 
Early Response to RDD and IND Attacks: 

Most emergency managers responding to our questionnaire indicated that 
their cities perceive a need for federal government research that 
could improve procedures or information for their early response to 
RDD and IND attacks. Using DHS guidance, we developed a list of 10 
topic areas for federal government research initiatives that could 
improve procedures or information used by cities during the first 24 
hours after the detonation of an RDD or IND.[Footnote 38] We asked 
emergency managers for their opinions on how much impact, if any, each 
topic area might have on improving their city's capability for early 
response to an RDD or IND attack. For example, emergency managers from 
two-thirds of the major cities (18 of 27 cities) identified 
communicating a sheltering-in-place strategy to the public and 
communicating potential impacts of radiation exposure to the public as 
the topic areas having the highest impact. Figure 6 shows emergency 
managers' responses identifying the topic areas their city considers 
important for improving procedures or information necessary for early 
response to RDD and IND attacks. 

Figure 6: Federal Radiological Dispersal Device (RDD) or Improvised 
Nuclear Device (IND) Response Topic Areas Identified by Major City 
Emergency Managers as Needed to Improve Early Response Capabilities: 

[Refer to PDF for image: horizontal bar graph] 

Federal research initiatives topic area: Communicating a sheltering-in-
place strategy to the public; 
Number of cities indicating high impact: 18. 

Federal research initiatives topic area: Communicating potential
impacts of radiation exposure to the public; 
Number of cities indicating high impact: 18. 

Federal research initiatives topic area: Measuring the actual, real-
time dispersal of radioactive materials; 
Number of cities indicating high impact: 17. 

Federal research initiatives topic area: Predicting impacts on the 
city’s physical infrastructure; 
Number of cities indicating high impact: 16. 

Federal research initiatives topic area: Early decontamination
of people; 
Number of cities indicating high impact: 14. 

Federal research initiatives topic area: Mass evacuation; 
Number of cities indicating high impact: 14. 

Federal research initiatives topic area: Developing a strategy for
relocating the public to emergency shelters; 
Number of cities indicating high impact: 12. 

Federal research initiatives topic area: Modeling the predicted
dispersal of radioactive materials; 
Number of cities indicating high impact: 11. 

Federal research initiatives topic area: Predicting radiological
impacts on people; 
Number of cities indicating high impact: 10. 

Federal research initiatives topic area: Early decontamination of
buildings; 
Number of cities indicating high impact: 9, 

Source: GAO content analysis of questionnaire responses. 

Note: GAO received questionnaire responses from emergency managers of 
27 major cities: Anaheim, Baltimore, Boston, Charlotte, Chicago, 
Dallas, Denver, Detroit, Houston, Indianapolis, Kansas City, Las 
Vegas, Los Angeles, Miami, Minneapolis, New Orleans, New York City, 
Orlando, Philadelphia, Portland, Riverside, San Diego, San Francisco, 
Seattle, St. Louis, Tampa, and the District of Columbia. 

[End of figure] 

We compared the emergency managers' responses on the impact that 
improved procedures and information might have on their city's early 
response to RDD and IND attacks with the research initiatives being 
considered by six FEMA IND focus working groups to determine if they 
align. FEMA has established these working groups of subject matter 
experts to mitigate shortcomings in response capabilities for an IND 
attack, such as clarifying responsibilities and coordinating efforts 
among government levels and federal agencies.[Footnote 39] We found 
that the areas addressed by the working groups through their 
initiatives are generally the same as those topic areas emergency 
managers reported as having a high impact on procedures and 
information needed for early response to an RDD and IND attack. 

FEMA does not have current plans to identify or attempt to fill 
potential gaps in capabilities for early response specifically to an 
RDD attack. However, IND focus area working group experts and a senior 
FEMA official told us that their efforts to fill gaps in IND 
capabilities and all hazards plans would have application for other 
catastrophic hazards, including RDD attacks. For example, they told us 
that RDD and IND attacks share some common attributes, such as (1) the 
release of radiological materials, (2) the need for decontamination 
and radiation treatment, and (3) prioritization of response resources 
and personnel based on ethical, philosophical, legal, and practical 
decision tools. In addition, both types of attacks also require 
communication of consistent information about radiation effects on 
general health outcomes and protective measures. Further, NNSA 
officials told us they also have several programs that might apply to 
RDD, as well as IND planning and capability enhancements. 

Major Cities See Need for Federal Funding to Maintain Early Response 
to RDD and IND Attacks: 

Most emergency managers responding to our questionnaire indicated that 
their cities need federal funding to maintain current early response 
capabilities to an RDD or IND attack. Almost all emergency managers 
(24 of 27 cities for RDD and 23 of 27 cities for IND) indicated that 
their city needs federal funding to maintain current early response 
capabilities. According to the 2008 National Response Framework, 
response capabilities are developed within the national preparedness 
system through effective planning, coordinating, training, equipping, 
and exercising activities. These activities are essential elements of 
an integrated, capability-based approach to preparedness. Emergency 
managers reported that a decrease in federal funding would affect the 
degree to which each of these activities builds the capabilities 
needed for early response to an RDD or IND attack. Our analysis of 
questionnaire results indicated that about a third of 27 cities 
identified equipment, training, and planning activities important to 
the capabilities that would be most affected by a decrease in federal 
preparedness funding, with fewer cities indicating that coordination 
and exercising would be affected. 

Federal funding to support preparedness against terrorist attacks and 
other catastrophic incidents such as RDD and IND attacks currently 
comes from seven DHS grant programs.[Footnote 40] In fiscal year 2013, 
DHS allocated more than $1.5 billion for these seven grant programs, 
but officials in charge of these programs were unable to determine how 
much of the funding was used by major cities to improve early RDD and 
IND response capabilities.[Footnote 41] Two of the DHS grant programs 
that have been most relevant to response preparation for an RDD or IND 
attack are the Homeland Security Grant Program and the temporary 
(fiscal years 2008 to 2011) Regional Catastrophic Planning Grant 
Program. In fiscal year 2013, DHS allocated more than $968 million to 
the Homeland Security Grant Program, and more than half (roughly $560 
million) was allocated to Urban Areas Security Initiative grants, a 
portion of which goes to law enforcement terrorism prevention 
activities. The Regional Catastrophic Planning Grant Program awarded 
$14 million in grants in fiscal year 2011, the last year it made 
awards, to support regional planning efforts to address catastrophic 
incidents.[Footnote 42] For example, these funds were used by New York 
and New Jersey to develop RDD and IND response plans and were also 
combined with other federal funding to support development of the IND 
regional operations plan for Chicago. According to members of the IND 
planning team for Chicago, the Regional Catastrophic Planning Grant 
Program provided the funding to bring together the many stakeholder 
groups that would be involved in responding to an IND attack and, 
without continued funding, it would be difficult to maintain the same 
level of collaboration. Appendix III provides a detailed breakdown of 
the seven federal grant programs for fiscal year 2013. 

Conclusions: 

DHS has recognized that the early response to catastrophic incidents 
such as an RDD or IND attack on a major city is critical and has to 
come first from the city and surrounding jurisdictions. While cities 
are assumed to be preferred targets for an RDD or IND attack, in 
response to our questionnaire, many emergency managers indicated that 
their cities ranked the risk of these attacks as lower than other 
hazards their cities face, and fewer than half of the cities have 
specific response plans for such attacks. City emergency managers rely 
on federal guidance to prepare all hazards emergency operations plans 
and also specific response plans for hazards of concern that can be 
annexed to these emergency operations plans at the discretion of the 
city. However, we found limitations in the federal planning guidance 
applicable to the early response capabilities needed by cities for an 
RDD attack of the size depicted in the National Planning Scenarios. 
More federal planning guidance applicable to major cities has been 
developed for IND response, primarily based on the event depicted in 
the National Planning Scenarios, but this guidance does not detail the 
early response capabilities needed by major cities in relation to 
other sources of assistance. Perceptions of emergency managers varied 
widely on their cities' abilities to conduct the activities needed for 
early response to the type of RDD attacks described in the National 
Planning Scenarios--with assistance from surrounding jurisdictions but 
not the federal government--from being able to conduct all activities 
for early response to being able to conduct few early response 
activities. Less variation was evident for perceived early response 
abilities to an IND attack--considering this same source of 
assistance--with many cities indicating that such an attack would 
overwhelm their response abilities. Most cities indicated the need for 
federal technical and resource assistance--among other areas of 
federal support--for early response to RDD and IND attacks, but we 
found that complete guidance on the type and timing of this assistance 
is not readily available in a single document and is not well 
understood by all major city emergency managers. Any confusion over 
the type and timing of federal assistance could produce a disjointed 
and untimely early response to an attack that might increase its 
consequences. Without greater awareness of existing federal guidance 
and continued actions to close gaps in the guidance applicable to 
cities' early response to RDD and IND attacks, some cities may not 
have the information they need to adequately prepare for and respond 
to them. Lack of adequate response planning could lead to 
complications that result in greater loss of life and economic impacts. 

