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Communication Principles Can Assist in Refining the Advisory System' 
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Report to Congressional Requesters: 

June 2004: 

HOMELAND SECURITY: 

Communication Protocols and Risk Communication Principles Can Assist in 
Refining the Advisory System: 

GAO-04-682: 

GAO Highlights: 

Highlights of GAO-04-682, a report to congressional requesters

Why GAO Did This Study: 

Established in March 2002, the Homeland Security Advisory System was 
designed to disseminate information on the risk of terrorist acts to 
federal agencies, states, localities, and the public. However, these 
entities have raised questions about the threat information they 
receive from the Department of Homeland Security (DHS) and the costs 
they incurred as a result of responding to heightened alerts. This 
report examines (1) the decision making process for changing the 
advisory system national threat level; (2) information sharing with 
federal agencies, states, and localities, including the applicability 
of risk communication principles; (3) protective measures federal 
agencies, states, and localities implemented during high (code-orange) 
alert periods; (4) costs federal agencies reported for those periods; 
and (5) state and local cost information collected by DHS.

What GAO Found: 

DHS assigns threat levels for the entire nation and assesses threat 
conditions for geographic regions and industrial sectors based on 
analyses of threat information and vulnerability of potential terrorist 
targets. 

DHS has not yet officially documented its protocols for communicating 
threat level changes and related threat information to federal agencies 
and states. Such protocols could assist DHS to better manage these 
entities’ expectations about the methods, timing, and content of 
information received from DHS. To ensure early, open, and comprehensive 
information dissemination and allow for informed decisionmaking, risk 
communication experts suggest that warnings should include (1) multiple 
communication methods, (2) timely notification, and (3) specific threat 
information and guidance on actions to take. Federal agencies and 
states responding to GAO’s questionnaires sent to 28 federal agencies 
and 56 states and territories generally indicated that they did not 
receive specific threat information and guidance, which they believe 
hindered their ability to determine and implement protective measures. 

The majority of federal agencies reported operating at heightened 
security levels regardless of the threat level, and thus, did not need 
to implement a substantial number of additional measures to respond to 
code-orange alerts. States reported that they varied in their actions 
during code-orange alerts.

The costs reported by federal agencies, states, and selected localities 
are imprecise and may be incomplete, but provide a general indication 
of costs that may have been incurred. Additional costs reported by 
federal agencies responding to GAO’s questionnaire were generally less 
than 1 percent of the agencies’ fiscal year 2003 homeland security 
funding. DHS collected information on costs incurred by states and 
localities for critical infrastructure protection during periods of 
code-orange alert. However, this information does not represent all 
additional costs incurred by these entities during the code-orange 
alert periods.

Homeland Security Advisory System: 

[See PDF for image]

[End of figure]

What GAO Recommends: 

The Under Secretary for Information Analysis and Infrastructure 
Protection in DHS should (1) document communication protocols for 
sharing threat information and (2) incorporate risk communication 
principles into the Homeland Security Advisory System to assist in 
determining and documenting information to provide to federal agencies 
and states. We provided a draft copy of this report to DHS for 
comment. DHS generally concurred with the findings and recommendations 
in the report.

www.gao.gov/cgi-bin/getrpt? GAO-04-682

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact William Jenkins at (202) 
512-8777 or jenkinswo@gao.gov.

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

Threat Information and Vulnerability of Potential Targets Inform 
National and Sector-or Location-Specific Threat Level Decisions: 

Risk Communication Principles Can Be Useful in Communicating Threat 
Information and Guidance to Federal Agencies and States: 

Federal Agencies Reported Implementing Few New Protective Measures for 
Code-Orange Alerts because They Always Operate at High Security Levels, 
While States Varied Their Responses: 

Costs Reported by Federal Agencies, though Limited, Suggest a Decline 
in Additional Costs: 

Cost Data Collected by DHS and Data Reported by Others Cannot be 
Generalized: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendixes: 

Appendix I: Federal Agencies', States', Localities', and Foreign 
Countries' Threat Advisory Systems: 

Federal Agencies' Threat Advisory Systems: 

States' and Localities' Threat Advisory Systems: 

Foreign Countries' Systems: 

Appendix II: Scope and Methodology: 

Appendix III: Guidance and Information Federal Agencies and States 
Reported Using to Determine Protective Measures: 

Appendix IV: Most Commonly Implemented Protective Measures, Measures 
Tested, and Methods of Confirmation: 

Appendix V: Cost Information Provided by Federal Agencies, States, and 
Localities: 

Cost Information Provided by Federal Agencies: 

Cost Information Provided by States: 

Cost Information Provided by Localities: 

Appendix VI: Acknowledgment of Agency and Government Contributors: 

Federal Agencies: 

States and Territories: 

Localities: 

Appendix VII: Federal Agency Questionnaire: 

Appendix VIII: State and Territory Questionnaire: 

Appendix IX: Agency Comments: 

Appendix X: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Staff Acknowledgments: 

Bibliography: 

Tables: 

Table 1: Number of Federal Agencies and States Responding to Our 
Questionnaires that Reported Receiving Direct Notification from DHS and 
Reported Being Notified through Multiple Methods for the Three Code-
Orange Alert Periods: 

Table 2: Number of Federal Agencies and States That Reported Receiving 
Types of Information with Notification from DHS for the Three Code-
Orange Alert Periods: 

Table 3: Number of Federal Agencies That Indicated Specific Types of 
Information That Would Have Been Helpful to Determine Measures to Take 
for the Code-Orange Alert Period from December 21, 2003, to January 9, 
2004: 

Table 4: Number of States That Indicated Specific Types of Information 
That Would Have Been Helpful to Determine Measures to Take for the 
Code-Orange Alert Period from December 21, 2003, to January 9, 2004: 

Table 5: Number of States That Indicated DHS Requested Information on 
Protective Measures Taken by the State in Response to the Three Code-
Orange Alert Periods: 

Table 6: Number of Federal Agencies That Used Guidance from Sources and 
Found It Useful and Timely for the Code-Orange Alert Period December 
21, 2003, to January 9, 2004: 

Table 7: Number of Federal Agencies That Used Information and 
Intelligence from Sources and Found It Useful and Timely for the Code-
Orange Alert Period December 21, 2003, to January 9, 2004: 

Table 8: Number of States That Used Guidance from Sources and Found It 
Useful and Timely for the Code-Orange Alert Period December 21, 2003, 
to January 9, 2004: 

Table 9: Number of States That Used Information and Intelligence from 
Sources and Found It Useful and Timely for the Code-Orange Alert Period 
December 21, 2003, to January 9, 2004: 

Table 10: Protective Measures Most Commonly Reported by Federal 
Agencies Responding to Our Questionnaire for the December 21, 2003, to 
January 9, 2004, Code-Orange Alert Period: 

Table 11: Protective Measures Most Commonly Reported by States 
Responding to Our Questionnaire for the December 21, 2003, to January 
9, 2004, Code-Orange Alert Period: 

Table 12: Number of Federal Agencies and States That Reported 
Conducting Tests or Exercises on the Functionality and Reliability of 
Protective Measures: 

Table 13: Number of Federal Agencies and States That Reported Receiving 
Confirmation on the Implementation of Protective Measures through 
Various Methods for the Code-Orange Alert Period from December 21, 
2003, to January 9, 2004: 

Table 14: Number of Federal Agencies That Provided Cost Information and 
the Type of Cost Information They Provided for Each Code-Orange Alert 
Period under Review: 

Figure: 

Figure 1: London Metropolitan Police Antiterror Alert Poster: 

Abbreviations: 

CDC: Centers for Disease Control: 

DHS: Department of Homeland Security: 

DOD: Department of Defense: 

FBI: Federal Bureau of Investigation: 

FEMA: Federal Emergency Management Agency: 

FPS: Federal Protective Service: 

HSOC: Homeland Security Operations Center: 

HSPD: Homeland Security Presidential Directive: 

IAIP: Information Analysis and Infrastructure Protection: 

ODP: Office of Domestic Preparedness: 

OMB: Office of Management and Budget: 

SHSGP: State Homeland Security Grant Program: 

UASI: Urban Areas Security Initiative: 

Letter June 25, 2004: 

The Honorable Christopher Cox: 
Chairman: 
The Honorable Jim Turner: 
Ranking Minority Member: 
Select Committee on Homeland Security: 
House of Representatives: 

The Honorable Joseph R. Biden, Jr.: 
United States Senate: 

The Homeland Security Advisory System was established in March 2002 to 
disseminate information regarding the risk of terrorist acts to federal 
agencies, states and localities, and the public utilizing five color-
coded threat levels. Implementation of this system generated questions 
among government agencies regarding whether they were receiving the 
information necessary to respond appropriately when the national threat 
level was raised and about the costs resulting from additional 
protective measures implemented during periods of heightened alert.

You asked us to review several aspects about how the Department of 
Homeland Security (DHS) was operating the Homeland Security Advisory 
System including federal, state, and local responses to heightened 
alerts. This report discusses (1) the decision-making process for 
changing the national threat level; (2) guidance and other information 
provided to federal agencies, states, and localities, including the 
applicability of risk communication[Footnote 1] principles to 
information sharing;[Footnote 2] (3) protective measures federal 
agencies, states, and localities implemented during high--code-orange-
-alert periods; (4) additional costs federal agencies reported for 
implementing such measures; and (5) information DHS collected on costs 
states and localities reported for periods of code-orange alert. In 
addition, this report provides information on other threat advisory 
systems used by federal agencies, states, localities, and other 
countries. (See app. I.) 

To respond to your request, we met with and obtained information from 
DHS officials on the decision-making process for changing the national 
threat level; guidance and threat information the department provides 
to federal agencies, states, and localities; and information on 
protective measures and costs that the department collected from states 
and localities. We also examined literature on risk communication 
principles to identify the applicability of such principles to the 
Homeland Security Advisory System. In addition, we sent questionnaires 
to 28 federal agencies and the homeland security or emergency 
management offices in 50 states, the District of Columbia, American 
Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. 
Virgin Islands, regarding the notification and information these 
entities received, the protective measures they took, and the costs 
they reported for the three code-orange alert periods from March 17 to 
April 16, 2003; May 20 to 30, 2003; and December 21, 2003, to January 
9, 2004. Although some federal agencies and states did not respond to 
every question in our questionnaires, we received responses from 26 
federal agencies, which account for about 99 percent of total fiscal 
year 2003 nondefense homeland security funding as reported to the 
Office of Management and Budget (OMB),[Footnote 3] and 43 
states,[Footnote 4] for a 77 percent response rate. We selected the 28 
federal agencies because they reported receiving homeland security 
funding for fiscal year 2003 to OMB and are Chief Financial Officers 
Act agencies.[Footnote 5] For this review, we analyzed information from 
the District of Columbia, American Samoa, Guam, the Northern Mariana 
Islands, Puerto Rico, and the U.S. Virgin Islands along with 
information from states, and we refer to all of these throughout the 
report as states.

To obtain information on localities' experiences during code-orange 
alerts, we conducted site visits with officials from 12 localities (8 
cities and 4 counties).[Footnote 6] We selected the 12 localities to 
visit based on the following criteria: (1) their receipt of grants from 
DHS; (2) their geographic location and topography (e.g., inland, 
border, or seaport); and (3) the type of locality (e.g., metropolitan 
and nonmetropolitan areas).[Footnote 7] We also sent a questionnaire to 
8 additional localities,[Footnote 8] selecting them based on population 
and geographic location. We received questionnaire responses from 4 of 
these localities.[Footnote 9] We used information obtained from the 16 
localities we visited or from which we received questionnaire responses 
only as anecdotal examples, as information from these localities cannot 
be generalized across all localities in the United States.

DHS has not documented the policies and procedures it has used for 
assessing intelligence information, determining whether to raise or 
lower the threat level, and notifying federal agencies, states, and 
localities about changes in threat levels. Thus, the information 
provided about the operations of the Homeland Security Advisory System 
is principally based on interviews with DHS officials and questionnaire 
responses. We conducted our work from July 2003 to May 2004 in 
accordance with generally accepted government auditing standards. For 
more detailed information on our scope and methodology, see appendix 
II.

Results in Brief: 

In administering the Homeland Security Advisory System, DHS assigns 
national threat levels and assesses threat conditions for specific 
geographic locations and industrial sectors. The national threat level 
is assigned by the Secretary of Homeland Security, in consultation with 
members of the Homeland Security Council,[Footnote 10] based on 
analysis of intelligence information and assessment of the 
vulnerability of potential terrorist targets. DHS also uses analysis of 
threat information and assessments of the vulnerability of terrorist 
targets to determine whether specific industrial sectors or geographic 
regions should operate at heightened levels of security. DHS may 
encourage sectors or geographic regions to operate at heightened levels 
of security, without publicly announcing a threat.

DHS has not yet officially documented communication protocols for 
providing threat information and guidance to federal agencies and 
states. According to DHS officials, it has been difficult to develop 
protocols for notifying federal agencies and states of changes in the 
national threat level that provide sufficient flexibility for sharing 
information in a variety of situations. Communication protocols can 
assist DHS in better managing the expectations of federal agencies and 
states regarding the guidance and threat information they receive from 
the department. Risk communication experts suggest that threat warnings 
should include the following principles to ensure early, open, and 
comprehensive information dissemination and to allow for informed 
decisionmaking: (1) communication through multiple methods, (2) timely 
notification, and (3) specific threat information and guidance on 
actions to take. These principles have primarily been used in public 
warning contexts, but they are also applicable for communicating 
terrorist threat information to federal agencies and states through the 
Homeland Security Advisory System. DHS used multiple methods to 
communicate threat information to federal agencies and states when the 
national threat level was raised to code-orange. However, many federal 
agencies and states responding to our questionnaires reported first 
learning about changes in the national threat level from media sources. 
As a result, some of these states indicated that their ability to 
provide credible information to state and local agencies and the public 
was hampered. Moreover, federal agencies and states responding to our 
questionnaires indicated that they generally did not receive specific 
threat information and guidance, which they believed hindered their 
ability to determine whether they were at risk as well as their ability 
to determine and implement appropriate protective measures.

The majority of federal agencies responding to our questions regarding 
protective measures reported that they regularly operate at high levels 
of security and did not have to implement a substantial number of 
additional measures to respond to code-orange alerts. For the most 
part, these federal agencies reported that their most common response 
to code-orange alert periods was to enhance existing protective 
measures, for example, an increase in the frequency of facility 
security patrols. To a lesser extent, federal agencies reported they 
maintained the use of existing protective measures without enhancement, 
for example, continuing the use of intrusion detection systems during 
code-orange alerts. However, based on responses to our questionnaire, 
states varied in the extent to which they enhanced or maintained 
protective measures already in place, or implemented measures solely in 
response to the three code-orange alert periods. States indicated that 
various factors, such as specific threat information received by the 
state, influenced the extent to which they implemented protective 
measures. While federal agencies and states responding to our 
questionnaires reported benefiting by implementing various protective 
measures during code-orange alerts, they also indicated that taking 
such actions adversely affected their operations, and they identified 
several operational challenges. For example, while these federal 
agencies and states reported that protective measures taken during 
code-orange alerts promoted employees' sense of security, they also 
said that the lack of federal governmentwide coordination, such as 
multiple government agencies providing conflicting information to 
states regarding protective measures, limited their ability to 
effectively coordinate and, therefore, implement measures.

Code-orange alert cost data provided by federal agencies responding to 
our questionnaire are not precise, may not include all additional costs 
incurred by agencies, and, in some cases, we have concerns about the 
reliability of the cost data source within particular agencies. Despite 
these limitations, we believe the cost data to be sufficiently reliable 
as indicators of general ranges of cost and overall trends. However, 
the data should not be used to determine the cumulative costs incurred 
across all federal agencies. The total additional costs reported by 
federal agencies responding to our questionnaire for the March 17 to 
April 16, 2003, and May 20 to 30, 2003, code-orange alert periods were 
less than 1 percent of these agencies' fiscal year 2003 homeland 
security funding, as reported by agencies to OMB.[Footnote 11] On the 
basis of cost information reported by these federal agencies for the 
three code-orange alert periods in our review, we calculated additional 
average daily costs ranging from about $190 to about $3.7 million. 
Independent federal agencies typically reported the least amount of 
additional costs, while larger cabinet level agencies with 
responsibility for protecting critical national infrastructure 
reported the most additional costs. The majority of federal agencies 
responding to our questionnaire experienced a decline in additional 
average daily costs between the March 17 to April 16, 2003, and the 
December 21, 2003, to January 9, 2004, code-orange alert periods, which 
some of these agencies attributed to continued enhancement of standard 
levels of security. Some federal agencies responding to our 
questionnaire reported that they did not incur any additional costs 
during code-orange alert periods, because they did not implement any 
additional protective measures or they redirected already existing 
resources to implement additional code-orange alert measures rather 
than employ additional resources.[Footnote 12] Although some federal 
agencies reported not incurring additional costs directly as a result 
of implementing protective measures for code-orange alerts, actions 
taken such as redirecting resources from normal operations may have 
resulted in indirect costs.

DHS collected information on critical infrastructure protection costs 
states and localities reported incurring during the March 17 to April 
16, 2003, May 20 to 30, 2003, and December 21, 2003, to January 9, 
2004, code-orange alert periods through its State Homeland Security 
Grant Program - Part II and the Urban Areas Security Initiative - Part 
II. However, this cost information does not represent all additional 
costs incurred by states and their localities during code-orange alert 
periods. The U.S. Conference of Mayors also collected and reported 
estimates of costs localities incurred in response to code-orange 
alerts. Additionally, a Director with the Center for Strategic and 
International Studies estimated and reported costs incurred by federal 
agencies during code-orange alerts. However, because of limitations in 
the scope and methodologies used in these estimates, the cost 
information reported may not be adequate for making generalizations 
regarding additional costs federal agencies, states and localities 
incurred in response to code-orange alerts.

In this report, we make specific recommendations to the Secretary of 
Homeland Security regarding documentation of communication protocols to 
assist DHS in better managing federal agencies' and states' 
expectations regarding the methods, timing, and content of threat 
information and guidance provided to these entities and to ensure that 
DHS follows clear and consistent policies and procedures when 
interacting with these entities through the Homeland Security Advisory 
System. We also make a recommendation to the Secretary to incorporate 
risk communication principles into the Homeland Security Advisory 
System, including information on the nature, location, and time periods 
of threats and guidance on protective measures to take.

