Recommendation: The Commandant of the Coast Guard should ensure that the Deputy Commandant for Mission Support implements risk management processes that more fully align with the five key steps outlined in DHS's Critical Infrastructure Risk Management Framework to better guide agency shore infrastructure investment decisions. This should include (1) setting goals and objectives, (2) identifying critical infrastructure, (3) assessing and analyzing risks and costs, (4) implementing risk management activities, and (5) measuring the effectiveness of actions taken. (Recommendation 1)

Agency: Department of Homeland Security: United States Coast Guard
Status: Open

Comments: The Coast Guard concurred with the spirit of GAO's recommendation to formalize its shore infrastructure risk management processes. As noted in their formal comment, the Coast Guard was mandated by the DHS Under Secretary for Management to follow risk management guidance outlined in the DHS Resilience Framework in March 2018. The Coast Guard reported that progress towards implementing GAO's recommendation is expected to be concurrent with the development and implementation of the Component Resilience Plan in accordance with the DHS Resilience Framework. According to the Coast Guard, the DHS-mandated Component Resilience Plan assigns a mission criticality level and resilience factor to each shore facility based on a criticality assessment, inter-dependencies between mission essential assets and functions, and risk. It will then align its current resilience factor formulation to that defined through the process in the DHS Resilience Framework. Risks identified through the Framework will be managed through a strategic combination of risk acceptance, mitigation, engineering, and operational controls. The Coast Guard stated that it intends to complete these multiple efforts by the end of 2021. In a March 2020 update, the Coast Guard stated that its Office of Civil Engineering was developing the Work Plan, newly named the 2020 Civil Engineering Program Work Plan: Initiatives and Tactics and said it would include goals and objectives for identifying and addressing infrastructure resilience gaps and resource needs in alignment with the Coast Guard's Component Resilience Plan. The Coast Guard expected to publish this Civil Engineering Work Plan by July 31, 2020, after which it said it would begin implementing and measuring the effectiveness of the actions identified in the Work Plan. In June 2020, the Coast Guard reported that it now anticipates finalizing the Civil Engineering Work Plan by September 30, 2020.

Recommendation: To help reduce federal fiscal exposure by enhancing the resilience of infrastructure to extreme weather, the Secretary of Commerce, through the Director of NIST, in consultation with MitFLG and USGCRP, should convene federal agencies for an ongoing governmentwide effort to provide the best available forward-looking climate information to standards-developing organizations for their consideration in the development of design standards, building codes, and voluntary certifications.

Agency: Department of Commerce
Status: Open

Comments: As of August 5, 2020, NIST has not convened a governmentwide effort to provide the best available forward-looking climate information to standards developing-organizations.

Recommendation: To strengthen efforts to mitigate earthquake risks to federal buildings, the Secretary of Defense and the Administrator of GSA should (1) Define what constitutes an exceptionally high risk building, identify such buildings, and develop plans to mitigate those risks, including prioritizing associated funding requests as needed; and (2) To the extent practicable, prioritize and implement comprehensive seismic safety measures which could include earthquake drills, seismic safety inspections, and non-structural retrofits to decrease risks and reduce damage in federally-owned and -leased buildings in earthquake hazard areas.

Agency: Department of Defense
Status: Open

Comments: DOD concurred with our recommendation. In June 2019, DOD reported that the U.S. Army Corps of Engineers had developed a sophisticated risk assessment tool which could potentially be used to both define and assess exceptionally high risk buildings in a cost-effective manner. DOD said that it was in the process of determining the suitability of the tool for use by its components, and potentially other federal government partners. According to DOD, further action to address this recommendation will depend on both a favorable determination of the tool's suitability and the availability of funding to conduct assessments and complete the mitigation actions identified by the assessments. We will continue to monitor DOD's efforts to address this recommendation.

Recommendation: To better ensure the viability and safety of manufactured housing produced in accordance with the HUD Code, the Secretary of the Department of Housing and Urban Development should develop a plan to assess how FHA financing might further promote the affordability of manufactured homes and identify the potential for better securitization of manufactured housing financing.

Agency: Department of Housing and Urban Development
Status: Open

Comments: According to HUD officials, Ginnie Mae and FHA met to discuss their manufactured housing programs and produced a white paper. Once we receive a copy of the white paper, we will determine if it addresses our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should assess the feasibility, including an analysis of the benefits and costs, of putting in place user fees for its dispute resolution and installation programs.

Agency: Department of Housing and Urban Development
Status: Open

Comments: As of March 2018, HUD stated that the Office of Manufactured Housing Programs continues to work toward fully implementing both the installation and dispute resolution programs in the default states using two new contractors for these purposes. As the implementation of these programs continues to mature, HUD stated that its Office of Manufactured Housing Programs will be monitoring program requirements and service delivery and gathering data that it can use in assessing the feasibility of putting in place user fees for these programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To better ensure that Congress, stakeholders, and agencies have complete information about changing costs and whether a fee needs to be changed, HUD should establish the goals for use of reserves of the Manufactured Housing Fees Trust Fund, and the minimum and maximum thresholds for the reserves appropriate for meeting these goals.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In response to this recommendation, as of March 2018, HUD plans to consider user fee reserve best practices in evaluating any carryover balances and developing future operating budgets for its manufactured housing programs. The Office of Manufactured Housing Programs plans on reviewing best practices and determining next steps ideally by the end of Fiscal Year 2019. We continue to believe that setting clear goals for the reserve and clarifying how those reserves will be used helps ensure accountability and transparency both to Congress and users of fee-based programs. We will continue to monitor HUD's progress in implementing our recommendation.

Recommendation: To better ensure that air ventilation systems in manufactured homes perform as specified and meet the HUD Code, HUD should develop an appropriate method to test and validate the performance of the ventilation system as part of the HUD certification process.

Agency: Department of Housing and Urban Development
Status: Open

Comments: In March 2017, HUD stated that it has not developed a test to validate the performance of the whole-house ventilation specification. HUD reported that the Manufactured Housing Consensus Committee (MHCC) did not agree with the testing validation recommendations. As of March 2018, HUD continues to move forward in updating its standards, including a test for whole house ventilation. However, as part of the overall HUD effort to review regulations, HUD officials stated they are currently conducting a review of current and planned federal regulations for manufactured housing with the goal to facilitate the affordability of manufactured housing and to promote durable, safe, and cost effective construction techniques for manufactured homes. As a result, HUD does not anticipate moving forward with any manufactured housing regulations until it completes its review. We continue to believe that developing such a test will better ensure that air ventilation systems in manufactured homes perform as specified and meet the HUD Code and will continue to monitor HUD's progress in implementing our recommendation.