Recommendation for Executive Action: 

To provide assistance to major cities in planning for early response 
to RDD and IND attacks, we recommend that the Secretary of Homeland 
Security direct the Administrator for the Federal Emergency Management 
Agency to promote greater awareness of existing federal guidance and 
develop additional guidance where appropriate to clarify the 
capabilities needed by cities for these attacks, including the 
planning assumptions for an RDD attack and the type and timing of 
federal assistance for early response. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to DHS and to DOE through NNSA for 
review and comment. DHS did not concur with our recommendation and 
provided written comments, which are reproduced in appendix IV. In 
addition, in an e-mail received August 27, 2013, the Director, Audit 
Coordination and Internal Affairs Office of Management and Budget (NA-
MB-1.1) for NNSA stated that as the recommendations in the report are 
directed to DHS and FEMA, NNSA would not be preparing a formal 
response. DHS and NNSA provided technical comments, which we 
incorporated as appropriate. 

In the comment letter, DHS states that FEMA program officials and 
subject matter experts are concerned that our survey may have resulted 
in the receipt of skewed data and information that affected our 
analysis and conclusions. For example, the letter stated that some 
respondents may have believed that an IND/RDD event would or could be 
fully handled at the local level and therefore provided inputs partial 
toward taking on an inordinate level of responsibility. They also 
stated that our recommendation runs contrary to the survey results 
which illustrate a trend of grouping RDD and IND attacks for analysis 
and planning. We disagree. Our questionnaire explicitly asked city 
emergency managers to consider response assistance from surrounding 
jurisdictions in their assessment of response abilities, and only 
exclude federal assistance. In this way, we were able to isolate the 
perceived need for federal support, which we found for technical and 
resource assistance, improved procedures and information, and funding. 
Further, emergency managers did not provide trend information through 
their questionnaire responses on assessing RDD and IND risks, and 
cities more often separated the assessment of RDD and IND risks than 
combined them as DHS indicated in its comment letter. In addition, we 
took a number of steps to develop the questionnaire and to identify 
the best source for a response. For example, we conducted extensive 
pretesting and obtained comments on a draft questionnaire from 
officials at FEMA's National Preparedness Assessment Division. We also 
determined that city emergency managers were in the best position to 
provide a city-wide perspective on this issue, but we allowed them to 
seek advice from other city officials as necessary. 

In its comment letter, DHS stated that neither the department nor FEMA 
believes that our recommendation that FEMA develop additional guidance 
in a single document to clarify the capabilities needed by cities for 
these attacks, including the planning assumptions for an RDD attack 
and addressing the type and timing of federal assistance for early 
response takes into sufficient account advances made to the 
preparedness system. In addition, the comment letter states that FEMA 
program officials and subject matter experts believe the 
recommendation does not align with our survey results or all-hazard 
risk management for worst case catastrophic scenarios. It also states 
that FEMA has concerns with the report's characterization of the 
nation's ability to respond to a nuclear and/or radiological attack. 
Furthermore, the letter states that additional RDD response guidance 
in a single document would be counterproductive to the existing 
planning and guidance structure for IND and all hazards incidents. As 
we note in the report, FEMA is already considering development of a 
nuclear and radiological incident annex to the FIOPs for the response 
and recovery mission areas based on the recognition that the all 
hazards approach may be insufficient to cover the unique response 
needs for nuclear and radiological incidents. While our recommendation 
did not specify how FEMA should provide this additional guidance, we 
have added language to the recommendation to clarify that we are not 
recommending a single guidance document to cover only RDD response. In 
addition, to address the DHS/FEMA concern that city emergency managers 
may not be fully informed about available guidance, we added language 
to the recommendation for FEMA to promote greater awareness of 
existing federal guidance. 

More generally, DHS' comment letter states that FEMA officials do not 
believe we provided adequate context for the National Preparedness 
System as defined by Presidential Policy Directive 8, which may cause 
confusion for cold readers not familiar with how the directive has 
been implemented. In addition, the comment letter states that the 
operational frameworks, structures, and ongoing efforts that have been 
developed in support of the directive's comprehensive approach to 
national response are not fully outlined in the report; specifically, 
the letter states that the Nuclear and Radiological Incident Annex to 
the National Response Framework and Emergency Support Functions as the 
nation's coordinating structures are not accurately portrayed and 
cites figure 5 as an inaccurate and misleading depiction of the 
federal response for an IND/RDD event. While the purpose of this 
report was not to conduct a detailed assessment of federal guidance or 
implementation of the directive, we added additional information about 
FEMA's leadership role in coordinating the federal response to nuclear 
and radiological incidents within the context of the National Response 
Framework and its efforts to develop IND response planning guidance. 
We also added that the illustration in figure 5 of federal agency 
support for core response capabilities that might be available to 
cities during the first 24 hours after an IND attack does not include 
all federal agencies' activities but only those four agencies 
confirmed by a senior FEMA official as being most present during this 
time period. 

We are sending copies of this report to the Secretary of Homeland 
Security and the Secretary of Energy, the appropriate congressional 
committees, and other interested parties. In addition, the report will 
be available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202)512-3841 or t [Hyperlink, trimbled@gao.gov] 
rimbled@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. GAO staff who made contributions to this report are listed in 
appendix V. 

Sincerely yours, 

Signed by: 

David C. Trimble: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

In our review, we examined major cities' (1) assessment of the risks 
of RDD and IND attacks and the extent to which they have developed 
plans for responding to them, (2) perceptions of their abilities to 
respond to RDD and IND attacks in the first 24 hours (early response), 
and (3) perceptions of their need for federal support in the early 
response to RDD and IND attacks. To address these questions we sent a 
questionnaire to major city emergency managers, and we conducted 
interviews with outside experts and federal, state, and local 
officials. 

To gather information from major U.S. cities relevant to all three of 
our objectives, we developed a questionnaire for the directors of 
emergency management for each of the 31 major cities that were in the 
Urban Areas Security Initiative (UASI) program in fiscal year 2012. 
[Footnote 43] We chose the major cities within each UASI region 
because in our document review, as well as in interviews with the 
Federal Emergency Management Agency (FEMA), UASI regions were 
identified as higher risk jurisdictions for terrorist acts, including 
those using RDDs or INDs.[Footnote 44] As FEMA guidance states that 
local jurisdictions should plan and develop capabilities to respond to 
incidents based on risk, these jurisdictions are in need of developing 
plans and preparing for the response to RDD and IND attacks. Each of 
the 31 UASI locations covers a large metropolitan area that includes 
many local governments. For example, the Chicago UASI includes 3 
states, 14 counties, and 10 principal cities. It did not serve our 
purpose to send the questionnaire directly through the UASI structure 
itself as the number of jurisdictions involved could introduce issues 
of reliability in the answers, as well as consistency in terms of the 
process used by each UASI to fill out our questionnaire. FEMA 
officials told us that the largest metropolitan area within each UASI 
constitutes the area at the highest risk for attack in each 
jurisdiction. In addition, we selected city emergency managers to 
receive the questionnaire because they were in the best position to 
provide a city-wide perspective on the level of preparedness to 
respond to RDD and IND attacks. Therefore, we chose to send 
questionnaires to only the emergency managers of these large 
metropolitan areas. The emergency management offices in Atlanta and 
Newark did not respond to our contact attempts, so we sent out 
questionnaires to the 29 cities that did reply. In developing our 
questionnaire, we developed questions that addressed all three of the 
report objectives and had these reviewed both internally, as well as 
by staff of FEMA's National Preparedness Assessment Division. We 
conducted seven cognitive pretests with emergency management officials 
and first responders from major cities selected for their geographic 
location and population size in order to minimize errors that might 
occur from respondents who interpreted our questions differently than 
we intended. During these pretests, we also interviewed these 
emergency management officials and first responders to gain additional 
context regarding their city's preparedness for responding to either 
an RDD or IND attack. 