Background: 

Homeland Security Presidential Directive 3 (HSPD-3) established the 
Homeland Security Advisory System in March 2002. Through the creation 
of the Homeland Security Advisory System, HSPD-3 sought to produce a 
common vocabulary, context, and structure for an ongoing discussion 
about the nature of threats that confront the nation and the 
appropriate measures that should be taken in response to those threats. 
Additionally, HSPD-3 established the Homeland Security Advisory System 
as a mechanism to inform and facilitate decisions related to securing 
the homeland among various levels of government, the private sector, 
and American citizens.

The Homeland Security Advisory System is comprised of five color-coded 
threat conditions as described below, which represent levels of risk 
related to potential terror attack.

* Code-red or severe alert--severe risk of terrorist attacks.

* Code-orange or high alert--high risk of terrorist attacks.

* Code-yellow or elevated alert--significant risk of terrorist attacks.

* Code-blue or guarded alert--general risk of terrorist attacks.

* Code-green or low alert--low risk of terrorist attacks.

As defined in HSPD-3, risk includes both the probability of an attack 
occurring and its potential gravity.

Since its establishment in March 2002, the Homeland Security Advisory 
System national threat level has remained at elevated alert--code-
yellow--except for five periods during which the administration raised 
it to high alert--code-orange. The periods of code-orange alert follow: 

* September 10 to 24, 2002;

* February 7 to 27, 2003;

* March 17 to April 16, 2003;

* May 20 to 30, 2003; and: 

* December 21, 2003, to January 9, 2004.

The Homeland Security Advisory System is binding on the executive 
branch. HSPD-3 directs all federal departments, agencies, and offices, 
other than military facilities,[Footnote 13] to conform their existing 
threat advisory systems to the Homeland Security Advisory System. These 
agencies are responsible for ensuring their systems are consistently 
implemented in accordance with national threat levels as defined by the 
Homeland Security Advisory System. Additionally, federal departments 
and agency heads are responsible for developing protective measures and 
other antiterrorism or self-protection and continuity plans in response 
to the various threat levels and operating and maintaining these plans. 
While HSPD-3 encourages other levels of government and the private 
sector to conform to the system, their compliance is voluntary.

When HSPD-3 first established the Homeland Security Advisory System, it 
provided the Attorney General with responsibility for administering the 
Homeland Security Advisory System, including assigning threat 
conditions in consultation with members of the Homeland Security 
Council, except in exigent circumstances. As such, the Attorney General 
could assign threat levels for the entire nation, for particular 
geographic areas, or for specific industrial sectors. Upon its 
issuance, HSPD-3 also assigned responsibility to the Attorney General 
for establishing a process and a system for conveying relevant threat 
information expeditiously to federal, state, and local government 
officials, law enforcement authorities, and the private sector.

In November 2002, Congress passed the Homeland Security Act of 2002, 
P.L. 107-296, which established the Department of Homeland Security. 
Under the Homeland Security Act of 2002, the DHS Under Secretary for 
Information Analysis and Infrastructure Protection (IAIP) is 
responsible for administering the Homeland Security Advisory System. As 
such, the Under Secretary for IAIP is primarily responsible for issuing 
public threat advisories and providing specific warning information to 
state and local governments and to the private sector.[Footnote 14] The 
act also charges the Under Secretary for IAIP with providing advice 
about appropriate protective actions and countermeasures.[Footnote 15]

In February 2003, in accordance with the Homeland Security Act, the 
administration issued Homeland Security Presidential Directive 5 (HSPD-
5), which amended HSPD-3 by transferring authority for assigning threat 
conditions and conveying relevant information from the Attorney General 
to the Secretary of Homeland Security. HSPD-5 directs the Secretary of 
Homeland Security to consult with the Attorney General and other 
federal agency heads the Secretary deems appropriate, including other 
members of the Homeland Security Council, when determining the threat 
level, except in exigent circumstances.

Threat Information and Vulnerability of Potential Targets Inform 
National and Sector-or Location-Specific Threat Level Decisions: 

In implementing the Homeland Security Advisory System, DHS assigns 
national threat levels and assesses the threat condition of specific 
geographic locations and industrial sectors. While the national threat 
level has been raised and lowered for five periods, DHS officials told 
us that the department has not yet assigned a threat level for an 
industrial sector or geographic location.[Footnote 16] However, DHS 
officials said that the department has encouraged specific sectors and 
regions to operate at heightened levels of security. According to DHS 
officials, decisions to change the national threat level and to 
encourage specific sectors and regions to operate at heightened levels 
of security involve both analysis and sharing of threat information, as 
well as an assessment of the vulnerability of national critical 
infrastructure assets that are potential targets of terrorist threats.

DHS officials told us they use the criteria in HSPD-3 in determining 
whether to raise the national threat level or whether to suggest that 
certain regions or sectors operate at heightened security levels. These 
criteria include: 

* the credibility of threat information;

* whether threat information is corroborated;

* the degree to which the threat is specific and/or imminent; and: 

* the gravity of the potential consequences of the threat.

In determining whether these criteria are met and whether to raise the 
national threat level, DHS considers intelligence information and the 
vulnerability of potential targets, among other things. DHS officials 
told us that they use a flexible, "all relevant factors" approach to 
decide whether to raise or lower the national threat level or whether 
to suggest that certain regions or sectors operate at heightened 
security levels. They said that analysis of available threat 
information and determination of national threat levels and regional 
and sector threat conditions are specific for each time period and 
situation. According to these officials, given the nature of the data 
available for analysis, the process and analyses used to determine 
whether to raise or lower the national threat level or suggest that 
specific regions or sectors heighten their protective measures are 
inherently judgmental and subjective.

DHS officials said that the intelligence community continuously gathers 
and analyzes information regarding potential terrorist activity. This 
includes information from such agencies as DHS,[Footnote 17] the 
Central Intelligence Agency, the Federal Bureau of Investigation (FBI), 
and the Terrorist Threat Integration Center,[Footnote 18] as well as 
from state and local law enforcement officials. DHS officials also 
noted that analyses from these and other agencies are shared with DHS's 
IAIP, which is engaged in constant communication with intelligence 
agencies to assess potential homeland security threats.

DHS also considers the vulnerability of potential targets when 
determining the national threat level. For example, DHS officials 
explained that they hold discussions with state and local officials to 
determine whether potential targets specified by threat information 
require additional security to prevent a terrorist attack or minimize 
the potential gravity of an attack. According to these officials, if 
the target is determined to be vulnerable, then DHS will consider 
raising the threat level. Last, DHS determines whether there is a 
nationwide threat of terrorist attack or if the threat is limited to a 
specific geographic location or a specific industrial sector. DHS 
officials said that, in general, upon assessment of the above criteria, 
if there appears to be a threat of terrorist attack nationwide, then 
IAIP recommends to the Secretary of Homeland Security that the national 
threat level should be raised. The Secretary of Homeland Security then 
consults with the other members of the Homeland Security Council on 
whether the national threat level should be changed.[Footnote 19] DHS 
officials told us that if the Homeland Security Council members could 
not agree on whether to change the national threat level, the President 
would make the decision. DHS officials also told us that when deciding 
whether to lower the national threat level, they consider whether the 
time period in which the potential threat was to occur has passed and 
whether protective measures in place for the code-orange alerts have 
been effective in mitigating the threats.

DHS officials told us that if a credible threat against specific 
industrial sectors or geographic locations exists, DHS may suggest that 
these sectors or locations operate at a heightened level of security, 
rather than raising the national threat level. For example, for the 
third code-orange alert period in our review from December 31, 2003, to 
January 9, 2004, threat information raised concerns of potential 
terrorist activity for specific industrial sectors and geographic 
locations. In response, DHS officials said that they encouraged those 
responsible for securing chemical and nuclear power plants, transit 
systems, and aircraft, as well as certain cities, to maintain a 
heightened level of security, even after the national threat level was 
lowered to code-yellow. However, DHS officials noted that they did not 
assign a threat level to these sectors and regions at that time. DHS 
officials further indicated that these sectors and locations were not 
operating at code-orange alert levels. Rather, they operated at 
heightened levels of security. According to DHS officials, when 
encouraging specific sectors or regions to continue to operate at 
heightened levels of security, DHS may suggest that these sectors or 
regions (1) implement security measures that are in addition to those 
implemented during a code-orange alert period, (2) continue the 
measures implemented during the code-orange alert period, or (3) 
continue selected measures implemented during a code-orange alert 
period.

DHS officials told us that not all threats to specific regions or 
sectors are communicated to the public or to officials in all regions 
or sectors. Rather, if intelligence information suggests a targeted 
threat to specific regions or industrial sectors, DHS officials said 
that they inform officials in the specific regions or sectors that are 
responsible for implementing protective measures to mitigate the 
terrorist threat. To inform these officials, DHS issues threat 
advisories or information bulletins. The threat advisories we reviewed 
contained actionable information about threats targeting critical 
national networks, infrastructures, or key assets such as transit 
systems. These products may suggest a change in readiness posture, 
protective actions, or response that should be implemented in a timely 
manner. If the threat is less urgent, DHS may issue information 
bulletins, which communicate risk and vulnerabilities of potential 
targets. In a February 2004 testimony, the Deputy Secretary of Homeland 
Security said that because threat advisories and information bulletins 
are derived from intelligence, they are generally communicated on a 
need-to-know basis to a targeted audience.[Footnote 20] The threat 
advisories and bulletins we reviewed also included advice on protective 
measures to be implemented by law enforcement agencies or the owners 
and operators of national critical infrastructure assets in response to 
the specific threat.

Risk Communication Principles Can Be Useful in Communicating Threat 
Information and Guidance to Federal Agencies and States: 

DHS officials told us that they have not yet officially documented 
protocols for communicating information about changes in the national 
threat level to federal agencies and states. To ensure early and 
comprehensive information sharing and allow for informed decision 
making, risk communication experts suggest that threat warnings should 
include the following principles: (1) communication through multiple 
methods, (2) timely notification, and (3) specific information on the 
nature, location, and timing of threats as well as guidance on actions 
to take in response to threats. These principles can be applied to 
threat information shared with federal agencies and states through the 
Homeland Security Advisory System. DHS used multiple methods to notify 
federal agencies and states of changes in the national threat level. 
However, many federal agencies and states responding to our 
questionnaires indicated that they heard about threat level changes 
from media sources before being notified by DHS. Federal agencies and 
states also reported that they did not receive specific threat 
information and guidance for the three code-orange alert periods from 
March 17 to April 16, 2003; May 20 to 30, 2003; and December 21, 2003, 
to January 9, 2004.

DHS Has Not Documented Communication Protocols Regarding Threat Level 
Changes Including the Methods, Timing, and Content of Guidance and 
Threat Information to Be Shared: 

Documentation of communication protocols can assist DHS in better 
managing the expectations of federal agencies and states regarding the 
methods, timing, and content of guidance and threat information they 
receive when the national threat level is raised to code-orange. DHS 
officials told us that they have not yet officially documented 
protocols for notifying federal agencies and states of changes in the 
national threat level, but are working to do so. They noted that it is 
has been difficult to develop protocols that provide sufficient 
flexibility for sharing information in a variety of situations. Thus, 
while attempts have been made to officially document protocols for 
notifying federal agencies and states of national threat level changes, 
DHS officials said that they have not made much progress in doing so 
and could not provide a specific target date for completing this 
effort. Without documented communication protocols, recipients of 
threat level notifications are uncertain as to how, when, and from what 
entity, such as which DHS agency, they will be notified of threat level 
changes and the content and extent of guidance and threat information 
they may receive. Communication protocols would, among other things, 
help foster clear understanding and transparency regarding DHS's 
priorities and operations.[Footnote 21] Moreover, protocols could help 
ensure that DHS interacts with federal, state, local, and other 
entities using clearly defined and consistently applied policies and 
procedures.

Risk Communication Experts Suggest Warnings Should Be Communicated via 
Multiple Methods, Be Timely, and Include Specific Threat Information 
and Guidance on Protective Measures: 

Risk communication is the exchange of information among individuals and 
groups regarding the nature of risk, reactions to risk messages, and 
legal and institutional approaches to risk management. Risk 
communication experts have identified the following as important 
principles for communicating risks to individuals and groups: 

* Threat information should be consistent, accurate, clear, and 
provided repeatedly through multiple methods.

* Threat information should be provided in a timely fashion.

* To the greatest extent possible, threat information should be 
specific about the potential threat, including: 

* the nature of the threat,

* when and where it is likely to occur, and: 

* guidance on protective measures to take to prevent or respond to the 
threat.

These risk communication principles have been used in a variety of 
warning contexts, from alerting the public about severe weather or 
providing traffic advisories, to less commonplace warnings of 
infectious disease outbreaks or potential dangers from hazardous 
materials or toxic contamination.[Footnote 22] However, warnings about 
terrorist threats differ from these relatively more familiar 
warnings.[Footnote 23] For example, specific terrorist threat warnings 
to the public may allow terrorists to alter tactics or targets in 
response to the issuance of warnings. Warnings of terrorist threats may 
also increase general anxiety for populations clearly not at risk. 
Moreover, government agencies may not always have specific information 
on terrorist threats, or may not be able to publicly share specific 
information in threat warnings. Yet, despite these differences, the 
purpose of warnings, regardless of the threat, is to provide 
information to citizens and groups that allows them to make informed 
decisions about actions to take to prevent and respond to threats. 
Thus, risk communication principles should be applicable to 
communicating terrorist threat information to federal agencies, states, 
and localities through the Homeland Security Advisory System.

DHS Used Multiple Methods to Notify Federal Agencies and States of 
Threat Level Changes: 

According to risk communication principles, threat information should 
be provided through multiple methods to ensure that dissemination of 
the information is comprehensive and that people receive the 
information regardless of their level of access to information. In 
addition, HSPD-3 states that the Homeland Security Advisory System 
should provide a comprehensive and effective means to disseminate 
information regarding the risk of terrorist acts to federal, state, and 
local authorities. One means of disseminating threat information is 
through notifications to federal agencies and states of changes in the 
national threat level. DHS officials told us that with each increase in 
the national threat level, they apply lessons learned from previous 
alerts to improve their notification and information sharing processes 
regarding threat level changes. Based on federal agencies' and states' 
responses to our questionnaires, it appears that DHS is making progress 
in expanding the scope of its notification process, which is consistent 
with HSPD-3. As shown in table 1, more federal agencies reported 
receiving direct notification from DHS for the third code-orange alert 
period than for the other two code-orange alert periods in our review. 
Similarly, more federal agencies reported receiving notification from 
DHS via multiple methods for the third code-orange alert period than 
for the other two code-orange alert periods.

Table 1: Number of Federal Agencies and States Responding to Our 
Questionnaires that Reported Receiving Direct Notification from DHS and 
Reported Being Notified through Multiple Methods for the Three Code-
Orange Alert Periods: 

DHS notification: Reported receiving direct notification from DHS; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 17; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 19; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 20; 
Number of states n = 41[B]: March 17 to April 16, 2003: 35; 
Number of states n = 41[B]: May 20 to 30, 2003: 33; 
Number of states n = 41[B]: December 21, 2003, to January 9, 2004: 39.

DHS notification: Reported receiving notification from DHS by more 
than one method; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 8; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 10; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 14; 
Number of states n = 41[B]: March 17 to April 16, 2003: 25; 
Number of states n = 41[B]: May 20 to 30, 2003: 24; 
Number of states n = 41[B]: December 21, 2003, to January 9, 2004: 31. 

Source: GAO analysis of questionnaire data.

[A] In the questionnaire we sent to DHS, we did not include questions 
on how DHS was notified of changes in the national threat level. Thus, 
this agency is not included in our analysis of code-orange alert 
notifications.

[B] One state responding to our questionnaire did not provide responses 
on how it was notified of changes in the national threat level. 
Additionally, 1 state reported that it did not follow the Homeland 
Security Advisory System. Thus, these 2 states are not included in our 
analysis of code-orange alert notifications.

[End of table]

DHS used the following methods, among others, to notify entities of 
changes in the national threat level, according to federal agencies' 
and states' responses to our questionnaires and discussions with DHS 
and local government officials: 

* Conference calls between the Secretary of Homeland Security and state 
governors and/or state homeland security officials.

* Telephone calls from Federal Protective Service[Footnote 24] (FPS) 
officials to federal agencies.

* E-mail, telephone, or electronic communications from Homeland 
Security Operations Center (HSOC) representatives to the federal, 
state, or local agencies they represent.

* FBI electronic systems, such as the National Law Enforcement 
Telecommunications System.

* E-mail and/or telephone communications with federal agencies' chief 
of staff and public affairs offices.

* E-mail and/or telephone communications to local government 
associations such as the National Governors Association and the U.S. 
Conference of Mayors.

Federal Agencies and States Reported Hearing about Threat Level Changes 
from Media Sources before Receiving Notification from DHS: 

Risk communication experts suggest that threat information should be 
provided in a timely fashion to prevent unofficial sources, such as the 
media, from reporting information before official sources, including 
government agencies, do so. These principles suggest that lack of early 
and open information sharing from official entities can undermine these 
entities' credibility. HSPD-3, as amended by HSPD-5, states that the 
Secretary of Homeland Security should establish a process and a system 
for conveying relevant information regarding terrorist threats 
expeditiously. In addition, for an entity to control its operations, it 
must have relevant, reliable, and timely communications relating to 
internal and external events.

Many federal agencies and some states responding to our questionnaires 
expressed concerns that they learned about national threat level 
changes from media sources before being notified by DHS. Specifically, 
16 of 24 federal agencies[Footnote 25] indicated that they learned 
about threat level changes via media sources prior to being notified by 
DHS for at least one of the three code-orange alert periods. Likewise, 
15 of 40 states[Footnote 26] reported learning about national threat 
level changes via media sources prior to being notified by DHS for at 
least one of the three code-orange alert periods. This raises questions 
about whether DHS is always conveying information regarding threat 
level changes to government entities expeditiously, as required by 
HSPD-3.

