Homeland Defense: National Guard Bureau Needs to Clarify Civil	 
Support Teams' Mission and Address Management Challenges	 
(31-MAY-06, GAO-06-498).					 
                                                                 
To prepare for potential attacks in the United States involving  
weapons of mass destruction (WMD), Congress approved the	 
development of National Guard Civil Support Teams (CST) tasked to
identify chemical, biological, radiological, nuclear, or	 
high-yield explosive weapons; assess consequences; advise civil  
authorities on response measures; and assist with requests for	 
additional support. Thus far, 36 of the 55 approved teams have	 
been fully certified to conduct their mission. The National Guard
Bureau (NGB) is in the process of establishing, certifying, and  
planning for the long-term sustainment of the CSTs. GAO was asked
to address the extent to which (1) the CSTs are ready to conduct 
their mission and (2) effective administrative mechanisms are in 
place for the CSTs.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-498 					        
    ACCNO:   A54907						        
  TITLE:     Homeland Defense: National Guard Bureau Needs to Clarify 
Civil Support Teams' Mission and Address Management Challenges	 
     DATE:   05/31/2006 
  SUBJECT:   Agency missions					 
	     Antiterrorism					 
	     Defense contingency planning			 
	     Emergency preparedness				 
	     Homeland security					 
	     Military training					 
	     National Guard					 
	     Weapons of mass destruction			 
	     Civil support					 
	     Strategic planning 				 

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GAO-06-498

     

     * Report to the Chairman, Subcommittee on National Security, Emerging
       Threats, and International Relations, Committee on Government Reform,
       House of Representatives
          * May 2006
     * HOMELAND DEFENSE
          * National Guard Bureau Needs to Clarify Civil Support Teams'
            Mission and Address Management Challenges
     * Contents
          * Results in Brief
          * Background
          * CSTs Are Prepared to Conduct Their Mission, but the Role of Non-
            WMD Missions Causes Confusion
               * Certified CSTs Are Ready to Perform Their Mission
               * Mechanisms Are in Place for CSTs to Operationally Respond to
                 Missions
               * Role of Non-WMD Missions Causes Confusion
               * DOD Plans to Expand Role of CSTs Outside the United States
          * CST Program Faces Management Challenges That Could Increase Risk
            to Long- term Sustainment
               * NGB Is Pursuing Institutional Management Efforts
                    * CSTs Struggle to Fully Staff Teams
                    * CSTs Lack Guidance on Conducting Coordination in Their
                      States
                    * CSTs Face Equipment, Training, Readiness Reporting, and
                      Facilities Challenges
                    * NGB Lacks Guidance to Help State National Guard
                      Commands Oversee and Support CSTs
          * Conclusions
          * Recommendations for Executive Action
          * Agency Comments and Our Evaluation
     * Scope and Methodology
     * CST Program Management Efforts
          * Standardization and Evaluation Program
          * Army Training and Evaluation Support
          * CST Working Groups
     * Data Collection Instrument
     * Comments from the Department of Defense
     * GAO Contact and Staff Acknowledgments

Report to the Chairman, Subcommittee on National Security, Emerging
Threats, and International Relations, Committee on Government Reform,
House of Representatives

May 2006

HOMELAND DEFENSE

National Guard Bureau Needs to Clarify Civil Support Teams' Mission and
Address Management Challenges

Contents

Tables

Figures

May 31, 2006Letter

The Honorable Christopher Shays Chairman Subcommittee on National
Security, Emerging Threats, and International Relations Committee on
Government Reform House of Representatives

Dear Mr. Chairman:

To help prepare the United States for potential terrorist attacks
involving weapons of mass destruction (WMD),  1 Congress in 1998 approved
the development of federally funded, state2 controlled, National Guard WMD
Civil Support Teams (CSTs). The CSTs' principal mission is to assist civil
authorities in the United States in responding to incidents involving WMD
or catastrophic terrorism, including the use of chemical, biological,
radiological, nuclear, or high-yield explosive weapons and agents. The
CSTs are to identify these agents and substances, assess current or
projected consequences, advise civil authorities on response measures, and
assist with requests for additional support. Like traditional National
Guard units, the CSTs are under the control of the governors of their
respective states and territories, unless they are activated for federal
service, at which time they would fall under the control of the Department
of Defense (DOD). However, unlike traditional National Guard units, these
highly specialized teams are each composed of 22 members who are on
full-time duty. The teams include both Army and Air National Guard
personnel who are divided into six sections, including command,
operations, administration/logistics, medical science, communications, and
survey. The teams possess highly technical mobile laboratory and
communications equipment to accomplish their mission.