The questionnaire was implemented as a self-administered Microsoft 
Word form e-mailed to respondents. We sent e-mail notifications to 
emergency managers beginning on December 11, 2012.[Footnote 45] We 
then sent the questionnaire and a cover e-mail to officials on 
December 12, 2012, and asked them to fill in the questionnaire form 
and e-mail it back to us within 3 weeks. To encourage emergency 
managers to complete the questionnaire, we sent e-mail reminders and a 
replacement questionnaire to nonrespondents approximately 1 week 
after, and again 3 weeks after, the initial questionnaire was 
distributed. We also made follow-up phone calls to nonrespondents from 
January 24, 2013, to February 8, 2013. We closed the questionnaire on 
February 20, 2013. We received 27 completed questionnaires for an 
overall response rate of 87 percent--Phoenix and San Antonio did not 
return the questionnaire. Because we attempted to collect data from 
each of the UASI major cities rather than a sample of major cities, 
there was no sampling error. However, the practical difficulties of 
conducting any questionnaire may introduce errors, commonly referred 
to as nonsampling errors. For example, differences in how a particular 
question is interpreted, the sources of information available to 
respondents, how the responses were processed and analyzed, or the 
types of people who do not respond can influence the accuracy of the 
questionnaire results. We took steps in the development of the 
questionnaire, the data collection, and the data analysis to minimize 
these nonsampling errors and help ensure the accuracy of the answers 
that were obtained. For example, a GAO social science questionnaire 
specialist designed the questionnaire, in collaboration with GAO staff 
with subject matter expertise. The draft questionnaire was pretested 
to ensure that questions were relevant, clearly stated, and easy to 
comprehend. The questionnaire was also reviewed by external experts 
and a second GAO questionnaire specialist. Data were electronically 
extracted from the Microsoft Word form questionnaires into a comma-
delimited file that was then imported into a statistical program for 
analyses. No manual data entry was performed, thereby removing an 
additional potential source of error. We examined the questionnaire 
results and performed computer analyses to identify inconsistencies 
and other indications of error and addressed such issues as were 
necessary. Additionally, we contacted respondents to clarify ambiguous 
responses when necessary. Quantitative data analyses and the 
compilation of open-ended responses were conducted by the first GAO 
questionnaire specialist using statistical software and working 
directly with GAO staff with subject matter expertise. An independent 
GAO data analyst checked the statistical computer programs for 
accuracy. 

Responses to closed-ended (e.g., Yes/No) questions were summarized as 
standard descriptive statistics. Responses to open-ended (i.e., 
narrative) questions were analyzed through content analysis. In 
conducting the content analysis, one GAO analyst reviewed each open-
ended response from each emergency manager to identify recurring 
themes. Using the identified themes, the analyst then developed 
categories for coding the responses. A second GAO analyst reviewed the 
responses from each emergency manager and reviewed the first analyst's 
themes and categories to reach concurrence on the themes and 
categories. Each of the two GAO analysts then independently reviewed 
the answers to all open-ended questions and placed them into one or 
more of the categories. The analysts then compared their coding to 
identify any disagreements and reached agreement on all items through 
discussion. For the analysis of the open-ended responses on the city's 
ability to respond to either an RDD or IND, we developed six 
categories based on the number of early response activities a city 
stated it could provide. Specifically, we reviewed the responses 
looking for whether the city would be overwhelmed, the number of 
specific activities the city stated it would conduct, and significant 
challenges it would face after the attack. 

To provide important context regarding current federal activities that 
relate to our second and third objectives on RDD and IND response 
planning and federal response capabilities, we traveled to Chicago to 
meet with federal, regional, state, and city planners who had 
participated in the interagency IND regional planning effort. In 
addition, we met with Department of Homeland Security and FEMA 
officials to learn how they may use insights gained from the 
interagency IND regional planning effort in Chicago for use in other 
major cities and for developing a potential nuclear and radiological 
annex to the draft federal interagency operational plans for the 
response and recovery mission areas. 

To obtain additional information for our third objective on the need 
and availability of federal early response support, we interviewed 
officials involved with federal research initiatives to close gaps in 
response capabilities, as well as those who oversaw planning funds and 
federal technical and resource assistance activities for RDD and IND 
attacks. Specifically, we interviewed FEMA emergency management 
interagency working groups, response planning, and grants officials; 
National Nuclear Security Administration emergency management response 
operations officials; Department of Energy national laboratory 
officials; and subject matter experts. We also reviewed relevant 
federal guidance documents. 

We conducted this performance audit from June 2012 to September 2013 
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. 

[End of section] 

Appendix II: Questionnaire: 

U.S. Government Accountability Office: 

Survey on City Early Response to Radiological Dispersal or Improvised 
Nuclear Device Attack: 

Survey Purpose: To gather the perspectives of local emergency managers 
about the threat posed by a terrorist detonation of a radiological 
dispersal device (RDD) or improvised nuclear device (IND) and their city
’s capability to respond to either incident. The responses will inform 
Congress as it explores ways to enhance local preparedness. 

The U.S. Government Accountability Office (GAO)--a non-partisan agency 
of the Congress that conducts objective, fact-based research--has been 
asked by the Senate Committee on Homeland Security and Governmental 
Affairs to study the perceived roles, responsibilities, and 
capabilities of major cities for early response to a terrorist attack 
using an RDD or IND. Either type of attack would require an effective 
response within the first 24 hours to characterize the dispersal of 
the radioactive material, communicate life-saving advice to affected 
populations, and to mobilize other response capabilities. 

This survey will gather the perspectives of emergency managers 
representing the most populated city within each of the 31 Urban Areas 
Security Initiative (UASI) jurisdictions about the threat posed by the 
detonation of an RDD or IND and their capabilities in conducting 
response activities during the first 24 hours after detonation. 

We need your help to provide Congress with this important information 
and your responses may help improve federal support to cities in the 
future. Your answers will be aggregated with those from all other 
cities and will be summarized in a report to Congress that will be 
publicly available. We will not publish survey responses that 
identify cities in our report. 

We will send you a copy or a link to the report when our report is 
published in 2013. 

This survey is not being conducted for FEMA and it is independent of 
any FEMA surveys or other assessments. 

You were identified as the emergency management point of contact for 
your city. You may not have the answer to every question readily 
available, so please consult records or ask other people in your 
emergency management office for information that will allow you to 
answer every question. We are interested in your city-wide perspective 
as an emergency manager rather than the perspectives of all city 
departments. 

Please complete and return this Microsoft Word file as an email 
attachment by Friday, January 4, 2013. 

This questionnaire includes approximately 25 questions. Almost all 
questions are “Yes/No” or “checkbox” questions that can be answered 
very quickly. 

When you are finished with this questionnaire, please save it and 
email it as an attachment to Eli Lewine at LewineE@gao.gov. If you 
have any questions, please contact Eli Lewine at LewineE@gao.gov or 
202-512-3494. 

Instructions: 

To navigate through this questionnaire, please use the tab key, up and 
down arrow keys, page up and page down keys, or the scroll bar. To 
select an answer using a check box, simply use the mouse to click in 
the box. To remove a mark from a check box, simply click in the check 
box again and the “X” should disappear. To select an answer using a 
“drop-down” box (Example), click on the box and select a response from 
the list provided. To answer a question that requires that you type a 
comment, please click on the answer box and begin typing. The comment 
area will expand as you type. 

Please save the file frequently to avoid losing your answers. Thank 
you. 

1. If a radiological dispersal device (RDD) or an improvised nuclear 
device (IND) detonated in your city, which of the following documents, 
if any, would you consult to know your city’s roles and 
responsibilities for responding? This includes but is not limited to 
your city’s response during the first 24 hours. Please select “yes” if 
the document’s roles and responsibilities apply to an RDD or IND 
attack even if the document does not explicitly refer to an RDD or IND 
attack. Please click in the Drop-Down box to select “Yes”, “No” , “Not 
applicable”, or “Don’t know” for each row. 

City emergency operations plan: Select One; 
City hazard management plan: Select One; 
City continuity of operations plan: Select One; 
Regional catastrophic incident coordination plan: Select One; 
State emergency operations plan: Select One; 
State radiological emergency response plan: Select One; 

Other plans, annexes, or documents not mentioned above (Please 
describe below): Select One. 