Moreover, some states reported that their ability to provide credible 
information to state and local agencies and the public was hindered 
because they did not receive notification from DHS before the media 
reported on the threat level changes. For example, 6 states noted that 
when media sources reported national threat level changes before state 
and local emergency response officials were directly notified by DHS, 
these officials did not have sufficient time to prepare their response 
to the threat level change, including how they would respond to 
requests from the public for additional information on the threat level 
change. One other state reported that it would prefer to first learn 
about changes in the national threat level from DHS so that it has 
sufficient time to notify state agencies and localities of the change 
and so that these entities can prepare their responses before the 
public is notified of the change. Additionally, 8 localities from which 
we obtained information indicated that they first learned of threat 
level changes from media sources, and 4 of these localities would 
prefer to be notified of threat level changes prior to the public. 
Officials from some of these localities told us that after media 
sources reported the change, their agencies received requests for 
detailed information on the change from the public and other entities. 
They noted that their agencies appeared ineffective to the public and 
other entities because, without notification of the national threat 
level change before it was reported by media sources, they did not have 
time to prepare informed responses.

DHS officials told us that they attempt to notify federal agencies and 
states of threat level changes before the media report on the changes. 
However, they noted that DHS has not established target time periods in 
which to notify these entities of the threat level changes. 
Furthermore, DHS officials indicated they were aware that the media 
sometimes reported threat level changes before DHS notified federal and 
state officials, and in the case of the second code-orange alert period 
in our review, before the decision to raise the threat level was even 
made. DHS officials told us that they send notifications/advisories to 
the media to inform them of impending press conferences and that the 
media may speculate about announcements of threat level changes that 
may be made at the press conferences. DHS officials indicated that the 
department is trying to determine the best approach for managing 
expectations created by this situation.

Federal Agencies and States Reported that They Generally Did Not 
Receive Specific Guidance and Threat Information for Code-Orange Alert 
Periods, Hindering Their Response to the Alerts: 

Risk communication experts said that without specific information on 
the nature, location, and timing of threats and guidance on actions to 
take, citizens may not be able to determine whether they are at risk 
and make informed decisions about actions to take in response to 
threats, and thus may take inappropriate actions. According to HSPD-3, 
the Homeland Security Advisory System was established to inform and 
facilitate decisions appropriate to different levels of government 
regarding terrorist threats and measures to take in response to 
threats. However, federal agencies and states responding to our 
questionnaires generally indicated that they did not receive guidance 
and specific information on threats on the three occasions included in 
our review when the national threat level was raised to code-orange. 
These entities reported that insufficient information on the nature, 
location, and timing of threats and insufficient guidance on 
recommended measures hindered their ability to determine whether they 
were at risk as well as their ability to determine and implement 
protective measures.[Footnote 27]

As shown in table 2, federal agencies and states responding to our 
questionnaires indicated that they generally did not receive specific 
information on threats with notification of increases in the national 
threat level for the three code-orange alert periods included in our 
review. Yet, as table 2 suggests, a greater number of federal agencies 
and states reported receiving more specific threat information for the 
third code-orange alert period than for the other two code-orange alert 
periods.

Table 2: Number of Federal Agencies and States That Reported Receiving 
Types of Information with Notification from DHS for the Three Code-
Orange Alert Periods: 

Type of information: General information on threats; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 10; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 11; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 12; 
Number of states n = 42[B]: March 17 to April 16, 2003: 35; 
Number of states n = 42[B]: May 20 to 30, 2003: 34; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 37.

Type of information: Information on region-or sector-specific threats; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 6; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 6; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 9; 
Number of states n = 42[B]: March 17 to April 16, 2003: 9; 
Number of states n = 42[B]: May 20 to 30, 2003: 11; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 22.

Type of information: Information on site-or event-specific threats; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 4; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 4; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 8; 
Number of states n = 42[B]: March 17 to April 16, 2003: 8; 
Number of states n = 42[B]: May 20 to 30, 2003: 7; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 15.

Type of information: Information on timing of threats; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 4; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 4; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 8; 
Number of states n = 42[B]: March 17 to April 16, 2003: 6; 
Number of states n = 42[B]: May 20 to 30, 2003: 7; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 17.

Type of information: Recommended measures for preventing incidents; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 6; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 4; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 7; 
Number of states n = 42[B]: March 17 to April 16, 2003: 20; 
Number of states n = 42[B]: May 20 to 30, 2003: 18; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 23.

Type of information: Recommended measures for responding to incidents; 
Number of federal agencies n = 25[A]: March 17 to April 16, 2003: 4; 
Number of federal agencies n = 25[A]: May 20 to 30, 2003: 4; 
Number of federal agencies n = 25[A]: December 21, 2003, to January 9, 
2004: 6; 
Number of states n = 42[B]: March 17 to April 16, 2003: 8; 
Number of states n = 42[B]: May 20 to 30, 2003: 7; 
Number of states n = 42[B]: December 21, 2003, to January 9, 2004: 10.

Source: GAO analysis of questionnaire data.

[A] In the questionnaire we sent to DHS, we did not include questions 
on how DHS was notified of changes in the national threat level. Thus, 
this agency is not included in our analysis of code-orange alert 
notifications.

[B] One state reported that it did not follow the Homeland Security 
Advisory System. Thus, this state is not included in our analysis of 
code-orange alert notifications.

[End of table]

As shown in tables 3 and 4, federal agencies and states responding to 
our questionnaires indicated that guidance and specific information on 
threats, if available, would have assisted them in determining their 
levels of risk and measures to take for the December 21, 2003, to 
January 9, 2004, code-orange alert period. Results for the other two 
code-orange alert periods are consistent with those reported in tables 
3 and 4 for the third code-orange alert period.

Table 3: Number of Federal Agencies That Indicated Specific Types of 
Information That Would Have Been Helpful to Determine Measures to Take 
for the Code-Orange Alert Period from December 21, 2003, to January 9, 
2004: 

Type of information: Timing of threats; 
Number of federal agencies n = 25[A]: 24.

Type of information: Region-or sector-specific threats; 
Number of federal agencies n = 25[A]: 23.

Type of information: Site-or event-specific threats; 
Number of federal agencies n = 25[A]: 23.

Type of information: Recommended measures for preventing incidents; 
Number of federal agencies n = 25[A]: 21.

Type of information: Recommended measures for responding to incidents; 
Number of federal agencies n = 25[A]: 19.

Source: GAO analysis of questionnaire data.

[A] In the questionnaire we sent to DHS, we did not ask DHS to indicate 
what other types of information would have been helpful to determine 
measures to take for the three code-orange alert periods. Thus, this 
agency is not included in our analysis of guidance and information 
preferred by federal agencies.
[End of table]

Table 4: Number of States That Indicated Specific Types of Information 
That Would Have Been Helpful to Determine Measures to Take for the 
Code-Orange Alert Period from December 21, 2003, to January 9, 2004: 

Type of information: Region-or sector-specific threats; 
Number of states n = 41[A]: 34.

Type of information: Site-or event-specific threats; 
Number of states n = 41[A]: 34.

Type of information: Timing of threats; 
Number of states n = 41[A]: 32.

Type of information: Recommended measures for responding to incidents; 
Number of states n = 41[A]: 29.

Type of information: Recommended measures for preventing incidents; 
Number of states n = 41[A]: 27. 

Source: GAO analysis of questionnaire data.

[A] One of the states responding to our questionnaire did not provide 
responses on the types of information that would have been helpful to 
it in determining measures to take for the three code-orange alert 
periods. Additionally, 1 state reported that it did not follow the 
Homeland Security Advisory System. Thus, these 2 states are not 
included in our analysis of guidance and information preferred by 
states.

[End of table]

Furthermore, 13 localities reported to us that information on site-, 
area-, or event-specific threats would have been beneficial to them in 
responding to the code-orange alert periods. Six of the localities from 
which we obtained information reported that information on region-or 
sector-specific threats would have assisted them in determining their 
level of risk and measures to take in response to the three code-orange 
alerts in our review.

When federal agencies and states perceive that they have not received 
sufficient guidance and threat information, these entities may not be 
able to determine whether they are at risk from possible threats or 
what measures to take in response to the threats. For example, 1 
federal agency reported that DHS never notified the agency as to 
whether Washington, D.C., would remain at heightened security levels 
after the national threat level was lowered to code-yellow on January 
9, 2004, which resulted in the agency maintaining code-orange alert 
measures for an additional week and incurring additional costs for 
doing so. Another federal agency reported that to respond to the code-
orange alerts, it implemented measures at all facilities regardless of 
the specific location or risk involved, which spread resources across 
all facilities rather than focusing the measures on mitigating specific 
threats. Officials from 1 state and 1 locality noted that without 
specific threat information, these entities did not understand the true 
nature of the threat and what impact the threat may have on them.

Federal agencies and states responding to our questionnaire also 
indicated that without guidance and specific threat information, they 
may not be able to effectively and efficiently target or enhance 
protective measures to respond to the code-orange alerts. Eighteen of 
the 25 federal agencies and 32 of the 41 states providing responses to 
the questions on operational challenges in our questionnaires reported 
that lack of sufficient threat information was a challenge they faced 
during the three code-orange alert periods. Moreover, in responding to 
our questionnaires, 16 federal agencies and 12 states noted that 
insufficient information on threats makes it difficult for these 
entities to focus resources on specific measures to respond to threats.

At a February 2004 hearing, the Deputy Secretary of Homeland Security 
said that the department's communications of national threat level 
changes are intended to provide specific information regarding the 
intelligence supporting the change in the threat level, and that 
protective measures are developed and communicated, along with the 
threat information, prior to a public announcement of the decision. DHS 
officials told us that they provide specific threat information, when 
available, to federal agencies, states, and localities at risk and with 
the authority to respond to threats. For example, the Deputy Secretary 
said that threat information that was shared by DHS regarding changes 
in the national threat level was primarily intended for security 
professionals at all levels of government and the private sector. 
Moreover, to provide more specific threat information and respond to 
sector-and location-specific security needs, DHS officials told us they 
have adjusted the system based on feedback from federal, state, local 
and private sector officials; tests of the system; and experience with 
previous periods of code-orange alert. For example, for the most recent 
code-orange alert from December 21, 2003, to January 9, 2004, the 
Deputy Secretary noted in his February 2004 testimony that DHS provided 
specific recommendations for protective measures to industrial sectors 
and for geographic areas in response to specific threat information.

Federal Agencies Reported Implementing Few New Protective Measures for 
Code-Orange Alerts because They Always Operate at High Security Levels, 
While States Varied Their Responses: 

The majority of federal agencies responding to our questionnaire 
indicated that they maintain high security levels regardless of the 
national threat level and, as a result, they did not need to implement 
a substantial number of new or additional protective measures to 
respond to the three periods of code-orange alert from March 17 to 
April 16, 2003; May 20 to 30, 2003; and December 21, 2003, to January 
9, 2004. For the most part, these federal agencies reported enhancing 
existing protective measures to respond to the three code-orange 
alerts. To a lesser extent, federal agencies continued the use of 
existing measures, without enhancement, during the code-orange alert 
periods. On the other hand, states differed in the extent to which they 
enhanced or maintained existing measures or implemented additional 
protective measures solely in response to the code-orange alerts. 
Federal agencies and states reported benefits, such as a heightened 
sense of security among employees, from enhancing or implementing 
protective measures for the code-orange alert periods. However, federal 
agencies and states also indicated that taking such measures negatively 
affected their operations, for example, by redirecting resources from 
normal operations to code-orange alert duties.

Federal Agencies Reported that High Security Postures Reduced the Need 
to Implement Additional Measures Solely in Response to Code-Orange 
Alerts: 

More than half of the federal agencies responding to our questionnaire 
indicated that they operate at high security levels, regardless of the 
national threat level. Thus, they did not need to implement a 
significant number of new or additional protective measures to respond 
to code-orange alerts. For example, in response to the third code-
orange alert period in our review--December 21, 2003 to January 9, 
2004--10 of 24[Footnote 28] federal agencies indicated that they most 
commonly enhanced existing protective measures, such as increasing 
facility security patrols. During the same code-orange alert period, 8 
federal agencies reported most often continuing protective measures at 
their pre-code-orange alert levels, for example, relying on continuing 
activation of monitoring systems and intrusion detection devices. For 
the remaining 6 federal agencies, there were slight differences among 
the number of protective measures they enhanced during the third code-
orange alert period, those they maintained at pre-code orange alert 
levels, and those they implemented solely in response to the code-
orange alert. For one of these agencies,

* three of the protective measures in place for the third code-orange 
alert period were maintained at their pre-code-orange alert levels,

* three of the protective measures were enhanced beyond their pre-code-
orange alert levels, and: 

* four protective measures were implemented solely for the code-orange 
alert period.

Results for the other two code-orange alert periods in our review are 
similar to those reported for the third code-orange alert period. For 
more information on protective measures federal agencies most commonly 
reported having in place for the three code-orange alert periods and 
their testing of such measures, see appendix IV.

States Differed in the Extent to Which They Implemented Additional 
Protective Measures for Code-Orange Alerts: 

Overall, states differed in the extent to which they implemented 
additional protective measures for the three code-orange alert periods 
in our review. Based on our analysis of questionnaire responses from 
the 40 states[Footnote 29] that provided information on protective 
measures for the third code-orange alert period in our review,

* 16 states most often enhanced protective measures that were already 
in place prior to the code-orange alert period;

* 6 states most often implemented new protective measures for the code-
orange alert;

* 5 states most often maintained protective measures that were already 
in place at their pre-code-orange alert levels; and: 

* 13 states employed a varied response, enhancing measures, continuing 
existing measures, and/or implementing new measures in roughly equal 
proportion.

Results for the other two code-orange alert periods in our review are 
similar to those reported for the third code-orange alert period.

Various reasons influenced the extent to which states responding to our 
questionnaire enhanced, maintained, or implemented new protective 
measures. For example, some states reported that they already operated 
at heightened security levels and, therefore, did not need to implement 
additional protective measures in response to the code-orange alerts in 
our review; rather they enhanced measures already in place. Other 
states indicated that the extent to which they implemented protective 
measures for the code-orange alert periods in our review depended on 
specific threat information. For example, 1 state indicated that it did 
not enhance existing protective measures or implement new protective 
measures for the code-orange alert periods in our review because there 
were no specific threats to the state that required it to do so. Other 
states indicated that the extent to which they implemented protective 
measures for code-orange alert periods depended on the required level 
of security for their critical infrastructure sites. For example, 1 
state reported that it implemented new protective measures for its 
nuclear power plants during code-orange alert periods, but for some 
other critical infrastructure assets, it enhanced security measures 
already in place. Some states also indicated that resource constraints 
determined the extent to which they enhanced or implemented new 
protective measures for code-orange alert periods. For example, 2 
states indicated that they had to implement a substantial number of new 
protective measures for the three code-orange alert periods in our 
review because they could not afford to always operate at a high level 
of security. For more detailed information on protective measures that 
states most commonly reported having in place for code-orange alert 
periods and testing of these measures, see appendix IV.

Additionally, 4 localities from which we obtained information reported 
that they did not enhance or implement a substantial number of 
protective measures to respond to the code-orange alerts because they 
did not receive specific threat information indicating that the 
localities were at risk. For example, 1 locality reported that because 
it did not receive specific threat information on possible targets, the 
locality did not take any measures to respond to the code-orange 
alerts. Additionally, another locality noted that its emergency 
response staff was not able to implement additional measures in 
response to the code-orange alerts because the staff was too busy with 
regular duties such as responding to 911 calls.

Federal Agencies and States Reported that Protective Measures for Code-
Orange Alerts Were Beneficial, but also Presented Operational 
Challenges and Affected Normal Operations: 

Federal agencies and states responding to our questionnaires indicated 
that they benefited in various ways from the protective measures they 
enhanced or implemented during the code-orange alert periods, but also 
noted that they faced operational challenges in responding to the three 
code-orange alert periods in our review. For example, federal agencies 
and states reported that protective measures increased employees' sense 
of security, promoted staff awareness, and provided visible deterrents 
to possible threats. However, federal agencies and states responding to 
our questionnaires also reported that their operations were negatively 
affected during code-orange alerts as a result of protective measures 
they enhanced or implemented. For example, 10 federal agencies and 13 
states reported that they had to redirect resources from normal 
operations to enhance or implement protective measures for code-orange 
alerts. One locality also reported that its operations were negatively 
affected by the redirection of personnel, which resulted in delays of 
maintenance activities and preventative exercises as well as 
postponement of training. Additionally, 15 federal agencies noted 
delays for visitors and employees. Some of these federal agencies and 
states reported that maintaining a code-orange alert level of security 
for more than a few days at a time significantly drained their security 
resources--an effect federal agencies and states have identified as 
"code-orange alert fatigue." 

Federal agencies and states also indicated that the lack of federal 
governmentwide coordination hindered their ability to respond to 
threats. Without coordination of information and intelligence sharing 
during code-orange alert periods, federal agencies and states 
responding to our questionnaires noted that they may not receive threat 
information needed to help them determine and implement their responses 
to code-orange alerts. For example, 1 federal agency reported that it 
received different requests from several federal agencies to deploy 
personnel to different locations. This federal agency noted that 
improved federal governmentwide coordination might result in more 
efficient assignment of resources. Similarly, 1 locality noted that 
because different government agencies notified different local agencies 
of changes in the national threat level, first responders and local 
officials could not effectively and efficiently coordinate and 
implement protective resources. On the other hand, 1 state official 
raised concerns about whether federal agencies were fully informed of 
the information DHS provided to states and had the information needed 
to implement appropriate local security measures. This official noted 
that persons from the Transportation Security Administration, the Coast 
Guard, and the U.S. Army Corps of Engineers called his state's homeland 
security office for advisories and bulletins DHS had provided to the 
state. Because of these information requests, this official noted that 
the state was concerned that officials from these federal agencies did 
not receive information needed to implement security measures, 
especially at airports. In commenting on a draft of this report, DHS 
officials stated that the department is working to address this 
problem.