Congress initially approved the establishment of 10 CSTs.3 Since 1998,
Congress has incrementally increased the number of authorized teams to the
currently approved 55: one in each state; a second team in California; and
one each in the District of Columbia, Puerto Rico, the Virgin Islands, and
Guam. DOD established the stationing plan for the CSTs in five phases. The
National Guard Bureau (NGB), the managing organization for the CSTs,
executed the establishment, certification, and sustainment program for the
teams. Phase one comprised 10 teams; phase two 17 teams; phase three 5
teams; phase four 12 teams; and phase five 11 teams. Each team must be
certified by the Secretary of Defense as capable of conducting its
mission. To accomplish this, each team must complete a battery of
individual and team training, receive all its authorized equipment,
achieve full staffing, pass an external evaluation by Army experts, and
apply (via its state adjutant general) to the Secretary of Defense for
certification. Thirty-six teams have been certified as of May 2006; the
remaining 19 will be certified by the end of fiscal year 2007. The
approximate cost for establishing all 55 teams is $424 million, and it
costs approximately $3.4 million annually to sustain each team.

The challenges DOD faces in managing its reserve forces and allocating its
resources across services and programs are some of the many issues that we
highlighted for Congress as the nation entered the 21st century. For
example, we issued a report in November 2004 that recommended the
establishment of readiness standards and measures for the National Guard's
homeland security missions.4 In 2001, the DOD Inspector General
highlighted a number of structural and management problems with the CST
program, including the standards for certification and readiness of the
teams as well as other problems that may impede the CSTs from conducting
their mission.

We examined the operational readiness of the Army National Guard's WMD
CSTs. Our objectives were to address (1) the extent to which the CSTs are
ready to conduct their mission and (2) the extent to which there are
effective administrative mechanisms in place for the CSTs.

To address these objectives, we reviewed the readiness criteria and
categories for the two systems used to track CST readiness.5 We also
incorporated these criteria into our questions as we designed and
distributed a broad data collection instrument to all 55 CSTs to collect
information regarding the status and availability of CST equipment,
training and certification, mission, coordination, and personnel. We
received complete responses from 52 CSTs. Further, we supplemented this
information with visits to 14 CSTs, and we conducted interviews with state
National Guard personnel as well as with local, State, and federal
officials who currently or will potentially work with CSTs. In preparing
the data collection instrument, we tested the reasonableness of our
questions in discussions with the commanders of two CSTs not included in
our 14 site visits. During several of our site visits, we observed
exercises, an external evaluation, and other training events. We also
compared the information collected during our visits, including
interviews; after-action reports; and existing command, control, and
coordination mechanisms, with policies and the expectations of officials
with whom the CSTs must work in the states. We selected the site-visit
sample to comprise a wide distribution of states and territories based on
such criteria as geographic distribution, age of team, certification
status, state size, and population. Additionally we collected cost data
related to the establishment and sustainment of the CSTs from NGB, state
National Guard personnel, and the CSTs themselves. We did not
independently verify cost data, but we interviewed NGB officials who
manage the data about data quality control procedures. We determined the
data were sufficiently reliable for the purposes of this report. Further
details on our scope and methodology appear in appendix I. We performed
our work from April 2005 through March 2006 in accordance with generally
accepted government auditing standards.

Results in Brief

The certified CSTs have thus far been ready to conduct their mission in
terms of having the training, equipment, and staff required of them, and
the teams have a functioning command and control structure. However,
confusion resulting from a lack of guidance on the types of non-WMD
missions the CSTs can conduct to prepare for their WMD terrorism mission
could impede coordination between state authorities and local emergency
management officials on the appropriate use of the CSTs. Congress
authorized the creation of the CSTs for the primary purpose of assisting
civil authorities in responding to domestic incidents involving WMD. Based
on our review of the CSTs' training, equipment, and staffing criteria;
data we collected for the CSTs in all three areas; our site visits to 14
CSTs; and our discussions with state, local, and federal responders who
have worked with those teams, we found the certified teams we visited to
thus far be ready to conduct their mission. NGB and the states have a
clear structure for operational control of the CSTs, including procedures
for who can authorize CST deployment, to whom they should report at an
incident scene, and when command authority shifts because of a federalized
effort. State and local officials we interviewed reported that the command
and control of the teams is well understood and exercised. Though the
CSTs' mission is focused on WMD events, and the CSTs emphasize this focus
when coordinating with state and local emergency management officials,
some CSTs have responded to non-WMD events, such as providing emergency
assistance to the Gulf Coast states after the 2005 hurricanes. Beyond the
benefits they provide to civil authorities, the CSTs use such missions to
prepare for responding to a WMD event. However, the lack of clarity and
guidance on what types of non-WMD operations the CSTs should use to
prepare for a WMD response, as well as the desire of civil authorities to
call upon the teams for other emergencies, is causing confusion among
state, local, and National Guard officials about the appropriate use of
the CSTs. This potentially slows coordination between local and state
responders and the CSTs and coordinated NGB-level responses involving
multiple CSTs. Also, DOD is proposing a limited role for the CSTs to
coordinate and operate with Mexican and Canadian officials in the event of
a cross-border WMD incident. DOD and NGB are also informally considering
limited overseas missions for the teams, though they have no plans to
request a further expansion of the CSTs' mission to encompass overseas
operations. According to NGB and the CST commanders, some overseas
missions could provide valuable experience and have a positive effect on
CST readiness, while other, more demanding missions, such as supporting
the warfighter, could be detrimental to the CSTs.