2. What is the current state of development of your city’s city-wide 
planning specifically for response to the detonation of an RDD in your 
city? This includes but is not limited to your city’s response during 
the first 24 hours. This question refers to city-wide plans, not the 
plans of specific departments (e.g., police or fire department-
specific plans). Please check only one box below. 

Not applicable - This city is not responsible for planning 
specifically for an RDD attack: Skip to Question 5; 

No city-wide RDD-specific plans have been completed nor are any in 
development: Skip to Question 5; 

No city-wide RDD-specific plans have been completed but some are in 
development: Skip to Question 5; 

Some but not all city-wide RDD-specific plans have been completed: 
Continue with “3” below; 

All city-wide RDD-specific plans that were in development have been 
completed: Continue with “3” below. 

3. If some or all city-wide RDD-specific plans for response to the 
detonation of an RDD have been completed, are the roles and 
responsibilities for your city in those plans significantly 
different from the local government roles and responsibilities 
described in the National Response Framework (NRF) and its supporting 
annexes? (Control-click here or direct your browser to [hyperlink, 
http://www.fema.gov/pdf/emergency/nrf/nrf-core.pdf] to download the 
National Response Framework, if desired.) Please check only one box 
below. 

City’s roles and responsibilities are significantly different from 
those for local governments in the NRF: Continue with “3a” below. 

City’s roles and responsibilities are not significantly different from 
those for local governments in the NRF: Skip to Question 4; 

Don’t know: Skip to Question 4. 

3a. If your city’s roles and responsibilities are significantly 
different from those described for local governments in the National 
Response Framework, what are the differences? The box will expand as 
you type. 

4. If some or all city-wide RDD-specific plans for response to the 
detonation of an RDD have been completed, has your city or will your 
city have participated in any exercises to test the validity of any of 
the plans between January 1, 2010 and December 31, 2012? This includes 
local, regional, state or federal exercises. Exercises may include 
workshops, facilitated policy discussions, seminars, tabletop 
exercises, games, modeling and simulation, drills, functional 
exercises, and full-scale exercises. Please check only one box below. 

Yes: Continue with “4a” below; 
No: Skip to Question 6; 
Don’t know: Skip to Question 6. 

4a. If “yes”, what types of exercises were they? Exercises may include 
workshops, facilitated policy discussions, seminars, tabletop 
exercises, games, modeling and simulation, drills, functional 
exercises, and full-scale exercises. The box will expand as you type. 

4b. Were the response activities performed by the federal government--
other than those of federal law enforcement agencies--incorporated in 
the execution of any of these exercises? Please check only one box 
below. 
Yes: 
No: 
Don’t know: 

5. In Question 2 you indicated that your city does not have city-wide 
RDD-specific plans. What city-wide plans does your city have that 
would apply to the detonation of an RDD in your city? This question 
refers to city-wide plans, not the plans of specific departments 
(e.g., police or fire department-specific plans). The box will expand 
as you type. 

6. What is the current state of development of your city’s city-wide 
planning specifically for response to the detonation of an IND in your 
city? This includes but is not limited to your city’s response during 
the first 24 hours. This question refers to city-wide plans, not the 
plans of specific departments (e.g., police or fire department-
specific plans). Please check only one box below. 

Not applicable - This city is not responsible for planning 
specifically for an IND attack: Skip to Question 9; 

No city-wide IND-specific plans have been completed nor are any in 
development: Skip to Question 9; 

No city-wide IND-specific plans have been completed but some are in 
development: Skip to Question 9; 

Some but not all city-wide IND-specific plans have been completed: 
Continue with “7” below; 

All city-wide IND-specific plans that were in development have been 
completed: Continue with “7” below. 

7. If some or all city-wide IND-specific plans for response to the 
detonation of an IND have been completed, are the roles and 
responsibilities for your city in those plans significantly different 
from the local government roles and responsibilities described in the 
National Response Framework (NRF) and its supporting annexes? (Control-
click here or direct your browser to [hyperlink, 
http://www.fema.gov/pdf/emergency/nrf/nrf-core.pdf] to download the 
National Response Framework, if desired.) Please check only one box 
below. 

City’s roles and responsibilities are significantly different from 
those for local governments in the NRF: Continue with “7a” below; 

City’s roles and responsibilities are not significantly different from 
those for local governments in the NRF: Skip to Question 8; 

Don’t know: Skip to Question 8. 

7a. If your city’s roles and responsibilities are significantly 
different from those described for local governments in the National 
Response Framework, what are the differences? The box will expand as 
you type. 

8. If some or all city-wide IND-specific plans for response to the 
detonation of an IND have been completed, has your city or will your 
city have participated in any exercises to test the validity of any of 
the plans between January 1, 2010 and December 31, 2012? This includes 
local, regional, state or federal exercises. Exercises may include 
workshops, facilitated policy discussions, seminars, tabletop 
exercises, games, modeling and simulation, drills, functional 
exercises, and full-scale exercises. Please check only one box below. 

Yes: Continue with “8a” below; 
No: Skip to Question 10; 
Don’t know: Skip to Question 10. 

8a. If “yes”, what types of exercises were they? Exercises may include 
workshops, facilitated policy discussions, seminars, tabletop 
exercises, games, modeling and simulation, drills, functional 
exercises, and full-scale exercises. The box will expand as you type: 

8b. Were the response activities performed by the federal government--
other than those of federal law enforcement agencies---incorporated in 
the execution of any of these exercises? Please check only one box 
below. 
Yes: 
No: 
Don’t know: 

9. In Question 6 you indicated that your city does not have city-wide 
IND-specific plans. What city-wide plans does your city have that 
would apply to the detonation of an IND in your city? This question 
refers to city-wide plans, not the plans of specific departments (e.g., 
police or fire department-specific plans). The box will expand as you 
type: 

10. Did your city assess the risk specifically of an RDD or IND attack 
as part of your city’s most-recently completed Hazard Identification 
and Vulnerability Assessment (HIVA) or similar assessment? For this 
survey, risk includes threat, vulnerability, and consequence. Please 
check only one box below. 

Not applicable - Our city has not completed a HIVA or 
similar assessment: Skip to the “Important” note before Question 11; 
No, neither RDD nor IND threats were assessed: Skip to the “Important” 
note before Question 11; 
Yes, but only the RDD threat was assessed: Continue with “10b” below; 
Yes, but only the IND threat was assessed: Skip to “10c”; 
Yes, both RDD and IND threats were assessed together as a single, 
combined “RDD/IND” threat: Skip to “10d”; 
Yes, both RDD and IND threats were assessed as two separate threats: 
Continue with “10a” below. 

10a. If the risk of an RDD attack was assessed separately from the 
risk of an IND attack, how did the risk of an RDD attack rank relative 
to the risk of an IND attack? Please check only one box below. 
An RDD attack was higher risk than an IND attack: 
An RDD attack was approximately the same risk as an IND attack: 
An RDD attack was lower risk than an IND attack: 

10b. How did the risk of an RDD attack rank relative to all other 
threats and hazards? Please check only one box below. 
An RDD attack was higher risk than all other threats/hazards: 
An RDD attack was higher risk than most other threats/hazards: 
An RDD attack was approximately the same risk as most other 
threats/hazards: 
An RDD attack was lower risk than most other threats/hazards: 
An RDD attack was lower risk than all other threats/hazards: 

10c. How did the risk of an IND attack rank relative to all other 
threats and hazards? Please check only one box below. 

Not applicable - An IND attack was not assessed: Skip to the 
“Important” note before Question 11; 
An IND attack was higher risk than all other threats/hazards: Skip to 
the “Important” note before Question 11; 
An IND attack was higher risk than most other threats/hazards: Skip to 
the Skip to the “Important” note before Question 11; 
“Important” note before Question 11; 
An IND attack was approximately the same risk as most other 
threats/hazards: Skip to the “Important” note before Question 11; 
An IND attack was lower risk than most other threats/hazards: Skip to 
the “Important” note before Question 11; 
An IND attack was lower risk than all other threats/hazards: Skip to 
the “Important” note before Question 11. 

10d. If the risk of an RDD or IND attack was assessed together as a 
single “RDD/IND” threat, how did the risk of an RDD/IND attack rank 
relative to all other threats and hazards? If they were not assessed 
together as a single threat, please skip to Question 8. Please check 
only one box below. 