Six states also indicated that insufficient information from DHS on 
national critical infrastructure assets made it difficult to 
effectively protect these assets during the code-orange alert periods. 
Three of these states indicated that DHS asked them to protect specific 
national critical infrastructure sites, some of which were no longer 
operational or others that were closed, such as shopping malls. 
Officials in one state indicated that DHS did not coordinate with the 
state when it initially developed this list of national critical 
infrastructure assets. DHS officials told us that the department 
developed a list of national critical infrastructure assets to assist 
states in determining protective measures to implement at their 
national critical infrastructure sites. According to the Deputy 
Director of the Protective Security Division of IAIP, DHS initially 
developed a list of 145 national critical infrastructure assets, 
including nuclear power plants, chemical facilities, and transportation 
systems, to ensure their security during Operation Liberty 
Shield.[Footnote 30] This official told us that DHS identified national 
critical infrastructure assets for the list based on intelligence 
information indicating possible assets at risk, the vulnerabilities of 
these assets, and possible consequences of an attack on assets, 
including health, safety, and economic impacts. DHS did not coordinate 
with states and localities in developing the national critical 
infrastructure assets list for Operation Liberty Shield because 
planning and timing of military operations for the war in Iraq and for 
Operation Liberty Shield were given the highest classification levels 
and discussed only at the federal level. The Deputy Director said that 
since Operation Liberty Shield, DHS has continually expanded and 
revised its national critical infrastructure assets list based on 
ongoing analysis of threat information and input from states. In 
reviewing a draft of this report, DHS officials told us that its 
Protective Security Division has given all states and territories 
opportunities to suggest assets to be included in the National Asset 
Database as well as to verify and validate information DHS maintains on 
such assets. To enhance standard security levels at national critical 
infrastructure sites, this DHS official said that the department is 
working with states to develop plans for protecting the immediate areas 
surrounding national critical infrastructure assets and reducing 
vulnerabilities in those areas. In particular, the Deputy Director told 
us that DHS provided guidance and information to states and local law 
enforcement agencies to develop protection plans for areas around 
national critical infrastructure assets.

DHS Efforts to Gather Information on Protective Measures Taken by 
States and Localities: 

The majority of states responding to our questionnaire indicated that, 
for all three code-orange alert periods in our review, DHS requested 
some information on protective measures taken by states in response to 
the heightened threat levels. However, as shown in table 5, most states 
reported that DHS did not request information on the effectiveness of 
these security measures.

Table 5: Number of States That Indicated DHS Requested Information on 
Protective Measures Taken by the State in Response to the Three Code-
Orange Alert Periods: 

Type of information: Security actions taken in response to the elevated 
threat; 
Number of states n = 40[A]: March 17 to April 16, 2003: 28; 
Number of states n = 40[A]: May 20 to 30, 2003: 22; 
Number of states n = 40[A]: December 21, 2003, to January 9, 2004: 33.

Type of information: Security actions taken at specific critical 
infrastructure sites; 
Number of states n = 40[A]: March 17 to April 16, 2003: 24; 
Number of states n = 40[A]: May 20 to 30, 2003: 18; 
Number of states n = 40[A]: December 21, 2003, to January 9, 2004: 31.

Type of information: Effectiveness of state or government security 
actions taken; 
Number of states n = 40[A]: March 17 to April 16, 2003: 7; 
Number of states n = 40[A]: May 20 to 30, 2003: 7; 
Number of states n = 40[A]: December 21, 2003, to January 9, 2004: 8. 

Source: GAO analysis of questionnaire data.

[A] Of the 43 states responding to our questionnaire, 1 reported that 
it did not follow the Homeland Security Advisory System and 2 did not 
provide responses to the question regarding the extent to which DHS 
requested information on protective measures taken by states in 
response to increased threat levels. Therefore, these 3 states are not 
included in our analysis of states from which DHS requested information 
on protective measures.

[End of table]

An Office of State and Local Government Coordination official said that 
DHS maintains close contact with states and localities during code-
orange alert periods and fosters information sharing about actions 
taken to increase security. For example, this official noted that DHS 
co-sponsored a February 2003 workshop with the FBI to encourage state-
level implementation of the Homeland Security Advisory System and 
provide a forum for information exchange among state and local homeland 
security representatives. More recently, on April 19, 2004, DHS 
launched a new Web site (www.llis.gov) to provide a nationwide network 
of lessons learned and best practices for homeland security officials 
and emergency responders. For the most recent code-orange alert from 
December 21, 2003 to January 9, 2004, DHS officials noted that they 
contacted states to inquire about protective measures that were put in 
place. According to DHS officials, they made such inquiries to (1) 
monitor the extent to which states implemented protective measures that 
DHS recommended, (2) apprise the White House of actions taken in 
response to code-orange alerts, and (3) enhance DHS officials' 
understanding of protective measures for which states may seek 
reimbursement.

Costs Reported by Federal Agencies, though Limited, Suggest a Decline 
in Additional Costs: 

Sixteen of 26 federal agencies responding to our questionnaire reported 
additional costs for at least one of the code-orange alert periods in 
our review. We examined the cost information provided by these agencies 
for obvious errors and inconsistencies and examined agencies' responses 
to the questionnaire regarding the development of the cost information. 
In doing so, we found that these federal agencies' cost data were 
generated from various sources, such as financial accounting systems, 
credit card logs, and security contracts. Additionally, this cost 
information is not precise, nor do the costs likely represent all 
additional costs incurred during code-orange alert periods. In some 
cases, we have concerns about the reliability of the data sources used 
to develop the costs reported to us. For example, 6 of the 16 federal 
agencies reported that they extracted some of the code-orange alert 
cost data from their agencies' financial accounting systems. However, 
as reported in the fiscal year 2005 President's Budget, 5 of these 
agencies' financial management performance had serious flaws as of 
December 31, 2003. Despite these limitations, we believe the cost data 
to be sufficiently reliable as indicators of general ranges of cost and 
overall trends. However, the data should not be used to determine the 
cumulative costs incurred across all federal agencies.

Based on the information provided by federal agencies, total additional 
costs reported by federal agencies responding to our questionnaire for 
the March 17 to April 16, 2003, and May 20 to 30, 2003, code-orange 
alert periods were less than 1 percent of these agencies' fiscal year 
2003 homeland security funding, as reported to OMB. On the basis of 
this cost information, we determined additional average daily costs 
ranged from about $190 to about $3.7 million across all three code-
orange alert periods in our review. Based on information reported by 
these agencies, the additional average daily costs incurred across 
code-orange alert periods have declined over time.

Some of these federal agencies attribute this decline to continued 
enhancement of standard levels of security. Some federal agencies 
reported that they did not have any additional costs during code-orange 
alert periods, as they either did not implement any additional 
protective measures or they redirected already existing resources to 
implement additional code-orange alert measures rather than employ 
additional resources. Although federal agencies may not have reported 
additional costs directly as a result of implementing protective 
measures for code-orange alerts, actions taken such as redirecting 
resources from normal operations would have resulted in indirect costs.

Additional Costs Reported by Federal Agencies for the First and Second 
Alert Periods in Our Review Were Less than 1 Percent of Agencies' 2003 
Homeland Security Funding: 

Sixteen of 26 federal agencies responding to our questionnaire reported 
additional costs for the first code-orange alert period in our review-
-March 17 to April 16, 2003. Fifteen of these agencies also reported 
additional costs for the second code-orange alert period in our review-
-May 20 to 30, 2003. For 13 of the 15 federal agencies that reported 
additional costs for both the first and second code-orange alert 
periods in our review, we calculated that the additional costs reported 
by these agencies were less than 1 percent of these agencies' fiscal 
year 2003 homeland security funding. This calculation is based on OMB's 
2003 Report to Congress on Combating Terrorism, which presented 
information federal agencies reported to OMB on the amount of homeland 
security funding authorized to federal agencies in fiscal year 2003.

For the 16 federal agencies responding to our questionnaire that 
reported additional costs during the first code-orange alert period in 
our review, we calculated average daily additional costs, which ranged 
from about $190 to about $848,000.[Footnote 31] A cabinet level agency 
with security responsibilities limited to protecting its facilities and 
employees reported the least additional costs for this code-orange 
alert period, while another cabinet level agency that, in addition to 
securing its facilities, is responsible for the protection of national 
critical infrastructure assets reported the most additional costs. For 
the 15 federal agencies that reported additional costs for the second 
and third--December 21, 2003, to January 9, 2004--code-orange alert 
periods in our review, we calculated additional average daily costs 
that ranged from about $240 to about $3.7 million and from about $190 
to about $1 million, respectively.[Footnote 32] The agency that 
reported the least additional costs for the second and third code-
orange alert periods in our review was an independent agency, while the 
agencies that reported the most additional costs for these code-orange 
alert periods were generally cabinet agencies that are responsible for 
the protection of national critical infrastructure assets. Most of the 
additional costs federal agencies reported were personnel costs, such 
as overtime wages or costs for additional security personnel. Appendix 
V provides additional information regarding cost information submitted 
by federal agencies.

Federal Agencies' Additional Average Daily Costs for Code-Orange Alerts 
Declined: 

Based on the cost information provided by federal agencies, we 
determined that there was a decline in the additional average daily 
costs incurred by these federal agencies over the three code-orange 
alert periods in our review. Of the 15 federal agencies that reported 
additional costs for the first and third code-orange alert periods, 11 
federal agencies experienced an overall decline in the additional 
average daily costs across the code-orange alert periods. Five of these 
11 federal agencies indicated that their additional costs declined 
across the three code-orange alert periods in our review because they 
were consistently enhancing their baseline levels of security, which, 
in turn, required fewer additional protective measures during 
subsequent code-orange alert periods. Three agencies indicated that the 
decline in additional average daily costs was due to a reduction in the 
number of protective measures they had in place. One of these agencies 
explained that rather than implementing general protective measures 
with the receipt of specific threat information for the third code-
orange alert in our review, it was able to determine the most 
appropriate protective measures to put in place.

Some Federal Agencies Reported No Additional Costs Due to Redirection 
of Existing Resources and Lack of Additional Measures: 

Six federal agencies reported that they did not have additional costs 
for at least two of the code-orange alert periods in our review. Four 
of these agencies indicated that they did not have additional costs 
because they redirected already existing resources to implement 
additional protective measures for the code-orange alert periods rather 
than employ additional resources. For example, 2 agencies said that 
they were able to increase the frequency of their facility patrols 
without hiring additional guards or requiring guards to work overtime 
by closing one of the facility's entrances during code-orange alert. 
Therefore, the guards who would normally secure that entrance were 
assigned to conduct additional roaming facility patrols. Furthermore, 2 
of the 4 agencies indicated that they planned their protective measures 
with the specific intent that the agency would not incur any additional 
security-related costs during code-orange alert periods. The remaining 
2 agencies reported that they did not have any additional costs because 
they did not implement additional protective measures for the code-
orange alert periods. One agency explained that it did not implement 
any protective measures during code-yellow or code-orange alert periods 
because it is located in a privately owned building and is not 
responsible for the security of its facility, nor does this agency have 
field offices for which it is responsible.

Although these federal agencies reported that they did not directly 
incur additional costs to implement protective measures for code-orange 
alert periods, the consequences of implementing such protective 
measures may have resulted in indirect costs for these agencies. Some 
federal agencies responding to our questionnaire indicated they could 
not quantify these indirect costs. However, federal agencies provided 
examples of redirection of resources that may have caused them to incur 
such costs. For example, 13 federal agencies noted that in order to 
implement code-orange alert measures, they had to redirect existing 
resources from normal operations. Furthermore, one agency indicated 
that redirecting resources in response to code-orange alerts prevented 
the agency from performing mission-related activities, such as 
deterrence of criminal activity other than terrorism. Additionally, 16 
federal agencies said that as a result of implementing measures for 
code-orange alerts, there were delays for employees and visitors 
entering facilities, which may have resulted in loss of productivity 
among employees and a delay in provision of services. Seven federal 
agencies indicated that as part of their response to code-orange 
alerts, they postponed or cancelled agency-sponsored activities such as 
training for staff development.

Cost Data Collected by DHS and Data Reported by Others Cannot be 
Generalized: 

DHS has collected limited information on costs incurred by states and 
localities during code-orange alert periods through its State Homeland 
Security Grant Program - Part II and the Urban Areas Security 
Initiative - Part II. States must submit information to DHS to be 
reimbursed for costs incurred as a result of actions taken to increase 
critical infrastructure protection during code-orange alerts. However, 
this cost information does not represent all costs incurred by states 
and their localities during code-orange alert periods. Therefore, it 
cannot be used to assess the financial impact of code-orange alerts on 
states and localities. The U.S. Conference of Mayors also collected 
information and reported estimates of costs localities incurred in 
response to code-orange alerts. Moreover, a Director with the Center 
for Strategic and International Studies estimated and reported[Footnote 
33] costs incurred by federal agencies during code-orange alerts. 
However, because of limitations in the scope and methodologies used in 
these estimates, the cost information they reported may not be adequate 
for making generalizations regarding additional costs states and 
localities incurred in response to code-orange alerts.

DHS Collected Limited Information on Costs Incurred by States and 
Localities during Code-Orange Alert Periods through Its Grant Programs: 

DHS issued an information bulletin to states on March 21, 2003, 
advising them to capture additional costs incurred by the state and its 
localities during the March 17 to April 16, 2003, code-orange alert 
period for the protection of critical infrastructure, in the event that 
funds became available to reimburse states and localities for these 
additional costs. Through the fiscal year 2003 State Homeland Security 
Grant Program - Part II (SHSGP II), DHS made a total of $200 million 
available to states and local communities to mitigate costs of critical 
infrastructure protection[Footnote 34] during the period of hostilities 
with Iraq and future periods of heightened threat.[Footnote 35] 
According to SHSGP II guidelines, SHSGP II funds can be used for: 

* public safety agency overtime costs,

* contract security personnel costs, and: 

* state-ordered National Guard deployments required to augment security 
at critical infrastructure.[Footnote 36]

Additionally, at least 50 percent of a state's award must be allocated 
to local communities.

Through the fiscal year 2003 Urban Areas Security Initiative - Part II 
(UASI II), DHS made approximately $125 million available to reimburse 
select urban areas for costs incurred during the February 7 to February 
27, 2003; March 17, 2003, to April 16, 2003; and May 20 to 30, 2003, 
code-orange alert periods. Specifically, UASI guidelines allowed for 
the reimbursement of costs associated with overtime and critical 
infrastructure protection.[Footnote 37] On January 23, 2004, DHS issued 
a memorandum to state officials indicating that SHSGP II and UASI II 
funding could also be used to reimburse states and localities for 
additional costs incurred for protection of critical infrastructure for 
the December 21, 2003, to January 9, 2004, code-orange alert period.

For the March 17 to April 16, 2003, and May 20 to 30, 2003, code-orange 
alert periods, DHS required states to submit budget detail worksheets, 
including the name of the state agency or local jurisdiction that 
incurred the additional critical infrastructure protection costs and 
the amount the agency or locality requested for reimbursement. For the 
December 21, 2003, to January 9, 2004, code-orange alert period, DHS 
provided a more detailed template for the budget detail worksheet, 
which asked states to identify the critical infrastructure site 
protected and the amount of costs incurred and personnel deployed for 
each of the following categories: 

* National Guard deployment,

* public safety overtime,

* contract security personnel, and: 

* emergency operations center overtime.

Additionally, for all three code-orange alert periods in our review, 
DHS asked states to distinguish between state-level and local-level 
costs. Through SHSGP II and UASI II, states were awarded a specified 
amount from which they could draw down over a period of 2 years to 
reimburse them for additional costs incurred during code-orange alert 
periods. According to the grant guidelines, DHS must approve the budget 
detail worksheet before states and localities can obligate, expend, or 
draw down these grant funds. DHS, in monitoring these grant programs, 
takes steps to validate critical infrastructure protection costs. 
Additionally, amounts that states and localities expend in excess of 
$300,000 are subject to an external audit which, when completed, 
provides assurance regarding the reliability of the cost data.[Footnote 
38]

Based on the following, it is unlikely that the cost information 
submitted by states to DHS represents all additional costs incurred by 
states and localities during code-orange alert periods: 

* States have up to 2 years from the time when the grant is awarded to 
submit requests for reimbursement of additional code-orange alert 
costs.

* Some states are still in the process of validating proposed costs 
incurred by the state and its localities. For example, one state 
estimated that its state agencies and localities incurred an additional 
$3.7 million for the March 17 to April 16, 2003, code-orange alert 
period. However, the state could only validate additional code-orange 
alert costs of about $1.3 million, and thus could only report this 
amount as eligible for DHS reimbursement.

* The cost information submitted by states does not include additional 
costs for training or the purchase of equipment and materials during 
code-orange alert periods.

Additionally, DHS officials told us that not all states and localities 
that incurred additional costs have requested reimbursement; therefore, 
not all states and localities have submitted information to DHS on 
additional code-orange alert costs. Since the cost information does not 
include all costs incurred by states and localities for code-orange 
alerts, it should not be used to reach conclusions about the financial 
impact of these alerts on states and localities.

According to the cost information collected by DHS, as of April 14, 
2004, 40 states provided cost information to DHS in order to draw down 
funds to reimburse additional costs incurred during the March 17 to 
April 16, 2003, and May 20 to 30, 2003, code-orange alert periods. 
Based on this cost information, the reported state share of additional 
code-orange alert costs ranged from about $7,900 to about $8 million 
for both the first and second code-orange alert periods, which lasted a 
total of 40 days. The locality share of additional costs incurred 
during these two code-orange alert periods ranged from about $2,800 to 
about $28 million.

As of April 14, 2004, 33 states provided information on additional 
costs incurred during the December 21, 2003, to January 9, 2004, code-
orange alert period to DHS. Based on this information, additional costs 
incurred by state agencies for this code-orange alert period, which 
lasted 19 days, ranged from about $2,000 to about $7 million. 
Additional costs incurred by localities during this code-orange alert 
period ranged from about $3,000 to about $4 million. In general, the 
states that have numerous critical infrastructure sites, as identified 
by DHS, were the ones that reported the most additional code-orange 
alert costs collectively for the state and its localities. 
Additionally, DHS officials noted that overtime costs for law 
enforcement or security personnel appear to be the primary expense 
incurred by states and localities.

You also requested that we determine the extent to which DHS analyzes 
available cost data related to code-orange alerts and the role that OMB 
plays in providing guidance to DHS on capturing such costs. Though not 
required to do so, DHS has not analyzed the cost data collected to 
identify trends or assess the financial impact code-orange alerts have 
on states and localities. DHS has not tallied individual or overall 
state and local costs for any of the increased threat alert periods. 
However, as cost information submitted by states for reimbursement 
through SHSGP II and UASI II does not include all costs incurred by 
states and localities during code-orange alert periods, such analysis 
may not be appropriate using these data. According to an OMB 
representative, OMB has not provided specific guidance to DHS in 
capturing and totaling additional costs that states and localities 
incurred during periods of heightened national threat levels, nor is it 
required to do so. However, the representative noted that OMB is 
concerned about the funds that the federal government expends on these 
programs and activities.