Although NGB continues to develop a long-term sustainment plan for the CST
program, going forward, it faces challenges to the administration and
management of the CSTs that could impede both the progress of newer teams
and the long term sustainment of the program. As the managing authority
for the CST program, NGB has made progress in establishing an
administrative management structure for the CSTs, including issuing a
broad CST management regulation and initiating a standardization and
evaluation program. However, NGB also faces challenges to the CSTs in such
areas as staffing, coordination plans, equipment maintenance and
acquisition, training and exercise oversight, readiness reporting, and
facilities. Further, NGB guidance explaining state National Guard roles
and responsibilities for overseeing and supporting their CSTs is
insufficient to fully inform the states about the unique nature and
requirements of the CSTs and how to integrate such a unit into the state
National Guard command structure. The result has been varied and generally
problematic oversight and support of CSTs at the state level in such areas
as staffing and equipment augmentation and designing and building the
facilities to house the teams. According to CST members and NGB officials
we interviewed, these challenges have yet to harm readiness, and NGB
officials recognize the importance of these challenges and have individual
initiatives to address many of them. If NGB's efforts are not successful,
the challenges could, in the long run, impede the progress of newer teams
and compromise the long-term sustainment of the CST program.

This report makes recommendations to help DOD and NGB address management
challenges and further its efforts to sustain the CST program. We are
recommending that DOD work with NGB and the Army and Air Force to clarify
the domestic CST mission, develop guidance to address management
challenges, and create a clear and effective administrative support
structure at the state level. In comments on a draft of this report, DOD
generally agreed with our recommendations and described steps it is taking
or will take to implement them.

Background

In response to an increase in the threat of potential terrorist attacks in
the United States involving WMDs, Congress directed the federal government
to enhance its capability to deter, prevent, respond, and recover from
terrorist attacks using such weapons.6 Among the resulting efforts,
Congress in fiscal year 1999 approved the development of National Guard
WMD CSTs.7 The CSTs are designed to support civil authorities in the event
of a domestic WMD event by identifying WMD agents and substances,
assessing current and projected consequences, advising on response
measures, and assisting with appropriate requests for additional support.
In describing WMD agents, DOD commonly uses the term chemical, biological,
radiological, nuclear, and high-yield explosives (CBRNE). Like traditional
National Guard units, the CSTs are under the day-to-day control of the
governors of their respective states and territories. The CSTs can also be
activated for federal service by the President, at which time they would
fall under DOD command. Unlike traditional National Guard units, which
generally consist of part-time soldiers who conduct regular drills, the
CSTs are composed of full-time Army and Air National Guard members. Each
22-person team is divided into six sections: command, operations,
communications, administration and logistics, medical/analytical, and
survey. The members of the CSTs are trained in their various disciplines
and operate sophisticated equipment that helps them accomplish their
mission. Table 1 shows examples of some of the tasks associated with each
CST section.