An RDD/IND attack was higher risk than all other threats/hazards: 
An RDD/IND attack was higher risk than most other threats/hazards: 
An RDD/IND attack was approximately the same risk as most other 
threats/hazards: 
An RDD/IND attack was lower risk than most other threats/hazards: 
An RDD/IND attack was lower risk than all other threats/hazards: 

Important: There are many possible scenarios for an RDD or IND attack. 
It is impossible for us to ask about your city’s ability to respond 
for all scenarios. For this survey, we will ask you some questions 
based on one RDD scenario and one IND scenario drawn directly from the 
Department of Homeland Security’s National Planning Scenarios. 

Note: The next questions apply to the following RDD scenario: 

Casualties: 180 fatalities; 270 injuries; 20,000 detectable 
contaminations; 

Infrastructure Damage: Near the explosion; 

Evacuations/Displaced Persons: 
* 10,000 evacuated to shelters in safe areas (decontamination required 
prior to entering shelters); 
* 25,000 are given shelter-in-place instructions; 
* Hundreds of thousands self-evacuate from major urban areas in 
anticipation of future attacks; 

Contamination: 36 city blocks; 

Economic Impact: Up to billions of dollars; 

Potential for Multiple Events: Yes; 

Recovery Timeline: Months to years; 

11. In your opinion as an emergency manager, how able is your city to 
conduct the response during the first 24 hours after the detonation of 
an RDD, including mutual aid from any jurisdiction other than the 
federal government, for the scenario above? The box will expand 
as you type: 

12. In your opinion as an emergency manager, if federal funding to 
your city decreased from its current level, could your city maintain 
its current overall ability to conduct the response during the first 
24 hours after the detonation of an RDD for the scenario above, 
including mutual aid from any jurisdiction other than the federal 
government? Please check only one box below. 

Yes, could sustain current overall ability: Skip to Question 13; 
No, could not sustain current overall ability: Continue with “12a” 
below; 
Don’t know: Continue with “12a” below. 

12a. If “no” or “don’t know”, please explain why below. The box will 
expand as you type: 

13. Does your city have city-wide plans to improve its overall ability 
to conduct response during the first 24 hours after the detonation of 
an RDD for the scenario above, including mutual aid from any 
jurisdiction other than the federal government, beyond your city’s 
current overall level of ability between now and December 31, 2013? 
This question refers to city-wide plans, not the plans of specific 
departments (e.g., police or fire department-specific plans). Please 
check only one box below. 

Yes: 
No: 
Don’t know: 

14. For the scenario above, do you expect the federal government to 
perform any response activities during the first 24 hours after the 
detonation of an RDD that neither your city, state, nor any other 
jurisdiction would perform? Please check only one box below. 

Yes: Continue with “14a” below; 
No: Skip to Question 15; 
Don’t know: Skip to Question 15. 

14a. If “yes”, what activities do you expect the federal government 
would perform during the first 24 hours after the detonation of an RDD 
for the scenario above that neither your city, state, nor any other 
jurisdiction would perform? The box will expand as you type. 

15. The 2011 National Preparedness Goal uses an “all-hazards” approach 
to describe activities that may be needed to respond to all hazards 
and threats rather than specific hazards or threats. For the RDD 
scenario provided above, how adequate, if at all, is an “all hazards” 
approach for the response during the first 24 hours after the 
detonation of an RDD? (Control-click here or direct your browser to 
[hyperlink, http://www.fema.gov/pdf/prepared/npg.pdf] to download the 
National Preparedness Goal, if desired.) Please check only one box 
below. 

Completely adequate: Skip to the “Note” on the next page; 
Mostly adequate: Skip to the “Note” on the next page; 
Moderately adequate: Continue to “15a”; 
Slightly adequate: Continue to “15a”; 
Not at all adequate: Continue to “15a”; 
Don’t know or no opinion: Skip to the “Note” on the next page. 

15a. If you checked “not at all”, “slightly”, or “moderately adequate,”
what is not adequate about the “all-hazards” approach regarding 
response during the first 24 hours after the detonation of an RDD in 
your city for the RDD scenario above? The box will expand as you type. 

Note: The next questions apply to the following IND scenario: 

Casualties: Hundreds of thousands; 

Infrastructure Damage: Total within radius of 0.5 to 3 miles; 

Evacuations/Displaced Persons: 
* 100,000 in affected area seek shelter in safe areas (decontamination 
required for all before entering shelters); 
* 250,000 instructed to shelter in place as plume moves across 
region(s); 
* 1 million+ self-evacuate from major urban areas. 

Contamination: Various levels up to approximately 3,000 square miles; 

Economic Impact: Hundreds of billions of dollars; 

Potential for Multiple Events: No; 

Recovery Timeline: Years. 

16. In your opinion as an emergency manager, how able is your city to 
conduct the response during the first 24 hours after the detonation of 
an IND, including mutual aid from any jurisdiction other than the 
federal government, for the scenario above? The box will expand 
as you type. 

17. In your opinion as an emergency manager, if federal funding to 
your city decreased from its current level, could your city maintain 
its current overall ability to conduct the response during the first 
24 hours after the detonation of an IND for the scenario above, 
including mutual aid from any jurisdiction other than the federal 
government? Please check only one box below. 

Yes, could sustain current overall ability: Skip to Question 18; 
No, could not sustain current overall ability: Continue with “17a” 
below; 
Don’t know: Continue with “17a” below. 

17a. If “no” or “don’t know”, please explain why below. The box will 
expand as you type. 

18. Does your city have city-wide plans to improve its overall ability 
to conduct response during the first 24 hours after the detonation of 
an IND for the scenario above, including mutual aid from any 
jurisdiction other than the federal government, beyond your city’s 
current overall level of ability between now and December 31, 2013? 
This question refers to city-wide plans, not the plans of specific 
departments (e.g., police or fire department-specific plans). Please 
check only one box below. 
Yes: 
No : 
Don’t know: 

19. For the scenario above, do you expect the federal government to 
perform any response activities during the first 24 hours after the 
detonation of an IND that neither your city, state, nor any other 
jurisdiction would perform? Please check only one box below. 
Yes: Continue with “19a” below; 
No: Skip to Question 20; 
Don’t know: Skip to Question 20. 

19a. If “yes”, what activities do you expect the federal government 
would perform during the first 24 hours after the detonation of an IND 
for the scenario above that neither your city, state, nor any other 
jurisdiction would perform? The box will expand as you type. 

20. The 2011 National Preparedness Goal uses an “all-hazards” approach 
to describe activities that may be needed to respond to all hazards 
and threats rather than specific hazards or threats. For the IND 
scenario provided above, how adequate, if at all, is an “all hazards” 
approach for the response during the first 24 hours after the 
detonation of an IND? (Control-click here or direct your browser to 
[hyperlink, http://www.fema.gov/pdf/prepared/npg.pdf] to download the 
National Preparedness Goal, if desired.) Please check only one box 
below. 
Completely adequate: Skip to Question 21; 
Mostly adequate: Skip to Question 21; 
Moderately adequate: Continue to “20a”; 
Slightly adequate: Continue to “20a”; 
Not at all adequate: : Skip to Question 21; 
Don’t know or no opinion: Skip to Question 21. 

20a. If you checked “not at all”, “slightly”, or “moderately adequate,”
what is not adequate about the “all-hazards” approach regarding 
response during the first 24 hours after the detonation of an IND in 
your city for the IND scenario above? The box will expand as you type. 

Final Questions: 

21. The federal government may support research that could improve 
procedures or information that could be used during the first 24 hours 
after the detonation of an RDD or IND, but needs to focus its 
resources on those areas that would provide the greatest impact. In 
your opinion as an emergency manager, how much impact, if any, would 
improving procedures or information in each of the following topic 
areas have on your city’s ability to respond during the first 24 hours 
after the detonation of an RDD or IND? This question applies to any 
RDD or IND scenario and is not limited to the specific scenarios 
presented earlier. Please click in the Drop-Down box to select “No 
impact”, “Very low impact”, Low impact”, “Moderate impact”, “High 
impact”, “Very high impact”, or “Don’t know/No opinion” for each area. 

select one: 

Improving procedures or information related to modeling the predicted 
dispersal of radioactive materials; 
Improving procedures or information related to measuring the actual, 
real-time dispersal of radioactive materials; 
Improving procedures or information related to predicting impacts on 
the city’s physical infrastructure;
Improving procedures or information related to predicting radiological 
impacts on people; 
Improving procedures or information related to communicating potential 
impacts of radiation exposure to the public; 
Improving procedures or information related to early decontamination 
of people; 
Improving procedures or information related to early decontamination 
of buildings; 
Improving procedures or information related to mass evacuation; 
Improving procedures or information related to communicating a 
sheltering-in-place strategy to the public; 
Improving procedures or information related to developing a strategy 
for relocating the public to emergency shelters. 