Publicly Reported Cost Information May be Insufficient for Assessing 
Financial Impact of Code-Orange Alerts: 

Prior to this report, the U.S. Conference of Mayors and a Director with 
the Center for Strategic and International Studies have been the only 
organization or official to attempt to report estimates of costs 
incurred by various governmental entities in response to code-orange 
alerts. However, despite their efforts, the information reported by the 
U.S. Conference of Mayors and a Director at the Center for Strategic 
and International Studies Homeland Security Initiatives, may not be 
adequate to draw conclusions regarding the extent to which responding 
to code-orange alerts imposes a financial burden on governmental 
entities.

On March 27, 2003, the Conference of Mayors published a report[Footnote 
39] that estimated localities within the United States were spending 
$69.5 million per week in response to the March 17 to April 16, 2003, 
code-orange alert period. However, the U.S. Conference of Mayors' 
estimate may not provide an adequate basis for drawing conclusions 
regarding the financial impact of code-orange alerts on localities due 
to several factors such as: 

* lack of guidance to localities for developing their estimates,

* low response rate,

* limited scope, and: 

* the absence of independent verification or confirmation of amounts 
reported to the Conference of Mayors.

For example, the Conference of Mayors surveyed its membership asking 
them to report, "What are you spending extra per week?" However, 
according to a Conference of Mayors' official, members were not 
provided guidance on how to develop their costs. Thus, localities could 
have used different methodologies potentially resulting in the 
inclusion of certain costs in one locality's estimate that may not be 
included in another locality's estimate. Additionally, only 145 cities 
out of the U.S. Conference of Mayors total membership of 1,185 
responded to the survey, representing a 12 percent response rate. The 
scope for this study was also somewhat limited in that the U.S. 
Conference of Mayors issued its report and estimates prior to the 
conclusion of the March 17 to April 16, 2003, code-orange alert period. 
Thus, the estimate may not represent all costs incurred during that 
time period. Finally, the U.S. Conference of Mayors' staff did not take 
any additional steps to verify the validity of the estimates provided 
in response to its survey nor did they request that localities provide 
information to assist them in corroborating the localities' responses.

Similarly, a December 21, 2003, news release[Footnote 40] from the 
Center for Strategic and International Studies cited remarks by one of 
its directors who independently estimated that it costs the nation $1 
billion a week to implement protective measures in response to a code-
orange alert. According to the official that generated this estimate, 
it was an informal calculation based primarily on the funds 
appropriated by Congress to federal agencies for Operation Liberty 
Shield. The director divided the total amount of federal appropriations 
related to Operation Liberty Shield by the number of weeks that 
Operation Liberty Shield lasted. However, appropriated funds are not 
accurate representations of expenditures or costs incurred by federal 
agencies. Additionally, Operational Liberty Shield was a comprehensive 
national plan to increase protection for America's citizens and the 
nation's infrastructure during the war with Iraq. Thus, federal 
agencies may have taken additional protective measures in relation to 
the war that are not normally associated with code-orange alerts. As a 
result, this estimate may not be an accurate reflection of costs 
incurred by federal agencies in relation to other code-orange alerts.

Conclusions: 

DHS's implementation of the Homeland Security Advisory System is 
evolving, and the responses to our questionnaires from federal agencies 
and states suggest that DHS has made progress in providing more 
specific information to federal agencies and states and localities 
regarding the specific threats and risks they may face. However, DHS 
has not yet officially documented its protocols for communicating 
changes in the national threat level, as well as guidance and threat 
information, to federal agencies and states. The responses we received 
to our questionnaires indicated continuing confusion on the part of 
federal agencies and states and localities regarding the process and 
methods that DHS uses to communicate changes in the national threat 
level or recommendations for heightened security measures in specific 
regions or sectors. Without clearly defined and consistently applied 
communication policies and procedures, DHS may have difficulty managing 
the communication expectations of federal agencies and states and 
effectively communicating the methods, timing, and content of guidance 
and information--including information on protective measures and 
potential threats--the department provides to federal agencies and 
states. We believe that risk communication principles are applicable to 
the Homeland Security Advisory System and should be applied in DHS 
communications with federal agencies, states, and localities. Risk 
communication experts suggest that warnings should include the 
following principles to provide for early, open, and comprehensive 
information dissemination and for informed decision making: (1) 
communication through multiple methods, (2) timely notification, and 
(3) specific information about the nature, location, and timing of the 
threat and guidance on actions to take. To the extent that DHS does not 
communicate specific threat information and guidance on actions to 
take, federal agencies, states, and localities may not be able to 
effectively determine their levels of risk, the appropriate protective 
measures to implement in response to threats, and how to effectively 
and efficiently focus their limited resources on implementing those 
appropriate protective measures. Finally, it is important to note that 
although periods of code-orange alert do result in some additional 
costs for many federal agencies, states, and localities, the available 
cost data have many limitations, are not precise or complete, and thus, 
any conclusions based on these data must reflect those limitations.

Recommendations for Executive Action: 

We recommend that the Secretary of Homeland Security direct the Under 
Secretary for Information Analysis and Infrastructure Protection to 
take the following two actions: (1) document communication protocols 
for notifying federal agencies and states of changes in the national 
threat level and for providing guidance and threat information to these 
entities, including methods and time periods for sharing information, 
to better manage these entities' expectations regarding the methods, 
timing, and content of information shared; and (2) incorporate risk 
communication principles into the Homeland Security Advisory System to 
assist in determining and documenting information to provide to federal 
agencies and states, including, to the extent possible, information on 
the nature, location, and time periods of threats and guidance on 
protective measures to take in response to those threats.

Agency Comments: 

We provided a draft copy of this report to DHS for comment. DHS 
generally concurred with the findings and recommendations in the report 
and provided formal written comments, which are presented in appendix 
IX. In commenting on the draft report, DHS expressed concern that we 
generalize examples cited in the report across all states and 
localities, rather than characterizing the examples as isolated 
experiences. As previously discussed, we surveyed 56 states and 
territories to obtain information on their experiences related to 
national threat level changes. We discuss the results of this 
questionnaire throughout the report, including information on the 
number of states that provided similar responses. After citing the 
number of states that provide a similar response related to a code-
orange alert issue, we frequently use examples to illustrate those 
perspectives. We did not cite all examples we received, but rather 
those that most effectively illustrate our message. Thus, we believe 
the report accurately portrays state perspectives on code-orange 
alerts. In regard to DHS's comments on the examples we discuss related 
to localities, we believe that we appropriately cautioned the reader in 
the report's introduction and scope and methodology sections that 
information from the 16 localities we visited or from which we received 
questionnaire responses were used only as anecdotal examples and cannot 
be generalized across all localities in the United States. DHS also 
provided technical comments, which we have incorporated as appropriate.

We plan no further distribution of this report until 14 days after the 
date of this report. At that time, we will send copies of this report 
to the Subcommittee on Terrorism, Technology, and Homeland Security, 
Senate Committee on the Judiciary; the Subcommittee on National 
Security, Emerging Threats, and International Relations, House 
Committee on Government Reform; the Secretary of Homeland Security; the 
Director, Office of Management and Budget; and other interested 
parties. Copies will be made available to others on request. In 
addition, this report will be available at no charge on GAO's Web site 
at [Hyperlink, http://www.gao.gov].

If you or your staffs have any questions about this report, please 
contact me at (202) 512-8777 or by e-mail at 
[Hyperlink, jenkinswo@gao.gov]. Other GAO contacts and key contributors 
are listed in appendix X.

Signed by: 

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

[End of section]

Appendixes: 

Appendix I: Federal Agencies', States', Localities', and Foreign 
Countries' Threat Advisory Systems: 

Some federal agencies, states, localities, and foreign countries had 
threat advisory systems in place prior to the implementation of the 
Homeland Security Advisory System in March 2002, while others have 
since developed such systems. Some of these advisory systems were 
generally similar to the Homeland Security Advisory System, identifying 
different threat levels and requiring or suggesting certain protective 
actions be taken at each threat level. However, other systems differed 
in terms of structural and operational characteristics--such as the 
number of threat levels, the issuance of local or regional alerts, and 
the dissemination of threat advisories to the public.

Federal Agencies' Threat Advisory Systems: 

Seven of the 25 federal agencies[Footnote 41] responding to our 
questionnaire reported that they operated their own threat advisory 
systems prior to the establishment of the Homeland Security Advisory 
System in March 2002. One agency, for example, indicated that it 
developed its own five-level alert system 8 years ago to ensure 
protection of critical national security assets. These seven agencies 
currently follow the Homeland Security Advisory System as well as their 
own agency advisory system that conforms to the Homeland Security 
Advisory System. Three of these agencies also reported they could 
independently raise agency threat levels in response to threats or 
events that specifically affect their operations, regardless of whether 
the national threat level is raised at the same time. However, they 
generally cannot lower a facility threat level below that specified by 
the agency head or other designated agency authority. Further, although 
these agencies can operate at a threat level that is higher than the 
Homeland Security Advisory System national threat level (e.g., at code-
orange when the national threat level is code-yellow), they generally 
cannot operate at a lower threat level.

Unlike federal civilian agencies, Department of Defense (DOD) military 
installations are exempt from following the Homeland Security Advisory 
System. Accordingly, DOD operates under its own terrorist threat 
advisory system--known as the Force Protection Condition system. 
According to DOD officials, this system has five threat conditions--
normal, alpha, bravo, charlie, delta--indicating increasing threats of 
a terrorist attack, and the system prescribes mandatory minimum 
protective measures for all units and installations for each condition 
level. Each of the nine DOD Unified Combatant Commands[Footnote 42]--
for example, Central Command (Middle East and Asia)--establishes a 
force protection condition for the entire Command, based on a variety 
of information including threat and vulnerability assessments from such 
sources as the Department of Homeland Security (DHS), the Federal 
Bureau of Investigation (FBI), and the Defense Intelligence Agency. 
Beyond this level of protection, installation and unit commanders may 
then require additional protective measures, also based on intelligence 
assessments. This system, therefore, provides flexibility to base 
commanders to set protective measures based on local threat conditions. 
In contrast to civilian federal agencies, changes in the Homeland 
Security Advisory System do not necessarily result in changes in DOD's 
force protection condition. When the national threat level is raised to 
code-orange, DOD reviews and analyzes the same intelligence used by DHS 
to decide to raise the national threat level. Based on this analysis, 
DOD military commanders then decide whether any change is warranted in 
their own force protection condition.

States' and Localities' Threat Advisory Systems: 

As discussed earlier in the report, the Homeland Security Advisory 
System is not binding on states or localities and they are not required 
to conform their advisory systems to the Homeland Security Advisory 
System. However, 42 of the 43 states responding to our 
questionnaire[Footnote 43] indicated they currently followed the 
Homeland Security Advisory System, an equivalent state system, or both.

Eight of the states responding to our questionnaire and 1 locality we 
visited indicated that they had implemented their threat advisory 
systems prior to the Homeland Security Advisory System. For example, 1 
state told us that it amended its state emergency response plan and 
implemented a state advisory system in 1998, in response to the bombing 
of the federal building in Oklahoma City.

Twenty-two states responding to our questionnaire and 5 localities we 
visited indicated that they currently operate their own advisory 
systems. Most of these states reported that their systems provided 
information about the type or location of the threat, notified other 
governmental entities, and identified protective measures to be taken-
-while most localities indicated their systems conformed to the 
Homeland Security Advisory System. Some state and local advisory 
systems are similar to the Homeland Security Advisory System, but 
contain a different number of threat levels than the Homeland Security 
Advisory System. For example: 

* One state uses a numbered, 4-level threat advisory system, which is 
similar to the Homeland Security Advisory System but combines the 
levels of Blue and Yellow into a single threat level.

* One locality uses a 4-level advisory system, which does not include 
the Homeland Security Advisory System Blue threat level.

State and local advisory systems typically identified actions or 
protective measures that were to be taken at each threat level. For 
example, one state advisory system identified state, county, and local 
government actions, as well as specific security recommendations; while 
another identified actions for law enforcement agencies, non-law 
enforcement agencies, businesses, and citizens. One locality advisory 
system identified general security recommendations, as well as specific 
agency action checklists identifying a minimum level of response by 
agencies and departments within the locality. Some states and 
localities can raise their systems' threat levels based on specific 
threats or events independent of changes in the national threat level. 
One state, for example, raised its state threat level in early February 
2003 (prior to the February 2003 code-orange alert) in response to the 
crash of the space shuttle Columbia. One locality could change its 
threat level locally based on information and coordination with the 
local FBI office, the state's department of public safety, and the 
locality's police department.

Foreign Countries' Systems: 

The United Kingdom has a developed threat advisory system and processes 
for communicating threat information that are similar to the Homeland 
Security Advisory System but, unlike the U.S. system, it does not 
require that terrorism threat alerts be issued to the public. According 
to United Kingdom officials, under the United Kingdom's threat advisory 
system, (1) threat levels are assigned nationwide, as well as to 
specific regions and economic sectors; and (2) these levels and related 
changes are communicated to government and law enforcement agencies and 
private sector entities with responsibility for critical infrastructure 
protection, but not to the public. The United Kingdom does not publicly 
announce these threat warnings because it wants to protect its 
intelligence sources and avoid alerting terrorists that the government 
is aware of the threat. If terrorists know that the government is aware 
of their planned attack, the terrorists may change their plans and 
modes of operation, allowing them to carry out attacks that are even 
more lethal. Additionally, the United Kingdom is concerned about 
causing public anxiety regarding possible threats, when, in most cases, 
the public cannot do anything to mitigate the threat.

However, United Kingdom officials noted that if warnings are necessary 
to protect public safety from specific and credible threats, the United 
Kingdom will issue public warnings. Additionally, the United Kingdom 
instituted a public campaign to encourage public vigilance regarding 
potential terrorist activity. The campaign included posters warning the 
public to alert the police to unattended baggage, as shown in figure 1.

Figure 1: London Metropolitan Police Antiterror Alert Poster: 

[See PDF for image]

[End of figure]

Unlike the United Kingdom system, the Australian threat advisory system 
places a greater emphasis on publicizing changes in national threat 
levels. Australia implemented its current four-level, national 
counter-terrorist threat alert system in June 2003.[Footnote 44] As in 
the United States, a threat level condition is publicly announced and 
defined. Under the Australian system, each level of alert is defined as 
follows: 

* Low--no information to suggest a terrorist attack in Australia.

* Medium--medium risk of a terrorist attack in Australia.

* High--high risk of a terrorist attack in Australia.

* Extreme--terrorist attack is imminent or has occurred.

According to the Australian Attorney-General's Department, the system 
was not introduced as a reaction to any particular threat, but rather 
as an arrangement to help inform national preparation and planning and 
provide greater flexibility for responding to threats. Accordingly, 
should any intelligence information come to light which causes the 
government to change the assessed level of threat, the public is to be 
advised immediately.

Conversely, Norway does not have a nationwide threat advisory system. 
According to Norwegian officials, the Norwegian Police Security Service 
conducts threat assessments--which are graded into levels of low, 
medium, and high--and these are issued to government agencies with 
responsibilities for preventing and responding to threats within their 
jurisdictions. Unlike the Homeland Security Advisory System, there are 
no routines in place for communicating these threat assessments 
directly to local governments, private sector entities or the general 
public, but a decision to do so can be made depending on the situation. 
National government agencies and county governors can be instructed to 
take action to address various types of emergencies. However, 
municipalities, private sector entities, and the general public cannot 
be instructed to take specific action, except in situations where such 
instructions are warranted by law.

Like Norway, Germany does not have a uniform nationwide system of 
threat levels or requirements that specific actions be taken by 
governmental entities in response to different types of emergencies, 
including terror attacks. However, Germany does have a single, central 
24-hour communication center. For natural disasters and other threats, 
this center collects, screens, and processes the incoming information 
for subsequent forwarding to other government agencies regarding 
actions to take. According to German officials, the central 
communication center is concerned primarily with information 
management, rather than with controlling and warning functions. After 
receiving the threat assessments from the central communication center, 
governmental entities at the German federal and state level are each 
responsible for deciding which measures are to be taken, based on the 
threat.

According to German officials, threat information is communicated to 
affected persons, individual institutions, the business community, and 
the general public by law enforcement agencies, the state governments 
or the German federal government, according to the nature of the threat 
or danger concerned and the underlying situation. For example, the 
federal Criminal Police Office informs the business community on a 
regular basis as to the current assessment of the situation regarding 
Islamic terrorism.

Additionally, Germany has a satellite-based warning system that enables 
official warnings to be broadcast to the public. Government agencies 
and emergency situation centers are linked via satellite and are able 
to relay warnings and information on prevailing dangers to the 
connected media in a matter of seconds.

[End of section]

Appendix II: Scope and Methodology: 

To determine the process that the Department of Homeland Security (DHS) 
used to make decisions about changes in the national threat level, we 
met with and obtained information from DHS officials. We examined this 
information to identify DHS's processes for determining whether to 
raise or lower the national threat level and for issuing threat 
products to federal agencies, states, localities, and private sector 
entities. We also analyzed DHS threat products to determine the type of 
threat information and guidance on protective measures that DHS 
included in the products.

To determine guidance and information provided to federal agencies, 
states, and localities; protective measures these entities implemented 
in response to the three code-orange alerts from March 17 to April 16, 
2003; May 20 to 30, 2003; and December 21, 2003, to January 9, 2004; 
and additional costs these entities reported for the code-orange alert 
periods, we sent questionnaires to (1) 28 federal agencies;[Footnote 
45] and (2) the homeland security or emergency management offices in 
the 50 states, the District of Columbia, American Samoa, Guam, the 
Northern Islands, Puerto Rico, and the U.S. Virgin Islands. We selected 
the 28 federal agencies because they reported receiving homeland 
security funding for fiscal year 2003 to the Office of Management and 
Budget (OMB) and are Chief Financial Officers Act agencies. We sent the 
questionnaire to the 25 federal agencies that reported homeland 
security funding for fiscal year 2003 to OMB and to 3 other federal 
agencies that are Chief Financial Officers Act agencies but did not 
report homeland security funding for fiscal year 2003.[Footnote 46]

To develop the questionnaires, we met with and obtained information 
from 8 federal agencies, 4 states, the District of Columbia, and 9 
localities. Overall, the questionnaires sent to federal agencies and 
states were very similar. We obtained comments on draft versions of the 
federal questionnaire from the 8 federal agencies. We adapted the final 
version of the federal questionnaire to create the state questionnaire. 
We pretested the questionnaires with 4 federal agencies and 3 states 
and made relevant changes to the questions based on these pretests. See 
appendixes VII and VIII for the federal and state questionnaires.

As of April 20, 2004, we received questionnaire responses from 26 
federal agencies,[Footnote 47] which account for about 99 percent of 
total fiscal year 2003 nondefense homeland security funding as reported 
to OMB, and 43 states,[Footnote 48] for a 77 percent response rate. We 
made extensive efforts to encourage federal agencies and states to 
complete and return the questionnaires, such as contacting all 
nonrespondents on multiple occasions and sending additional copies of 
questionnaires when requested. We performed this work from October 2003 
through May 2004.

Because our surveys were not statistical sample surveys, but rather a 
survey of a nonprobability selection of federal agencies and a census 
of all states, there are no sampling errors. However, the practical 
difficulties of conducting any survey may introduce errors, commonly 
referred to as nonsampling errors. For example, measurement errors are 
introduced if difficulties exist in how a particular question is 
interpreted or in the sources of information available to respondents 
in answering a question. In addition, coding errors may occur if 
mistakes are entered into a database. We took extensive steps in the 
development of the questionnaires, the collection of data, and the 
editing and analysis of data to minimize total survey error. As noted 
above, to reduce measurement error and ensure questions and response 
categories were interpreted in a consistent manner, we pretested the 
questionnaires with several federal agencies and states. We edited all 
completed surveys for consistency, such as ensuring that responses were 
provided for all appropriate questions, and, if necessary, contacted 
respondents to clarify responses. All questionnaire responses were 
double key-entered into our database (i.e., the entries were 100 
percent verified), and random samples of the questionnaires were 
further verified for completeness and accuracy of data entry. 
Furthermore, all computer syntax was peer reviewed and verified by 
separate staff to ensure that the syntax was written and executed 
correctly.

In addition to sending questionnaires to 28 federal agencies and 56 
states, we conducted site visits at 12 localities (eight cities and 
four counties) and sent a questionnaire to another 8 localities. The 12 
localities were Atlanta and Fulton County, Georgia; Denver, Colorado 
Springs, and Douglas County, Colorado; Norfolk, Virginia; Portland and 
Wasco County, Oregon; Chicago and Cook County, Illinois; and Boston and 
Fitchburg, Massachusetts. We selected these localities based on the 
following criteria: the locality's receipt of urban area 
grants[Footnote 49] from DHS, geographic location, topography (e.g., 
inland, border, or seaport), and type of locality (e.g., metropolitan 
or nonmetropolitan area). We selected four cities and one county that 
received grants from DHS and four cities and three counties that did 
not. We also selected cities and counties from different geographic 
regions and with different topographic characteristics, as well as some 
cities and counties located in metropolitan areas and some cities and 
counties located in nonmetropolitan areas. We used a structured data 
collection instrument to interview emergency management officials and 
first responders in these localities. We selected the 8 localities that 
we surveyed based on their populations and geographic locations. We 
received responses from 4 of these localities;[Footnote 50] 3 with 
populations of less than 40,000 - Helena, Montana; Mankato, Minnesota; 
and Rock Springs, Wyoming - and 1 with a population of greater than 
40,000 - San Jose, California.

To determine the extent to which risk communication principles could be 
incorporated into the Homeland Security Advisory System, we spoke with 
and obtained information from individuals and organizations with 
expertise in homeland security issues and risk communication. We 
analyzed reports and documents from the ANSER Institute for Homeland 
Security, Carnegie Mellon University, the Center for Strategic and 
International Studies, the Department of Health and Human Services, the 
Harvard Center for Risk Analysis, the Oak Ridge National Laboratory, 
and the Partnership for Public Warning.

To assess the reliability of cost data provided by federal agencies on 
our questionnaire, we examined the cost information for obvious errors 
and inconsistencies and examined responses to the questionnaire items 
requesting information regarding the development of the cost data. If 
necessary, we contacted respondents to clarify responses and, when 
provided, reviewed documentation about the cost data. Federal agencies 
generated their cost data from various sources such as their financial 
accounting systems, credit card logs, and security services contracts. 
This cost information is not precise, nor do the costs likely represent 
all additional costs for the code-orange alert periods. In some cases, 
we have concerns about the reliability of the cost data source within 
particular agencies. For example, 6 of the 16 federal agencies reported 
that they extracted some of the code-orange alert cost data from their 
agencies' financial accounting systems. As reported in the fiscal year 
2005 President's Budget, 5 of these agencies' financial management 
performance had serious flaws as of December 31, 2003. Despite these 
limitations, we believe the cost data to be sufficiently reliable as 
indicators of general ranges of cost and overall trends. However, the 
data should not be used to determine the cumulative costs for all 
federal agencies for code-orange alert periods. See appendix V for 
additional information on cost information reported by federal 
agencies.

To determine the extent to which DHS has collected information on costs 
reported by states and localities during periods of code-orange alert, 
we met with and obtained information from DHS officials on costs that 
states and their localities submitted to DHS for reimbursement for 
increased critical infrastructure asset protection during the three 
code-orange alert periods. We examined this information to identify the 
methods used by DHS to collect cost information from states and 
localities. We also met with and obtained information from 
representatives of OMB regarding the extent to which the office 
provided guidance to DHS for collecting cost information from states 
and localities.

We reported these cost data that DHS collected from states and 
localities for the three code-orange alert periods only to illustrate 
the range of costs that states reported to DHS for reimbursement. Cost 
information submitted by states to DHS does not include all costs for 
states and localities during the code-orange alert periods. In 
particular, not all states submitted costs to DHS for reimbursement, 
and not all state agencies and localities in states that submitted cost 
information to DHS may have reported costs to their states for 
submission to DHS. In addition, the cost information submitted by 
states does not include additional costs for training or equipment and 
material purchases during code-orange alert periods because these costs 
are not reimbursable through the critical infrastructure protection 
grant programs. Moreover, some states have not finished validating 
costs they plan to submit for reimbursement. Despite these limitations, 
we believe the cost data to be sufficiently reliable as indicators of 
general ranges of costs that states submitted for reimbursement to DHS 
and overall trends. However, because this cost information from states 
and localities is not complete, it should not be used to reach 
conclusions about the financial impact of code-orange alerts on states 
and localities.

To determine the methodologies used by other organizations to develop 
estimates of costs reported by federal agencies, states, and localities 
during code-orange alert periods, we spoke with and obtained 
information from officials at the U.S. Conference of Mayors and the 
Director of the Center for Strategic and International Studies Homeland 
Security Initiatives regarding how this organization and this 
individual developed their estimates. We evaluated methodologies used 
by the U.S. Conference of Mayors and the Director of the Center for 
Strategic and International Studies Homeland Security Initiatives based 
on their scopes, data collection methods, and analyses to assess the 
reliability of the cost estimates. Moreover, we examined costs 
estimates reported by other organizations, including the Council on 
Foreign Relations, the National League of Cities, the National 
Association of Counties, and the International Association of Emergency 
Managers. We did not include these organizations' reports in our review 
because they did not specifically address costs associated with 
responses to increases in the national threat level.

To obtain information on federal agencies', states', and localities' 
threat advisory systems, we analyzed questionnaire responses and other 
documents to determine the number of federal agencies, states, and 
localities that had their own threat advisory systems in place prior to 
the establishment of the Homeland Security Advisory System as well as 
the number of federal agencies, states, and localities that follow 
their own threat advisory systems and the Homeland Security Advisory 
System. We reviewed documentation of the threat advisory systems that 
these federal agencies, states, and localities provided with their 
questionnaire responses to identify the characteristics of the systems, 
including systems' threat levels and protective measures and 
conformance to the Homeland Security Advisory System. We also met with 
and received documents from the Department of Defense on its Force 
Protection Condition System. Furthermore, we spoke with and obtained 
information from officials of four foreign countries--Australia, 
Germany, Norway, and the United Kingdom--on these countries' threat 
advisory systems and information sharing processes.[Footnote 51] We 
compared the characteristics of these systems with characteristics of 
the Homeland Security Advisory System to identify similarities and 
differences between the systems. We selected the four countries because 
they are democracies similar to the United States that have generally 
faced terrorist threats.

We conducted our work from July 2003 to May 2004 in accordance with 
generally accepted government auditing standards: 

[End of section]

Appendix III: Guidance and Information Federal Agencies and States 
Reported Using to Determine Protective Measures: 

Federal agencies and states responding to our questionnaire indicated 
that they used guidance from various sources, such as the Federal 
Emergency Management Agency (FEMA), the Federal Protective Service 
(FPS), the Department of Justice, and the White House, among other 
sources, to develop plans for responding to each Homeland Security 
Advisory System threat level. For example, 12 federal agencies reported 
using the Department of Justice's Vulnerability Assessment of Federal 
Facilities[Footnote 52] that established security levels for various 
types of federal facilities and minimum-security standards for each 
security level. In addition, to develop their response plans, 8 federal 
agencies indicated that they used Homeland Security Presidential 
Directive 3, which established the Homeland Security Advisory System 
and suggested general protective measures for each advisory system 
threat level. Six states reported using terrorism alerts and guidelines 
from FEMA to develop their plans for protective measures for national 
threat levels.

In addition to their response plans for national threat levels, federal 
agencies and states responding to our questionnaires reported using 
guidance and information from various sources to determine protective 
measures to implement or enhance in response to the three code-orange 
alert periods from March 17 to April 16, 2003; May 20 to 30, 2003; and 
December 21, 2003, to January 9, 2004. As shown in tables 6 and 7, 
these federal agencies reported using guidance and information and 
intelligence from such sources as the Department of Homeland Security 
(DHS), the Federal Bureau of Investigation (FBI), and the White House 
to determine measures to take in response to the third code-orange 
alert period in our review. These federal agencies generally reported 
that this guidance and information and intelligence was useful and 
timely. Results for the other two code-orange alert periods - March 17 
to April 16, 2003; and May 20 to 30, 2003 - were consistent with those 
reported in tables 6 and 7 for the third code-orange alert period.

Table 6: Number of Federal Agencies That Used Guidance from Sources and 
Found It Useful and Timely for the Code-Orange Alert Period December 
21, 2003, to January 9, 2004: 

Source of guidance: DHS[C]; 
Number of federal agencies n = 26: 
Number that reported using guidance: 16; 
Number that reported that the guidance was useful[A]: 14; 
Number that reported that the guidance was timely[B]: 11.

Source of guidance: FBI; 
Number of federal agencies n = 26: 
Number that reported using guidance: 9; 
Number that reported that the guidance was useful[A]: 9; 
Number that reported that the guidance was timely[B]: 9.

Source of guidance: White House; 
Number of federal agencies n = 26: 
Number that reported using guidance: 6; 
Number that reported that the guidance was useful[A]: 5; 
Number that reported that the guidance was timely[B]: 5.

Source of guidance: Local law enforcement; 
Number of federal agencies n = 26: 
Number that reported using guidance: 3; 
Number that reported that the guidance was useful[A]: 3; 
Number that reported that the guidance was timely[B]: 3.

Source: GAO analysis of questionnaire data.

[A] We asked federal agencies to indicate whether the guidance they 
received was very useful, somewhat useful, or of little or nor use. 
Useful reflects respondents' ratings of very useful and somewhat 
useful.

[B] We also asked agencies to indicate whether the guidance they 
received was timely by responding yes or no.

[C] In the questionnaire we sent to DHS, we did not include DHS as a 
choice for guidance used to determine protective measures to take 
during the three code-orange alert periods.

[End of table]

Table 7: Number of Federal Agencies That Used Information and 
Intelligence from Sources and Found It Useful and Timely for the Code-
Orange Alert Period December 21, 2003, to January 9, 2004: 

Source of information/intelligence: DHS[C]; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 16; 
Number that reported that the information and intelligence was 
useful[A]: 14; 
Number that reported that the information and intelligence was 
timely[B]: 14.

Source of information/intelligence: FBI; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 17; 
Number that reported that the information and intelligence was 
useful[A]: 16; 
Number that reported that the information and intelligence was 
timely[B]: 15.

Source of information/intelligence: White House; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 8; 
Number that reported that the information and intelligence was 
useful[A]: 7; 
Number that reported that the information and intelligence was 
timely[B]: 7.

Source of information/intelligence: Local law enforcement; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 7; 
Number that reported that the information and intelligence was 
useful[A]: 7; 
Number that reported that the information and intelligence was 
timely[B]: 6.

Source of information/intelligence: National Joint Terrorism Task 
Force[D]; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 11; 
Number that reported that the information and intelligence was 
useful[A]: 11; 
Number that reported that the information and intelligence was 
timely[B]: 10.

Source of information/intelligence: Agency intelligence sources; 
Number of federal agencies n = 26: 
Number that reported using information and intelligence: 9; 
Number that reported that the information and intelligence was 
useful[A]: 9; 
Number that reported that the information and intelligence was 
timely[B]: 8.

Source: GAO analysis of questionnaire data.

[A] We asked federal agencies to indicate whether the information and 
intelligence they received was very useful, somewhat useful, or of 
little or nor use. Useful reflects respondents' ratings of very useful 
and somewhat useful.

[B] We also asked agencies to indicate whether the information and 
intelligence they received was timely by responding yes or no.

[C] In the questionnaire we sent to DHS, we did not include DHS as a 
choice for information and intelligence used to determine protective 
measures to take during the three code-orange alert periods.

[D] The task force is comprised of numerous federal agencies co-
located in the Strategic Information and Operations Center at FBI 
headquarters. This task force provides a central fusion point for 
terrorism information and intelligence to the Joint Terrorism Task 
Forces, which include state and local law enforcement officers, federal 
agents, and other federal personnel who work in the field to prevent 
and investigate acts of terrorism.

[End of table]

As shown in tables 8 and 9, states responding to our questionnaire also 
indicated that they used guidance and information from sources such as 
DHS, other federal entities, and state, territory, and local law 
enforcement agencies to determine actions to take in response to the 
third code-orange alert period. These states generally reported that 
this guidance and information and intelligence was useful and timely. 
Results for the other two code-orange alert periods in our review were 
similar to those reported in tables 8 and 9.

Table 8: Number of States That Used Guidance from Sources and Found It 
Useful and Timely for the Code-Orange Alert Period December 21, 2003, 
to January 9, 2004: 

Source of guidance: DHS; 
Number of states n = 41[A]: 
Number that reported using guidance: 34; 
Number that reported that guidance was useful[B]: 30; 
Number that reported that guidance was timely[C]: 29.

Source of guidance: Other federal entity, such as the FBI; 
Number of states n = 41[A]: 
Number that reported using guidance: 30; 
Number that reported that guidance was useful[B]: 27; 
Number that reported that guidance was timely[C]: 28.

Source of guidance: Other state, territory, or local government 
agency; 
Number of states n = 41[A]: 
Number that reported using guidance: 15; 
Number that reported that guidance was useful[B]: 15; 
Number that reported that guidance was timely[C]: 15.

Source of guidance: Regional, state, or local law enforcement 
agencies; 
Number of states n = 41[A]: 
Number that reported using guidance: 19; 
Number that reported that guidance was useful[B]: 18; 
Number that reported that guidance was timely[C]: 18.

Source of guidance: Governor or legislature; 
Number of states n = 41[A]: 
Number that reported using guidance: 20; 
Number that reported that guidance was useful[B]: 20; 
Number that reported that guidance was timely[C]: 20.

Source of guidance: Private sector organizations; 
Number of states n = 41[A]: 
Number that reported using guidance: 10; 
Number that reported that guidance was useful[B]: 9; 
Number that reported that guidance was timely[C]: 10.

Source: GAO analysis of questionnaire data.

[A] One of the states responding to our questionnaire did not provide 
responses to the questions on guidance and information and intelligence 
used to determine protective measures to take for the three code-orange 
alert periods. Additionally, 1 reported that it did not follow the 
Homeland Security Advisory System. Thus, these 2 states are not 
included in our analysis of guidance and information and intelligence 
used to determine protective measures.

[B] We asked states to indicate whether the guidance they received was 
very useful, somewhat useful, or of little or nor use. Useful reflects 
respondents' ratings of very useful and somewhat useful.

[C] We also asked states to indicate whether the guidance they received 
was timely by responding yes or no.

[End of table]

Table 9: Number of States That Used Information and Intelligence from 
Sources and Found It Useful and Timely for the Code-Orange Alert 
Period December 21, 2003, to January 9, 2004: 

Source of information/intelligence: DHS; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 32; 
Number that reported that information and intelligence was useful[B]: 
29; 
Number that reported that information and intelligence was timely[C]: 
27.

Source of information/intelligence: Other federal entity, such as the 
FBI; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 30; 
Number that reported that information and intelligence was useful[B]: 
28; 
Number that reported that information and intelligence was timely[C]: 
27.

Source of information/intelligence: Other state, territory, or local 
government agency; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 14; 
Number that reported that information and intelligence was useful[B]: 
14; 
Number that reported that information and intelligence was timely[C]: 
14.

Source of information/intelligence: Regional, state, or local law 
enforcement agencies; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 21; 
Number that reported that information and intelligence was useful[B]: 
20; 
Number that reported that information and intelligence was timely[C]: 
19.

Source of information/intelligence: Governor or legislature; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 11; 
Number that reported that information and intelligence was useful[B]: 
11; 
Number that reported that information and intelligence was timely[C]: 
11.

Source of information/intelligence: Private sector organizations; 
Number of states n = 41[A]: 
Number that reported using information and intelligence: 10; 
Number that reported that information and intelligence was useful[B]: 
10; 
Number that reported that information and intelligence was timely[C]: 
10.

Source: GAO analysis of questionnaire data.

[A] One of the states responding to our questionnaire did not provide 
responses to the questions on guidance and information and intelligence 
used to determine protective measures to take for the three code-orange 
alert periods. Additionally, 1 state reported that it did not follow 
the Homeland Security Advisory System. Thus, these 2 states are not 
included in our analysis of guidance and information and intelligence 
used to determine protective measures.