21a. If there are other topic areas in which improving procedures or 
information would have a “High” or “Very high” impact on your city’s 
ability to respond during the first 24 hours after the detonation of 
an RDD or IND, please type them in the box below. The box will expand 
as you type. 

22. In 2012, did or will your city follow the Threat and Hazard 
Identification and Risk Assessment (THIRA) approach, described in the 
2012 THIRA Comprehensive Preparedness Guide 201, to identify your 
city’s threats and hazards and assess associated risks and impacts? 
(Control-click here or direct your browser to [hyperlink, 
http://www.fema.gov/library/file?type=publishedFile&file=cpg_201_thira_g
uide_final_040312.pdf&fileid=b8f77f90-7e65-11e1-8178-001cc456982e] to 
download Comprehensive Preparedness Guide 201, if desired.) Please 
check only one box below. 
Yes: Continue with “22a” below; 
No: Skip to Question 23; 
Don’t know: Skip to Question 23. 

22a. If “yes”, did or will your city’s THIRA explicitly include the 
threat of an RDD attack or an IND attack or both? Please check only 
one box below. 
No, neither RDD nor IND threats were explicitly included: Continue with 
“22a1” below; 
Yes, but only the RDD threat was explicitly included: Continue with 
“22a1” below; 
Yes, but only the IND threat was explicitly included: Continue with 
“22a1” below; 
Yes, both RDD and IND threats were explicitly included together as a 
single, combined “RDD/IND” threat: Skip to Question 23' 
Yes, both RDD and IND threats were explicitly included as two separate 
threats: Skip to Question 23. 

22a1. If “no”, “yes but only RDD”, or “yes but only IND”, why was an 
RDD or IND threat or both threats not explicitly included in your 
city’s THIRA? The box will expand as you type. 

23. Has your city participated in preparing your Urban Area Security 
Initiative’s (UASI) 2012 THIRA? Please check only one box below. 
Yes: 
No: 
Don’t know: 

24. The results of this survey will be provided in a report to 
Congress. If you could tell Congress the most-important ways that the 
federal government could improve cities’ responses to an RDD or IND 
attack what would those ways be? This includes but is not limited to a 
city’s response during the first 24 hours. The box will expand as you 
type. 

25. In case we have follow-up questions about the answers in this 
questionnaire, please provide the following information about the 
person we should contact: 

Point of contact (POC) name: 
POC’s title: 
POC’s organization: 
POC’s phone number: 
POC’s email address: 

Please save this questionnaire and return it to Eli Lewine at 
LewineE@gao.gov. 

Thank you very much. 

[End of section] 

Appendix III: Fiscal Year 2013 DHS Preparedness Grant Programs Funding 
Awarded: 

Preparedness grant programs: Homeland Security Grant Program (HSGP); 
Comprised of three related grant programs: State Homeland Security 
Program (SHSP), Urban Areas Security Initiative (UASI), and Operation 
Stonegarden (OPSG); 
Grant programs purpose: For states and urban areas to prevent, protect 
against, mitigate, respond to, and recover from acts of terrorism and 
other threats; 
FY 2013 funding awarded: 
Over $968 million (HSGP); 
Over $354 million (SHSP); 
Over $558 million (UASI); 
$55 million (OPSG); 
Over $968 million (HSGP). 

* State Homeland Security Program; 
Grant programs purpose: To support the implementation of state 
homeland security strategies to build and strengthen preparedness 
capabilities at all levels; 
FY 2013 funding awarded: Over $354 million. 

* Urban Areas Security Initiative; 
Grant programs purpose: To enhance regional preparedness and 
capabilities in 31 high-threat, high-density areas; 
FY 2013 funding awarded: Over $558 million. 

* Operation Stonegarden; 
Grant programs purpose: To enhance cooperation and coordination among 
federal, state, territorial, tribal and local law enforcement agencies 
to jointly enhance security along the United States land and water 
borders; 
FY 2013 funding awarded: $55 million. 

Preparedness grant programs: Emergency Management Performance Grants 
Program; 
Grant programs purpose: To assist state and local governments in 
enhancing and sustaining all hazards emergency management capabilities; 
FY 2013 funding awarded: Over $332 million. 

Preparedness grant programs: Tribal Homeland Security Grant Program; 
Grant programs purpose: To implement preparedness initiatives to help 
strengthen the nation against risk associated with hazards including 
terrorist attacks; 
FY 2013 funding awarded: $10 million. 

Preparedness grant programs: Nonprofit Security Grant Program; 
Grant programs purpose: To support physical security enhancements for 
nonprofit organizations determined to be at high risk of a terrorist 
attack and located within one of the FY 2012 UASI-eligible urban areas; 
FY 2013 funding awarded: $10 million. 

Preparedness grant programs: Intercity Passenger Rail (Amtrak) Program; 
Grant programs purpose: To protect critical surface transportation 
infrastructure and the traveling public from terrorism and increase 
Amtrak rail system resilience; 
FY 2013 funding awarded: Over $9 million. 

Preparedness grant programs: Port Security Grant Program; 
Grant programs purpose: To protect critical port infrastructure from 
terrorism, enhance maritime domain awareness, and strengthen risk 
management capabilities to protect against improvised explosive 
devices and other nonconventional weapons; 
FY 2013 funding awarded: Over $93 million. 

Preparedness grant programs: Transit Security Grant Program; 
Grant programs purpose: To protect critical surface transportation and 
the traveling public from acts of terrorism and to increase the 
resilience of transit infrastructure; 
FY 2013 funding awarded: Over $83 million. 

Preparedness grant programs: Total Awarded; 
FY 2013 funding awarded: Over $1.5 billion. 

Source: DHS. 

[End of table] 

[End of section] 

Appendix IV: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528: 

September 13, 2013: 

David C. Trimble: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO-13-736, "Nuclear Terrorism Response Plans: Major 
Cities Could Benefit From Federal Guidance on Responding to Nuclear 
and Radiological Attacks" 

Dear Mr. Trimble: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

DHS is pleased to note GAO's positive recognition of actions taken by 
the Federal Emergency Management Agency (FEMA) to prepare guidance on 
planning assumptions for major attacks or natural disasters, including 
Radiological Dispersion Devices (RDDs) and Improvised Nuclear Device 
(IND) attacks. As noted in the report, this guidance, issued 7 years 
ago, serves as a reference to help planners at all levels of 
government identity the potential scope, magnitude, and complexity of 
these events. DHS remains committed to building and strengthening a
homeland security enterprise to better mitigate and defend against 
systemic threats, minimize risks, and maximize the ability to respond 
to and recover from attacks and disasters of all kinds. 

FEMA program officials and subject matter experts are concerned, 
however, that GAO's survey, used as a primary basis for this report, 
may have resulted in the receipt of skewed data and information that 
subsequently impacted GAO's analysis and conclusions documented in the
report. For example, it appears some respondents may have believed 
that an INDIRDD event would or could be fully handled at the local 
level and therefore provided inputs partial toward taking on an 
inordinate level of responsibility. This is not the case, as 
stakeholders at all levels of the Whole Community (local, state, 
tribal, territorial, federal, private and nonprofit sectors) would be 
involved in an INDIRDD weapons-of-mass-destruction (WMD) type of attack.
Response efforts would be dependent upon an incidents magnitude, which 
can also vary widely. Along these lines, FEMA has already delivered 
requisite risk analysis, training, and preparation for a wide variety 
of WMD attacks to stakeholders within its ongoing programs. 

In addition, FEMA officials do not believe the report provides an 
adequate context for the National Preparedness System as defined in 
Presidential Policy Directive 8 (PPD-8), which creates a National 
Preparedness Goal and System; thus the report may cause confusion for 
"cold readers" not familiar with exactly how PPD-8 has been 
implemented. Additionally, a portion of this system is defined by the 
well-established National Response Framework (NRF) and the Response 
Federal Interagency Operations Plan. These two documents, in addition 
to PPD-8, form the pillars of our Nation's response to all-threats and 
hazards planning or response, including that of a nuclear or 
radiological WMD incident. 