[B] We asked states to indicate whether the information and 
intelligence they received was very useful, somewhat useful, or of 
little or nor use. Useful reflects respondents' ratings of very useful 
and somewhat useful.

[C] We also asked states to indicate whether the information and 
intelligence they received was timely by responding yes or no.

[End of table]

[End of section]

Appendix IV: Most Commonly Implemented Protective Measures, Measures 
Tested, and Methods of Confirmation: 

Federal agencies and states responding to our questionnaires reported 
having a variety of protective measures in place for responding to the 
three code-orange alert periods from March 17 to April 16, 2003; May 20 
to 30, 2003; and December 21, 2003, to January 9, 2004, regardless of 
whether the measures were most commonly enhanced, maintained at pre-
code-orange alert levels, or implemented solely in response to the 
code-orange alerts. Table 10 provides examples of the protective 
measures that federal agencies most commonly reported having in place 
for the third code-orange alert period in our review. Results from the 
other two code-orange alert periods are consistent with those reported 
in the following table for the third code-orange alert period.

Table 10: Protective Measures Most Commonly Reported by Federal 
Agencies Responding to Our Questionnaire for the December 21, 2003, to 
January 9, 2004, Code-Orange Alert Period: 

Protective measures: Implement facility patrols; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 24; 
Number that indicated no change in measure that was already in 
place[B]: 3; 
Number that enhanced measure that was already in place[C]: 21; 
Number that implemented measure for code- orange only[D]: 0.

Protective measures: Activate monitoring systems; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 24; 
Number that indicated no change in measure that was already in 
place[B]: 16; 
Number that enhanced measure that was already in place[C]: 8; 
Number that implemented measure for code- orange only[D]: 0.

Protective measures: Screen mail and deliveries; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 24; 
Number that indicated no change in measure that was already in 
place[B]: 12; 
Number that enhanced measure that was already in place[C]: 12; 
Number that implemented measure for code- orange only[D]: 0.

Protective measures: Screen facility visitors; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 23; 
Number that indicated no change in measure that was already in 
place[B]: 12; 
Number that enhanced measure that was already in place[C]: 11; 
Number that implemented measure for code- orange only[D]: 0.

Protective measures: Activate instrusion detection systems; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 23; 
Number that indicated no change in measure that was already in 
place[B]: 19; 
Number that enhanced measure that was already in place[C]: 4; 
Number that implemented measure for code- orange only[D]: 0.

Protective measures: Escort facility visitors; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 22; 
Number that indicated no change in measure that was already in 
place[B]: 10; 
Number that enhanced measure that was already in place[C]: 9; 
Number that implemented measure for code- orange only[D]: 3.

Protective measures: Ensure that response procedures and plans are up 
to date; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 21; 
Number that indicated no change in measure that was already in 
place[B]: 4; 
Number that enhanced measure that was already in place[C]: 17; 
Number that implemented measure for code-orange only[D]: 0.

Protective measures: Conduct emergency response drills and/or 
training; 
Number of federal agencies n = 24[A]: 
Number that reported measure: 20; 
Number that indicated no change in measure that was already in 
place[B]: 10; 
Number that enhanced measure that was already in place[C]: 10; 
Number that implemented measure for code-orange only[D]: 0.

Source: GAO analysis of questionnaire data.

[A] One federal agency responding to our questionnaire reported that 
it does not implement protective measures because it is located in a 
privately owned building and is not responsible for its own security. 
Another federal agency did not provide a response to questions related 
to the protective measures taken during code-orange alerts due to 
security concerns. Thus, these 2 federal agencies are not included in 
our analysis of protective measures.

[B] No change in a protective measure indicates that the measure was 
already in place prior to the code-orange alert period and continued at 
the same level of use or frequency during a code-orange alert.

[C] The enhancement of a measure that was already in place refers to 
the increased use of an existing protective measure, such as more 
frequent facility security patrols or increased volume of mail 
screened.

[D] The implementation of a measure for code-orange only refers to the 
use of an additional measure that was not already in place solely to 
respond to a code-orange alert.

[End of table]

Table 11 provides examples of the protective measures that states most 
commonly reported having in place during the third code-orange alert 
period in our review. Results for the other two code-orange alert 
periods in our review are similar to those reported in table 11.

Table 11: Protective Measures Most Commonly Reported by States 
Responding to Our Questionnaire for the December 21, 2003, to January 
9, 2004, Code-Orange Alert Period: 

Protective measures: Alert other state, territorial, local and private 
sector counterparts; 
Number of states n = 40[A]: 
Number that reported measure: 38; 
Number that indicated no change in measure that was already in 
place[B]: 4; 
Number that enhanced measure that was already in place[C]: 21; 
Number that implemented measure for code- orange only[D]: 13.

Protective measures: Ensure response and communication plans are up to 
date; 
Number of states n = 40[A]: 
Number that reported measure: 36; 
Number that indicated no change in measure that was already in 
place[B]: 12; 
Number that enhanced measure that was already in place[C]: 21; 
Number that implemented measure for code-orange only[D]: 3.

Protective measures: Issue recommendations or guidance for protective 
measures; 
Number of states n = 40[A]: 
Number that reported measure: 35; 
Number that indicated no change in measure that was already in 
place[B]: 2; 
Number that enhanced measure that was already in place[C]: 25; 
Number that implemented measure for code-orange only[D]: 8.

Protective measures: Implement facility security patrols; 
Number of states n = 40[A]: 
Number that reported measure: 34; 
Number that indicated no change in measure that was already in 
place[B]: 3; 
Number that enhanced measure that was already in place[C]: 26; 
Number that implemented measure for code-orange only[D]: 5.

Protective measures: Place vehicle barriers around facilities; 
Number of states n = 40[A]: 
Number that reported measure: 31; 
Number that indicated no change in measure that was already in 
place[B]: 8; 
Number that enhanced measure that was already in place[C]: 17; 
Number that implemented measure for code-orange only[D]: 6.

Protective measures: Prepare for possible biological, chemical, or 
radiological attacks; 
Number of states n = 40[A]: 
Number that reported measure: 30; 
Number that indicated no change in measure that was already in 
place[B]: 16; 
Number that enhanced measure that was already in place[C]: 13; 
Number that implemented measure for code- orange only[D]: 1.

Protective measures: Screen mail and deliveries; 
Number of states n = 40[A]: 
Number that reported measure: 30; 
Number that indicated no change in measure that was already in 
place[B]: 19; 
Number that enhanced measure that was already in place[C]: 9; 
Number that implemented measure for code-orange only[D]: 2.

Protective measures: Restrict parking near facilities; 
Number of states n = 40[A]: 
Number that reported measure: 30; 
Number that indicated no change in measure that was already in 
place[B]: 5; 
Number that enhanced measure that was already in place[C]: 16; 
Number that implemented measure for code-orange only[D]: 9.

Protective measures: Limit number of facility access points; 
Number of states n = 40[A]: 
Number that reported measure: 30; 
Number that indicated no change in measure that was already in 
place[B]: 11; 
Number that enhanced measure that was already in place[C]: 14; 
Number that implemented measure for code-orange only[D]: 5.

Source: GAO analysis of questionnaire data.

[A] Two states responding to our questionnaire did not provide 
responses on protective measures they had in place for the three 
periods of code-orange alert. Additionally, 1 state reported that it 
did not follow the Homeland Security Advisory System. Thus, these 3 
states are not included in our analysis on protective measures.

[B] No change in a protective measure indicates that the measure was 
already in place prior to the code-orange alert period and continued at 
the same level of use or frequency during a code-orange alert.

[C] The enhancement of a measure that was already in place refers to 
the increased use of an existing protective measure, such as more 
frequent facility security patrols or increased volume of mail 
screened.

[D] The implementation of a measure for code-orange only refers to the 
use of an additional measure that was not already in place solely to 
respond to a code-orange alert.

[End of table]

To ensure that protective measures operate as intended and are 
implemented as planned, most of the federal agencies and states 
responding to our questionnaires indicated that they had conducted 
tests or exercises on the functionality and reliability of protective 
measures within the past year. Table 12 provides examples of protective 
measures on which federal agencies and states reported conducting 
tests and exercises.

Table 12: Number of Federal Agencies and States That Reported 
Conducting Tests or Exercises on the Functionality and Reliability of 
Protective Measures: 

Protective measures: Intrusion detection systems; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 25; 
Number of states that reported testing protective measure n = 37[B]: 
14.

Protective measures: Visitor and employee screening equipment and 
procedures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 24; 
Number of states that reported testing protective measure n = 37[B]: 
22.

Protective measures: Vehicle inspection equipment and procedures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 24; 
Number of states that reported testing protective measure n = 37[B]: 
23.

Protective measures: Baggage and cargo screening equipment and 
procedures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 16; 
Number of states that reported testing protective measure n = 37[B]: 
14.

Protective measures: Mail and delivery screening procedures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 25; 
Number of states that reported testing protective measure n = 37[B]: 
23.

Protective measures: Monitoring systems, such as surveillance cameras; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 25; 
Number of states that reported testing protective measure n = 37[B]: 
24.

Protective measures: Continuity of operations measures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 25; 
Number of states that reported testing protective measure n = 37[B]: 
21.

Protective measures: Emergency response measures; 
Number of federal agencies that reported testing protective measure 
n = 25[A]: 25; 
Number of states that reported testing protective measure n = 37[B]: 
32.

Source: GAO analysis of questionnaire data.

[A] One federal agency responding to our questionnaire reported that 
it does not implement protective measures because it is located in a 
privately owned building and is not responsible for its own security. 
Thus, this agency is not included in our analysis of protective 
measures tested by federal agencies.

[B] Six states responding to our questionnaire did not provide 
responses on the testing of protective measures they had in place for 
the three periods of code-orange alert. Thus, these 6 states are not 
included in our analysis of protective measures tested by states.

[End of table]

In addition, most of the federal agencies and states responding to our 
questionnaires reported receiving confirmation from component 
entities, offices, or personnel that protective measures were actually 
enhanced or implemented during the three code-orange alert periods. 
Table 13 provides examples of the methods by which federal agencies and 
states reported receiving confirmation from their component entities, 
offices, and personnel, for the code-orange alert period from December 
21, 2003, to January 9, 2004. Results for the other two code-orange 
alert periods from March 17 to April 16, 2003, and May 20 to 30, 2003, 
are consistent with those reported in table 13.

Table 13: Number of Federal Agencies and States That Reported Receiving 
Confirmation on the Implementation of Protective Measures through 
Various Methods for the Code-Orange Alert Period from December 21, 
2003, to January 9, 2004: 

Methods of confirmation: Oral notification of protective measures 
implementation; 
Number of federal agencies that reported receiving confirmation n = 
25[A]: 20; 
Number of states that reported receiving confirmation n = 41[B]: 35.

Methods of confirmation: Written notification of protective measures 
implementation; 
Number of federal agencies that reported receiving confirmation n = 
25[A]: 18; 
Number of states that reported receiving confirmation n = 41[B]: 23.

Methods of confirmation: Inspection of protective measures 
implementation; 
Number of federal agencies that reported receiving confirmation n = 
25[A]: 22; 
Number of states that reported receiving confirmation n = 41[B]: 16.

Source: GAO analysis of questionnaire data.

[A] One federal agency responding to our questionnaire reported that 
it does not implement protective measures because it is located in a 
privately owned building and is not responsible for its own security. 
Thus, this agency is not included in our analysis of the confirmation 
of protective measures.

[B] One state responding to our questionnaire did not provide responses 
on the receipt of confirmation of the implementation of protective 
measures. Additionally, 1 state reported that it did not follow the 
Homeland Security Advisory System. Thus, these 2 states are not 
included in our analysis of the confirmation of protective measures.

[End of table]

[End of section]

Appendix V: Cost Information Provided by Federal Agencies, States, and 
Localities: 

Cost Information Provided by Federal Agencies: 

Table 14: Number of Federal Agencies That Provided Cost Information and 
the Type of Cost Information They Provided for Each Code-Orange Alert 
Period under Review: 

Cost information: Provided code-orange alert cost information; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 21; 
May 20 to 30, 2003: 21; 
December 21, 2003, to January 9, 2004: 21.

Cost information: * Incurred additional costs; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 16; 
May 20 to 30, 2003: 15; 
December 21, 2003, to January 9, 2004: 15.

Cost information: * Provided cost estimates; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 13; 
May 20 to 30, 2003: 13; 
December 21, 2003, to January 9, 2004: 13.

Cost information: * Provided actual costs; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 3; 
May 20 to 30, 2003: 2; 
December 21, 2003, to January 9, 2004: 2.

Cost information: * Provided costs for immediately preceding code-
yellow alert period; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 12; 
May 20 to 30, 2003: 11; 
December 21, 2003, to January 9, 2004: 11.

Cost information: * Did not incur additional costs; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 5; 
May 20 to 30, 2003: 6; 
December 21, 2003, to January 9, 2004: 6.

Cost information: Did not provide code-orange alert cost information; 
Number of federal agencies n = 26: 
March 17 to April 16, 2003: 5; 
May 20 to 30, 2003: 5; 
December 21, 2003, to January 9, 2004: 5.

Source: GAO analysis of questionnaire data. 

[End of table]

For each code-orange alert period, the federal agencies that reported 
incurring additional costs generally provided cost estimates. Many of 
these agencies reported using similar methods to develop their 
estimates. For example, 8 of these agencies reported using the 
additional hours accumulated by security personnel during code-orange 
alerts and the hourly rates of security personnel to develop estimates 
for additional personnel costs incurred during code-orange alerts. The 
majority of additional costs reported by federal agencies are personnel 
costs. One federal agency indicated that it provided cost estimates 
rather than actual costs for the code-orange alert periods because, 
given the short durations of the code-orange alerts and the changes 
required to track these limited costs in the accounting system, it was 
more efficient to utilize security cost estimates.

Six federal agencies that provided cost information extracted at least 
some of their cost data from their agencies' financial accounting 
systems. However, as reported in the fiscal year 2005 President's 
Budget, 5 of these agencies' financial management performance had 
serious flaws as of December 31, 2003. Thus, we have concerns regarding 
the accuracy of the cost information these 5 agencies provided to us.

Agencies that did not provide cost information indicated that either 
they did not track additional code-orange alert costs or they did not 
have the capability to separate additional code-orange alert costs from 
their total annual security-related costs.

Cost Information Provided by States: 

In our questionnaire, we asked states to provide information on 
additional costs incurred by the state during the three code-orange 
alert periods in our review. However, of the 42 states that responded 
to our questionnaire and follow the Homeland Security Advisory System, 
only 6 reported additional costs incurred by state agencies during at 
least one of the three code-orange alerts in our review. Therefore, we 
did not collect sufficient cost information from our questionnaire to 
provide ranges or assess general trends in costs incurred by states 
during code-orange alert periods.

Twenty-two of the 42 states that responded to our questionnaire and 
follow the Homeland Security Advisory System provided us with cost 
information they submitted to DHS in order to be reimbursed for state 
and local critical infrastructure protection costs through the State 
Homeland Security Grant Program - Part II and the Urban Areas Security 
Initiative - Part II. As discussed previously in this report, through 
these two grant programs, DHS offered financial assistance to reimburse 
costs incurred by state agencies and localities as a result of 
increased security measures at critical infrastructure sites during the 
period of hostilities with Iraq and for other periods of heightened 
alert. We obtained this critical infrastructure protection cost 
information from DHS for 40 states and their localities for the March 
17 to April 16, 2003, and May 20 to 30, 2003, code-orange alert periods 
and for 33 states and their localities for the December 21, 2003, to 
January 9, 2004, code-orange alert period. However, this cost 
information does not represent all additional costs incurred by states 
and localities during code-orange alert periods.

Cost Information Provided by Localities: 

We also received information on additional code-orange alert costs from 
14 select metropolitan and rural localities. However, information on 
localities' costs is most appropriately used anecdotally, as these 
cities and counties represent a small, nonprobability sample of 
localities within the United States.

The rural localities from which we obtained information indicated that 
they did not incur additional costs for any of the code-orange alert 
periods because they did not take significant action in response to the 
alert. These localities explained that they had insufficient resources 
to do so or did not perceive their localities to be at risk.

[End of section]

Appendix VI: Acknowledgment of Agency and Government Contributors: 

We would like to acknowledge the time and effort made by agencies and 
governments that provided information by responding to questionnaires 
and talked with us during site visits.

Federal Agencies: 

Department of Agriculture: 
Department of Commerce: 
Department of Education: 
Department of Energy: 
Department of Health and Human Services: 
Department of Homeland Security: 
Department of Housing and Urban Development: 
Department of the Interior: 
Department of Justice: 
Department of Labor: 
Department of State: 
Department of Transportation: 
Department of the Treasury: 
Department of Veterans Affairs: 
Corporation for National and Community Service: 
Environmental Protection Agency: 
Federal Communications Commission: 
General Services Administration: 
National Aeronautics and Space Administration: 
National Archives and Records Administration: 
National Science Foundation: 
Nuclear Regulatory Commission: 
Small Business Administration: 
Smithsonian Institution: 
Social Security Administration: 
United States Holocaust Memorial Museum: 

States and Territories: 

Alabama:
Alaska: 
Arizona: 
Arkansas: 
Connecticut: 
Delaware: 
Florida: 
Georgia: 
Idaho: 
Illinois: 
Iowa: 
Kansas: 
Kentucky: 
Louisiana: 
Maine: 
Massachusetts: 
Michigan: 
Minnesota: 
Mississippi: 
Missouri: 
Montana: 
Nebraska: 
New Hampshire: 
New Jersey: 
New Mexico: 
New York: 
North Carolina: 
North Dakota: 
Ohio: 
Oklahoma: 
Pennsylvania: 
South Carolina: 
South Dakota: 
Tennessee: 
Texas: 
Utah: 
Vermont: 
Washington: 
West Virginia: 
Wisconsin: 
Wyoming: 
Guam: 
Puerto Rico: 

Localities: 

Atlanta, Ga.: 
Fulton County, Ga.: 
Denver, Colo.: 
Douglas County, Colo.: 
Colorado Springs, Colo.: 
Portland, Ore.: 
Wasco County, Ore.: 
Boston, Mass.: 
Fitchburg, Mass.: 
Norfolk, Va.: 
Chicago, Ill.: 
Cook County, Ill.: 
Mankato, Minn.: 
Helena, Mont.: 
San Jose, Calif.: 
Rock Springs, Wyo.: [Footnote 53]

[End of section]

Appendix VII: Federal Agency Questionnaire: 

[See PDF for image]

[End of figure]

[End of section]

Appendix VIII: State and Territory Questionnaire: 

[See PDF for image]

[End of figure]

[End of section]

Appendix IX: Agency Comments: 

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

Homeland Security:

June 8, 2004:

William O. Jenkins, Jr.
Director, Homeland Security and Justice Issues: 
United States General Accounting Office:
441 G Street, NW: 
Washington, DC 20548:

Dear Mr. Jenkins:

Thank you for the opportunity to review and comment on the GAO Draft 
Report, "Homeland Security: Communication Protocols and Risk 
Communication Principles Can Assist in Refining the Advisory System 
(GAO-04-682). We concur with the purpose of the report and generally 
concur with its contents. We fully agree that the provision of accurate 
and timely threat information is critical to the nation's security. 
Your report effectively discusses many of the important issues 
in this area and will be of great value. 