The operational frameworks, structures, and ongoing efforts that have 
been developed in support of the PPD-8 comprehensive approach to 
national response are not fully outlined in the report; specifically, 
the Nuclear and Radiological Incident Annex to the NRF and Emergency 
Support Functions as the Nation's coordinating structures are not 
accurately portrayed regarding context and perspective within the 
report, and these concepts are not reflected in many, if not all, of the
graphics in the report. For instance, Figure 5 is an inaccurate and 
misleading depiction of the federal response concept of operations for 
an IND/RDD event under the NRF. 

The draft report contained one recommendation with which DHS non-
concurs. Specifically, GAO recommended that the Secretary of Homeland 
Security direct the FEMA Administrator to: 

Recommendation: Develop additional guidance to clarify the 
capabilities needed by cities for these attacks, including the 
planning assumptions for an ROD attack and addressing the type and
timing of federal assistance for early response in a single document. 

Response: Non-Concur. The implementation of PPD-8 provides guidance to 
the Whole Community to guide preparedness efforts in all five mission 
areas: Prevention, Protection, Response, Recovery, and Mitigation. The 
Nation has adopted a Whole Community approach that attempts to engage 
the full capacity of the local, state, tribal, territorial, and 
private and nonprofit sectors, including businesses, faith-based and 
disability organizations, and the general public. Focusing 
jurisdictions on outcome-based planning that is specific to their 
respective threats and capabilities provides for a more useful 
understanding of specific needs that communities will face given the 
risks they view as a high priority. 

Neither DHS nor FEMA believes this recommendation takes into 
sufficient account the significant advances made in the preparedness 
system linking capability investments to risk analysis, including the 
Regional Threat Identification and Hazard Analysis (THIRA) and
Strategic National Risk Assessment. For example, while the report 
acknowledged that state and local officials ranked the RDD and IND 
risks as lower compared to other hazards, the report did not 
adequately highlight that none of the to FEMA regional THIRAs 
identified ROD attacks as a hazard. 

In addition, FEMA program officials and subject matter experts believe 
the recommendation does not align with GAO's survey results nor is it 
reflective of all-hazard risk management for worst case catastrophic 
scenarios. FEMA also has concerns with the report's characterization of
the Nation's capability to respond to a nuclear and/or radiological 
attack, since the report does not: 

* Demonstrate or show how the suggested recommendation supported the 
implementation of PPD-8 and the National Preparedness Goal from a risk-
based perspective. 

* Include a qualitative or quantitative assessment of risk, but rather 
significant portions of the analysis provided seem only to have been 
based on opinion. 

* Reflect overall preparedness justifications that guide planning 
activities to risks identified as higher priority by the 
jurisdictions, but seems focused on survey results that show a
relatively low ranking for RDD threats. 

* Fully assess the degree to which other related mission frameworks 
are being used but instead focuses on Response. For example, it would 
seem to be a high priority to assess and/or influence the use of the 
Prevention or Protection mission areas. Stopping what is a low 
probability-but conceivably high-consequence---event should be 
considered as a higher priority than focusing only on Response. 

It is also not clear how the recommendation best supports the 
implementation of the all-hazards preparedness and planning systems 
established under PPD-8 or how it provides an increased value 
proposition to the continued successful improvement to National 
Preparedness as structured by the associated National Preparedness 
Goal and System. The recommendation also seems to run contrary to the 
survey results from state and local officials whose responses
illustrate a trend of grouping RDD and IND attacks for analysis and 
planning. Therefore, it seems that re-writing and incorporating the 
comprehensive elements of the NRF contingencies into a single document 
specifically designed for RDD would be counterproductive, as the
appropriate source of planning and readiness guidance should be 
derived from the existing planning and guidance structure for all-
hazards and IND incidents (i.e., the appropriate maximum-of-maximum 
scenario for catastrophic incident planning). DHS requests that GAO
consider this recommendation resolved and closed. 

Again, thank you for the opportunity to review and comment on the 
draft report. Technical comments were previously provided under 
separate cover. Please feel free to contact me if you have any 
questions. We look forward to working with you in the future. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David C. Trimble (202) 512-3841 or t [Hyperlink, trimbled@gao.gov] 
rimbled@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Ned Woodward, Assistant 
Director; Cheryl Arvidson; Thomas Laetz; Eli Lewine; David Lysy; Mike 
Silver; Kathy Smith; and Kiki Theodoropoulos made key contributions to 
this report. 

[End of section] 

Footnotes: 

[1] RDDs and INDs are considered weapons of mass destruction, along 
with chemical and biological weapons. See 18 U.S.C. § 2332a(c); 6 
U.S.C. § 485(a)(6). 

[2] Fissile material is composed of atoms that can be split by 
neutrons in a self-sustaining chain reaction to release enormous 
amounts of energy. In nuclear weapons, the fission energy is released 
all at once to produce a violent explosion. The primary fissile 
materials are plutonium and uranium. 

[3] The term "response," refers to those capabilities necessary to 
save lives, protect property and the environment, and meet basic human 
needs after an incident has occurred. 

[4] National Science and Technology Council, Nuclear Defense Research 
and Development Roadmap, Fiscal Years 2013-2017 (Washington, D.C.: 
Executive Office of the President, April 2012). 

[5] The White House, Presidential Policy Directive/PPD-8: National 
Preparedness (Washington, D.C.: Mar. 30, 2011). DHS, National 
Preparedness Report (Washington, D.C.: Mar. 30, 2012). 

[6] An incident is an occurrence or event--natural, technological, or 
human-caused--that requires a response to protect life, property, or 
the environment. 

[7] DHS, National Preparedness Goal, First Edition (Washington, D.C.: 
September 2011). 

[8] The FIOP is intended to provide a detailed concept of operations, 
description of critical tasks and responsibilities, detailed 
resources, personnel, and sourcing requirements, and specific 
provisions for the delivery of capabilities by the federal government. 

[9] DHS, National Preparedness System (Washington, D.C.: November 
2011). 

[10] DHS, National Planning Scenarios (Washington, D.C.: March 2006). 
The planning scenarios include a large IND attack; biological attack-
aerosol anthrax; biological disease outbreak-pandemic influenza; 
biological attack-plague; chemical attack-blister agent; chemical 
attack-toxic industrial chemicals; chemical attack-nerve agent; 
chemical attack-chlorine tank explosion; natural disaster-major 
earthquake; natural disaster-major hurricane; radiological attack-RDD; 
explosive attack-bombing using improvised explosive device; biological 
attack-food contamination; biological attack-foreign animal disease 
(e.g., foot-and-mouth disease); and cyber attack. 

[11] DHS, National Incident Management System (Washington, D.C.: 
December 2008). This document is an update from the original 2004 
publication. 

[12] FEMA accomplishes this responsibility through the Federal 
Radiological Preparedness Coordinating Committee. The federal response 
mechanisms include the Emergency Support Functions and supporting 
annexes to the National Response Framework, and existing emergency 
response plans that address nuclear and radiological incidents. 

[13] Generally, DOD resources are committed only after approval by the 
Secretary of Defense or at the direction of the President. 

[14] The 31 major cities supported by the fiscal year 2012 Urban Areas 
Security Initiative program are Anaheim, Atlanta, Baltimore, Boston, 
Charlotte, Chicago, Dallas, Denver, Detroit, Houston, Indianapolis, 
Kansas City, Las Vegas, Los Angeles, Miami, Minneapolis, Newark, New 
Orleans, New York City, Orlando, Philadelphia, Phoenix, Portland (OR), 
Riverside, San Antonio, San Diego, San Francisco, Seattle, St. Louis, 
Tampa, and the District of Columbia. We were unable to contact 
emergency managers in two cities, Atlanta and Newark. 

[15] Jonathan Medalia, "Dirty Bombs": Technical Background, Attack 
Prevention and Response, Issues for Congress (Washington, D.C.: 
Congressional Research Service, June 24, 2011). 

[16] FEMA, Regional Planning Guide (Washington, D.C: March 2010), 
FEMA, Developing and Maintaining Emergency Operations Plans: 
Comprehensive Preparedness Guide (CPG) 101, Version 2.0 (Washington, 
D.C.: November 2010). 

[17] DHS, National Preparedness System (Washington, D.C.: November 
2011). 

[18] DHS, "Planning Guidance for Protection and Recovery Following 
Radiological Dispersal Device (RDD) and Improvised Nuclear Device 
(IND) Incidents (73 Fed. Reg. 45-029 (Aug. 1, 2008); and National 
Security Staff Interagency Policy Coordination Subcommittee for 
Preparedness & Response to Radiological and Nuclear Threats, Planning 
Guidance for Response to a Nuclear Detonation, Second Edition 
(Washington, D.C.: June 2010). 