While the report carefully notes when only one state or a particular 
entity reported or observed something, there are instances where the 
report uses the term "one state" or "one locality" as an example (as 
noted in the critical asset discussion for Liberty Shield). This could 
be misleading to some readers who might not look carefully and jump to 
the conclusion that one particular point of view is an accurate 
characterization of the whole. 

With respect to the two recommendations, we concur subject to the 
comments provided:

Recommendation 1: The Under Secretary for Information Analysis and 
Infrastructure Protection should document communication protocols for 
notifying federal agencies and states of changes in the national threat 
level and for providing guidance and threat information to these 
entities, including methods and time periods for sharing information, 
to better manage these entities' expectations regarding the methods, 
timing, and content of information shared.

Response: Concur. I am pleased to report that the Department is moving 
forward and making significant progress in developing a thoughtfu and 
balanced approach to documenting these protocols. Communication 
protocols must provide clear guidance to federal agencies and states. 
However, the Department must also retain provide appropriate 
flexibility in adapting threat communications to a variety of 
circumstances. The Department is moving deliberately to create such 
flexible communications protocols and continues to work with federal 
agencies and states in refining these protocols.

Recommendation 2: The Under Secretary for Information Analysis and 
Infrastructure Protection should incorporate risk communication 
principles into the Homeland Security Advisory System to assist in 
determining and documenting information to provide to federal 
agencies and states, including, to the extent possible, information on 
the nature, location, and time periods of threats and guidance on 
protective measures to take in response to those threats.

Response: Concur. The Department is also committed to incorporating 
appropriate risk communications principles and procedures when we 
develop our written communications protocols, As the report notes, the 
cited risk communication procedures have primarily been 
developed in response to threats such as severe weather, traffic 
situations, and hazardous materials contamination. The report implies, 
and we fully agree, that terrorist threats are substantially different 
in nature and as such full application of the risk communication 
principles will be somewhat problematic in many situations, For 
example, it will be rare that we ever have the degree of specificity in 
threat information that we or the receiving audience would prefer.

Additionally, we have forwarded a number of technical comments, under 
separate cover, which we believe will add value to and improve the 
accuracy of this report.

We look forward to receiving your final report. If you or your staff 
have any questions or need additional information, contact John Daley 
at 202-282-8381.

Sincerely, 

Signed by: 

Anna F. Dixon: 
Director, Bank card Programs and GAO/OIG Liaison: 

[End of section]

Appendix X: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

William O. Jenkins, Jr. (202) 512-8777 Debra B. Sebastian (202) 512-
9385: 

Staff Acknowledgments: 

In addition to the individuals named above, David P. Alexander, 
Fredrick D. Berry, Nancy A. Briggs, Kristy N. Brown, Philip D. Caramia, 
Christine F. Davis, Michele Fejfar, Rebecca Gambler, Catherine M. 
Hurley, Gladys Toro, Jonathan R. Tumin, Tamika S. Weerasingha, and 
Kathryn G. Young made key contributions to this report.

[End of section]

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Security." The Washington Quarterly, vol. 27, no. 1 (2003-2004) 37-52.

Fischoff, Baruch. "Assessing and Communicating the Risks of Terrorism." 
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Stephen D. Nelson, and Stephen J. Lita. Washington, D.C.: American 
Association for the Advancement of Science, 2003: 51-64.

Fischoff, Baruch, Roxana M. Gonzalez, Deborah A. Small, and Jennifer S. 
Lerner. "Evaluating the Success of Terror Risk Communications." 
Biosecurity and Bioterrorism: Biodenfense Strategy, Practice, and 
Science, vol. 1, no. 4 (2003) 255-258.

Gray, George M., and David P. Ropeik. "Dealing with the Dangers of 
Fear: The Role of Risk Communication." Health Affairs, vol. 21, no. 6 
(2002) 106-116.

Mileti, Dennis S., and John H. Sorensen. Communication of Emergency 
Public Warnings: A Social Science Perspective and State-of-the-Art 
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Agency, August 1990.

Mitchell, Charles, and Chris Decker. "Apply Risk-Based Decision-Making 
Methods and Tools to U.S. Navy Antiterrorism Capabilities." Journal of 
Homeland Security. February 2004.

National Research Council. Improving Risk Communication. Washington, 
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Partnership for Public Warning. A National Strategy for Integrated 
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(440224): 

FOOTNOTES

[1] According to the National Research Council, risk communication is 
the exchange of information among individuals and groups regarding the 
nature of risk, reactions to risk messages, and legal and institutional 
approaches to risk management. 

[2] See U.S. General Accounting Office, Homeland Security: Risk 
Communication Principles May Assist in Refinement of the Homeland 
Security Advisory System, GAO-04-538T (Washington, D.C.: Mar. 16, 
2004). 

[3] Office of Management and Budget, 2003 Report to Congress on 
Combating Terrorism (Washington, D.C.: September 2003).

[4] One state for which we received a questionnaire response indicated 
that it did not follow the Homeland Security Advisory System. We 
analyzed questionnaire responses for the other 42 states that indicated 
they followed the Homeland Security Advisory System.

[5] P.L. 101-576 (Nov. 15, 1990). Three of the federal agencies to 
which we sent a questionnaire are Chief Financial Officers Act agencies 
but did not report receiving homeland security funding in fiscal year 
2003 to the Office of Management and Budget. We sent our questionnaire 
to these three federal agencies to include all Chief Financial Officers 
Act agencies in our review, and thus these 28 federal agencies 
accounted for about 91 percent of total nondefense gross federal 
obligations for fiscal year 2003. 

[6] The 12 localities are Atlanta and Fulton County, Georgia; Denver, 
Colorado Springs, and Douglas County, Colorado; Norfolk, Virginia; 
Portland and Wasco County, Oregon; Chicago and Cook County, Illinois; 
and Boston and Fitchburg, Massachusetts.

[7] We selected the 12 localities based on a mix of these criteria. For 
example, 5 of the localities we selected received urban areas grants 
from DHS, while 7 did not. Nine of the localities we visited were in 
metropolitan areas, while 3 were not.

[8] The 8 localities are Helena, Montana; Mankato, Minnesota; Rock 
Springs, Wyoming; San Jose, California; Miami/Dade County, Florida; 
Seattle, Washington; Jamestown, North Dakota; and New York City, New 
York.

[9] One of the localities from which we received a questionnaire 
response indicated that it did not follow the Homeland Security 
Advisory System. We analyzed questionnaire responses for the other 3 
localities that indicated following the Homeland Security Advisory 
System.

[10] Members of the Homeland Security Council include the President; 
the Vice President; the Secretaries of Defense, Health and Human 
Services, Homeland Security, Transportation, and the Treasury; the 
Attorney General; the Director of the Federal Emergency Management 
Agency; the Director of the Federal Bureau of Investigation; the 
Director of Central Intelligence; and the Assistant to the President 
for Homeland Security. 

[11] We calculated the additional code-orange alert costs for the March 
17 to April 16, 2003, and May 20 to 30, 2003, code-orange alert periods 
as a percentage of agencies' fiscal year 2003 homeland security funding 
because these are the only two code-orange alert periods in our review 
that occurred during fiscal year 2003.

[12] Typically, there are indirect costs associated with redirection of 
resources from one agency function to another. Federal agencies 
responding to our questionnaire were not able to quantify such indirect 
costs. However, they provided examples of redirection of resources that 
may have caused them to incur such costs. 

[13] The Homeland Security Advisory System does not directly apply to 
the armed forces, including their military facilities. Rather, the 
Department of Defense's Force Protection Condition system rates threats 
and sets specific measures for military facilities.

[14] DHS components and offices collaborate and share responsibility 
for notifying federal agencies, states, localities, the private sector, 
and the public of changes in the national threat level.

[15] P.L. 107-296, Sec. 201(d)(7).

[16] According to HSPD-3, threat levels may be assigned for the entire 
nation, or they may be set for a particular geographic area or 
industrial sector.

[17] DHS's Homeland Security Operations Center and its IAIP Directorate 
monitor threats and conduct information assessments on a daily basis. 
The Center is comprised of representatives from DHS component entities, 
other federal agencies, and local law enforcement agencies. 

[18] The Terrorist Threat Integration Center is responsible for 
analyzing and sharing terrorist-related information that is collected 
domestically and abroad. It is an interagency joint venture that is 
comprised of elements of DHS, the FBI's Counterterrorism Division, the 
Director of Central Intelligence Counterterrorist Center, the 
Department of Defense, and other agencies.

[19] Under HSPD-5, the Secretary can change the national threat level 
without consulting other Homeland Security Council members in exigent 
circumstances. However, DHS officials told us that this did not occur 
for any of the code-orange alert periods in our review. 

[20] DHS also issues threat advisories and information bulletins that 
provide general information to the public about indicators of possible 
terrorist attacks. 

[21] See U.S. General Accounting Office, Standards for Internal Control 
in the Federal Government, GAO/AIMD-00.21.3.1 (Washington, D.C.: 
November 1999).

[22] Public warning systems in the weather and health sectors provide 
information to citizens that allow them to determine their actions to 
respond to threats. For example, for severe storms, the National 
Weather Service and the mass media attempt to alert the public in 
advance when they might pose a hazard to public safety. Similarly, the 
CDC developed a nationwide reporting system that seeks to detect 
emerging epidemics and then to warn the public about the nature of the 
health threat.

[23] DHS officials told us that they are currently studying the impact 
that public announcement of changes in the national threat level may 
have on terrorist planning, targeting decisions, and attack execution.

[24] The Federal Protective Service became part of DHS upon creation of 
the department in March 2003. Its overall mission is to provide law 
enforcement and security services to over one million tenants and daily 
visitors to all federally owned and leased facilities nationwide. FPS 
protection services focus directly on the interior security of the 
nation's facilities and the reduction of crimes and potential threats 
in federal facilities throughout the nation.

[25] We did not ask DHS questions about how it first learned about 
changes in the national threat level. One other federal agency did not 
respond to our questions on how federal agencies first learned about 
changes in the national threat level. Thus, these 2 federal agencies 
are not included in our analysis of how federal agencies first learned 
about national threat level changes.

[26] Two states did not provide responses to our questions on how 
states first learned about changes in the national threat level. 
Additionally, 1 state reported that it does not follow the Homeland 
Security Advisory System. Thus, these 3 states are not included in our 
analysis of how states first learned about national threat level 
changes. 

[27] Please see appendix III for information on guidance and 
information and intelligence federal agencies and states reported using 
from sources other than DHS to determine protective measures to take 
for the three code-orange alert periods.

[28] One federal agency responding to our questionnaire reported that 
it did not implement protective measures because it is located in a 
privately owned building and is not responsible for its own security. 
Another federal agency did not provide a response to questions related 
to the protective measures taken during code-orange alerts due to 
security concerns. Thus, these 2 agencies are not included in our 
analysis of protective measures.

[29] Of the 43 states responding to our questionnaire, 1 reported that 
it did not follow the Homeland Security Advisory System and 2 did not 
provide responses to questions related to protective measures taken 
during code-orange alerts. Thus, these 3 states are not included in our 
analysis of protective measures.

[30] Operation Liberty Shield was a comprehensive plan to increase 
protection for U.S. citizens and critical infrastructure assets during 
the war with Iraq in March and April 2003. For example, this plan 
included increased security measures at U.S. borders and enhanced 
protection for the transportation system.

[31] Five federal agencies reported that they did not incur any 
additional costs during the March 17 to April 16, 2003, code-orange 
alert period.

[32] Six federal agencies reported that they did not incur any 
additional costs during the May 20 to 30, 2003, and December 21, 2003, 
to January 9, 2004, code-orange alert periods. One of these 6 agencies 
did incur additional costs for the March 17 to April 16, 2003, code-
orange alert period.

[33] According to a Center for Strategic and International Studies 
press release, the estimate cited by its Director is solely the view of 
the Director and not that of the Center.

[34] The SHSGP II guidelines define critical infrastructure as any 
system or asset that if attacked would result in catastrophic loss of 
life and/or catastrophic economic loss. Some examples of critical 
infrastructure are public water systems serving large population 
centers and nuclear power plants.

[35] SHSGP II also made $1.3 billion available for first responder 
preparedness to supplement funding received by first responders through 
the fiscal year 2003 State Homeland Security Grant Program. 

[36] For the December 21, 2003, to January 9, 2004, code-orange alert 
period, DHS informed states that SHSGP II funds could also be used to 
reimburse costs incurred by states and localities for staffing their 
emergency operations centers for this, as well as previous, code-orange 
alert periods. 

[37] Only 25 percent of UASI II funding can be used by localities to 
reimburse additional costs incurred during code-orange alert periods.

[38] According to SHSGP II and UASI II program guidelines, recipients 
that expend $300,000 or more of federal funds during their fiscal year 
are required to submit a statewide financial and compliance audit 
report. The audit must be performed in accordance with the U.S. General 
Accounting Office's Government Auditing Standards and OMB Circular A-
133.

[39] U.S. Conference of Mayors, "Survey On Cities' Direct Homeland 
Security Cost Increases Related to War/High Threat Alert," Mar. 27, 
2003.

[40] Center for Strategic and International Studies, Orange Threat 
Alert: Cost, Burden of Raising Level Signals Serious Concern by 
Administration (Washington, D.C.: Dec. 21, 2003).

[41] DHS was not formally established until March 1, 2003. Thus, we did 
not include DHS in our analysis of federal agencies with threat 
advisory systems in place prior to the creation of the Homeland 
Security Advisory System.

[42] Operational control of U.S. combat forces is assigned to the 
nation's Unified Combatant Commands. A Unified Combatant Command is 
composed of forces from two or more military services, has a broad and 
continuing mission, and is normally organized on a geographical basis. 
There are currently nine Unified Combatant Commands.

[43] One state did not respond to our questions about whether it 
currently followed the Homeland Security Advisory System or its own 
state advisory system, or whether it had established a state advisory 
system prior to the Homeland Security Advisory System. We contacted 
this state and determined that it currently follows the Homeland 
Security Advisory System, as well as its own state system that does not 
conform to the Homeland Security Advisory System and was implemented 
prior to the Homeland Security Advisory System. Therefore, this state 
is included in our analysis of the questionnaire responses in this 
section. 

[44] This four-level system replaced a three-level system that had been 
in use since 1978.

[45] We sent DHS a modified version of the questionnaire we sent to the 
other 27 federal agencies.We sent DHS a modified questionnaire because 
some of the questions included in the questionnaire sent to the other 
27 federal agencies did not apply to DHS. For example, we asked the 
other federal agencies to indicate the methods by which they received 
notification of changes in the national threat level from DHS.

[46] We sent the questionnaire to all Chief Financial Officers Act 
agencies except DOD. Although DOD is a Chief Financial Officers Act 
agency and, along with the Army Corps of Engineers-Civil Works, 
reported homeland security funding for fiscal year 2003, we did not 
send the questionnaire to these agencies because these agencies and 
their component entities do not follow the Homeland Security Advisory 
System.

[47] See appendix VI for a list of federal agencies that responded to 
our questionnaire. We did not receive questionnaire responses from 2 
federal agencies in time to include their responses in the report. The 
2 federal agencies were the Office of Personnel Management and U.S. 
Agency for International Development. Of the other 26 federal agencies, 
24 provided one questionnaire response for the entire agency. The 
Department of Justice and DHS provided questionnaire responses for 
their component entities. For these 2 agencies, we consolidated their 
component entities' responses into one response for the entire agency. 
In most cases, we did this by identifying the responses most often 
selected by the component entities.

[48] We did not receive questionnaire responses from 13 states in time 
to include their responses in the report. The 13 states were 
California, Colorado, the District of Columbia, Hawaii, Indiana, 
Maryland, Neveda, Oregon, Rhode Island, Virginia, American Samoa, 
Northern Mariana Islands, and the U.S. Virgin Islands. One state for 
which we received a questionnaire response indicated that it did not 
follow the Homeland Security Advisory System. We analyzed questionnaire 
responses for the other 42 states that indicated following the Homeland 
Security Advivory System.

[49] The Urban Areas Security Initiative grants are awarded based on a 
combination of current threat estimates, critical assets within the 
urban area, and population density.

[50] We did not receive responses from Miami/Dade County, Florida; 
Seattle, Washington; Jamestown, North Dakota; and New York City, New 
York.

[51] We also contacted officials from France and Israel, but did not 
receive information from these officials in sufficient time to include 
the information in the report.

[52] Department of Justice, Vunerability Assessment of Federal 
Facilities (Washington, D.C.: June 28, 1995). The Department of Justice 
developed the assessment in consultation with the General Services 
Administration, the Department of Defense, the Secret Service, the 
Department of State, the Social Security Administration, and the 
Administrative Office of the U.S. Courts.

[53] In addition to the federal agencies listed, we sent questionnaires 
to the Agency for International Development and the Office of Personnel 
Management. Also, in addition to the states and territories listed, we 
sent questionnaires to California, Colorado, the District of Columbia, 
Hawaii, Indiana, Maryland, Nevada, Oregon, Rhode Island, Virginia, 
American Samoa, Northern Mariana Islands, and the U.S. Virgin Islands. 
We also sent questionnaires to Miami/Dade County, Florida; Seattle, 
Washington; Jamestown, North Dakota; and New York City, New York.

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