[19] National Council on Radiation Protection and Measurements, 
Responding to a Radiological or Nuclear Terrorism Incident: A Guide 
for Decision Makers, Report No. 165 (Bethesda, MD: 2010); Conference 
on Radiation Control Program Directors, Inc., Responding to a 
Radiological Dispersal Device: First Responder's Guide--The First 12 
Hours (Frankfort, KY: September 2006); and Schoch-Spane, et al., Rad 
Resilient City: A Preparedness Checklist for Cities to Diminish Lives 
Lost From Radiation after a Nuclear Terrorist Attack (Baltimore, MD: 
Center for Biosecurity of UPMC, September 2011). 

[20] According to FEMA officials and some city emergency managers we 
spoke with, the Hazard Identification and Vulnerability Assessment is 
also referred to as a Hazard Identification and Risk Assessment by 
some cities. They stated that both titles refer to the same type of 
document. Many of the major cities are adopting a new process, the 
Threat and Hazard Identification and Risk Assessment that FEMA 
requires its regional offices, states, and Urban Areas Security 
Initiative locations to use. 

[21] In accordance with the National Incidence Management System, a 
response plan is to address the tactics and support activities 
required for the planned operational period, generally the first 12 to 
24 hours after the event. 

[22] FEMA, Nationwide Plan Review: Fiscal Year 2010 Report to Congress 
(Washington, D.C.: July 2010). FEMA reviewed emergency operations 
plans for 75 major cities, which include the 27 cities that responded 
to our questionnaire. 

[23] This question requested a self-assessment because FEMA currently 
uses self-assessments to gauge local response capabilities and has not 
yet developed performance measures to determine actual levels of 
capability for incident response. 

[24] DHS, "Planning Guidance for Protection and Recovery Following 
Radiological Dispersal Device (RDD) and Improvised Nuclear Device 
(IND) Incidents" (73 Fed. Reg. 45-029, Aug. 1, 2008). 

[25] DHS, "Nuclear/Radiological Incident Annex" to the National 
Response Framework (Washington, D.C.: June 2008). According to a FEMA 
official, FEMA intends to replace this 2008 annex with the nuclear and 
radiological annex under consideration and, because this new annex 
will be more of an operational guide, it will be annexed to the all 
hazards FIOPs for the response and recovery missions. 

[26] DHS, Emergency Support Function #10--Oil and Hazardous Materials 
Response Annex to the National Response Framework (Washington, D.C.: 
May 2013). 

[27] DHS, "Planning Guidance for Protection and Recovery Following 
Radiological Dispersal Device (RDD) and Improvised Nuclear Device 
(IND) Incidents" (73 Fed. Reg. 45-029, Aug. 1, 2008). 

[28] The RDD attack depicted in the National Planning Scenario would 
contaminate 36 city blocks, causing 180 fatalities, 270 injuries, and 
20,000 detectable contaminations, requiring 10,000 people to seek 
shelters and prompting hundreds of thousands to self-evacuate in 
anticipation of future attacks. 

[29] The IND attack depicted in the National Planning Scenario would 
contaminate up to 3,000 square miles, causing hundreds of thousands 
casualties and damage up to a radius of .5 to 3 miles, requiring 
100,000 people to seek shelter after being decontaminated and 
prompting 1 million to self-evacuate from the city. 

[30] DHS, Interim IND CONPLAN: Federal Interagency Improved Nuclear 
Device Concept of Operations Plan, Version 10 (Washington, D.C.: Nov. 
17, 2009). 

[31] National Security Staff, DHS, Planning Guidance for Response to a 
Nuclear Detonation, Second Edition (Washington, D.C. Interagency 
Policy Coordinating Subcommittee for Preparedness & Response to 
Radiological and Nuclear Threats, June 2010). 

[32] Planning guidance recommendations were provided for consideration 
by emergency planners within the first days after an IND attack for 1) 
shelter and evacuation, 2) medical care, 3) population monitoring and 
decontamination, and 4) emergency public information. 

[33] GAO, Managing Preparedness Grants and Assessing National 
Capabilities: Continuing Challenges Impede FEMA's Progress, 
[hyperlink, http://www.gao.gov/products/GAO-12-526T] (Washington, 
D.C.: Mar. 20, 2012). 

[34] DHS, Response and Recovery Knowledge Product: Key Planning 
Factors for Recovery from a Radiological Terrorism Incident 
(Washington, D.C.: September 2012). 

[35] FEMA, Developing and Maintaining Emergency Operations Plans: 
Comprehensive Preparedness Guide (CPG) 101, Version 2.0 (Washington, 
D.C.: November 2010). 

[36] FEMA, Improvised Nuclear Device Regional Operations Plan: Region 
V, State of Illinois, and City of Chicago Operations Plan (Chicago, 
IL: June 2012). 

[37] Public health and medical services provide lifesaving medical 
treatment and provide support and products to avoid additional disease 
and injury. Operational coordination establishes and maintains a 
unified and coordinated operational structure. On-scene security and 
protection ensures a safe and secure environment through law 
enforcement and other operations. 

[38] We developed the list of current federal IND focus areas from the 
following two DHS reports: DHS, DHS Strategy for Improving the 
National Response and Recovery from an IND Attack (Washington, D.C.: 
March 24, 2010) and DHS, Improvised Nuclear Device Response and 
Recovery Capability-Based Implementation Plan: Methods, Plans, and 
Projects for Addressing the Capability Gaps Identified in the DHS 
Strategy for Improving the National Response and Recovery from an IND 
Attack (Washington, D.C.: March 2012), and the Executive Office of the 
President, National Science and Technology Council, Nuclear Defense 
Research and Development Roadmap, Fiscal Years 2013-2017 (Washington, 
D.C.: April 2012). 

[39] The six IND focus area working groups are the Manage the 
Response, Crisis Decision-making, Communications and Public Messaging, 
Scientific Support, Public Health and Medical, and Recovery. Multiple 
federal agencies participate in these focus area working groups along 
with members from state and local emergency management offices and 
first responders (fire, police, emergency medical services, and public 
work officials). Nongovernment organizations such as medical 
practitioners, ethicists, clergy, biologists, sociologists, and 
university and private industry representatives also participate. 

[40] The seven DHS grant programs are the Homeland Security Grant 
Program, Emergency Management Performance Grants Program, Tribal 
Homeland Security Grant Program, Nonprofit Security Grant Program, 
Intercity Passenger Rail (Amtrak) Program, Port Security Grant 
Program, and the Transit Security Grant Program. From fiscal years 
2002 through 2011, the federal government appropriated over $37 
billion to DHS's preparedness grant programs to enhance the 
capabilities of state and local governments to prevent, protect 
against, respond to, and recover from terrorist attacks. 

[41] FEMA could query its Biannual Strategy Implementation Report 
database to determine the level of funding used for the general 
category of chemical, biological, radiological, nuclear, and 
explosives. 

[42] From 2007 through 2011 the Regional Catastrophic Planning Grant 
Program provided more than $147 million in funding. The Regional 
Catastrophic Preparedness Grant Program Comprehensive Report, February 
2012 lists 10 sites as receiving this funding including the San 
Francisco Bay Area, Boston, Chicago, Hampton Roads (24 jurisdictions 
in southeast Virginia and northeast North Carolina), Honolulu, 
Houston, Los Angeles, the National Capital Region, New York/New 
Jersey/Connecticut/Pennsylvania, and the Puget Sound region (8 
Washington state counties and their associated cities). 

[43] The 31 major cities in the UASI program in fiscal year 2012 were 
Anaheim, Atlanta, Baltimore, Boston, Charlotte, Chicago, Dallas, 
Denver, Detroit, Houston, Indianapolis, Kansas City, Las Vegas, Los 
Angeles, Miami, Minneapolis, Newark, New Orleans, New York City, 
Orlando, Philadelphia, Phoenix, Portland (OR), Riverside, San Antonio, 
San Diego, San Francisco, Seattle, St. Louis, Tampa, and the District 
of Columbia. 

[44] The questionnaire is reproduced in full in appendix II. 

[45] Three cities, Tampa, Philadelphia, and Los Angeles, did not 
receive e-mail notifications because they responded later than other 
cities to our initial contact attempts. They instead received by e-
mail the cover letter and questionnaire on the same days in late 
December 2012 that they responded to us. 

[End of section] 

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