Table 1: Examples of Civil Support Team Section Tasks

                                        

         Section       Number of               Examples of tasks              
                       personnel  
Command                     2  o Provides command and control of the team  
                                                                              
                                  o Interfaces with external agencies and     
                                  organizations                               
                                                                              
                                  o Provides advice to the first responder    
                                  community                                   
                                                                              
                                  o Facilitates introduction of follow-on DOD 
                                  forces into a consolidated response team    
                                                                              
                                  o Ensures that sample collection and        
                                  handling procedures are conducted safely    
                                  and are accurately documented and the chain 
                                  of custody is maintained                    
Operations                  4  o Conducts hazard modeling                  
                                                                              
                                  o Provides information for vulnerability    
                                  analysis                                    
                                                                              
                                  o Coordinates and directs CBRNE surveys     
                                                                              
                                  o Coordinates and monitors unit training    
                                                                              
                                  o Prepares site safety and incident action  
                                  plans                                       
Medical/ analytical         4  o Establishes and maintains medical         
                                  surveillance and monitoring programs for    
                                  the unit                                    
                                                                              
                                  o Conducts lab analysis of incident-related 
                                  samples                                     
                                                                              
                                  o Conducts medical reach-back coordination  
                                  with medical labs                           
                                                                              
                                  o Secures and prepares samples for          
                                  transport and subsequent transfer           
                                                                              
                                  o Provides emergency medical stability for  
                                  CST members                                 
Communications              2  o Provides voice and data communications    
                                  through a variety of networks designed to   
                                  support CST operations                      
                                                                              
                                  o Maintains communications within the team, 
                                  with higher headquarters, with other        
                                  responding agencies, and with subject       
                                  matter experts                              
                                                                              
                                  o Establishes secure communications links,  
                                  as required                                 
Survey                      8  o Conducts missions in appropriate          
                                  protective equipment                        
                                                                              
                                  o Enters a suspected hot zone to conduct    
                                  search for CBRNE hazards                    
                                                                              
                                  o Collects and preserves incident-related   
                                  samples for delivery to analytical          
                                  equipment                                   
                                                                              
                                  o Identifies, marks and reports             
                                  contaminated areas                          
Administration and          2  o Sustains the ability of the CST to        
logistics                      conduct operations                          
                                                                              
                                  o Maintains logistics status reports        
                                                                              
                                  o Procures and stores unit equipment        
                                  according to command guidance               

Source: DOD.

The CSTs employ military-provided equipment that is common to active duty
military units, such as chemical defense equipment and uniforms. They also
use a large variety of specialized commercial equipment, such as the
protective ensembles worn in the hazard zone and much of the teams'
laboratory equipment. The CSTs employ several vehicles for transporting
and supporting the six sections of the team. Among these are two specially
constructed vehicles: the Unified Command Suite, which contains a wide
range of radio, data, and video communications equipment, and the
Analytical Laboratory System, which contains such equipment as a gas
chromatograph/mass spectrometer for organic material analysis and a gamma
spectrometer for radiological material analysis as well as other
laboratory support equipment. Figures 1 and 2 show the Unified Command
Suite and the Analytical Laboratory System, respectively.

Figure 1: The Unified Command Suite

Figure 2: The Analytical Laboratory System

The equipment in the Analytical Laboratory System helps the CSTs conduct a
"presumptive identification" of a CBRNE sample. If requested by the
incident commander, the CST then transfers a sample to a Centers for
Disease Control and Prevention-approved laboratory for confirmation and
official identification.

NGB is responsible for managing the CST program and is the principal
channel of communication between DOD and the adjutant general commanding
the National Guard unit in each state. NGB also coordinates with other DOD
commands and organizations to support various aspects of the CST program.
For example, the joint service Chemical and Biological Defense Program
conducts the acquisition process for much of the CST equipment, and the
Army's Maneuver Support Center assists in developing CST doctrine and
conducting key CST-specific training.

The Secretary of Defense must certify each CST as ready to execute its WMD
mission.8 This certification involves a series of staffing, equipping, and
training steps that take from 18 to 24 months. To achieve certification,
each CST must complete the following steps:

1.Have the required personnel and equipment resources and be trained to
undertake the full mission for which it is organized or designed. For
example, at least 85 percent of assigned personnel must have completed all
of their CST-specific individual training.

2.Undergo an external evaluation by Army experts according to the CST's
approved mission training plan.

3.Notify its adjutant general that it has completed the above steps,
whereupon the adjutant general submits a request for certification to NGB,
which then reviews and forwards the request to the Army Staff and to the
Assistant Secretary of Defense for Homeland Defense.9

The Secretary of Defense makes the final determination of approval for CST
certification. Although certification is a onetime event, a CST that loses
a significant number of key personnel associated with command and control
or with medical and assessment capabilities that substantially degrades
the team's ability to conduct its mission must undergo a revalidation
process. In addition, each CST undergoes an external evaluation every 18
months, during which Army experts assess each team's ability to meet
specific mission standards associated with all related WMD threats.

Both civil and military responders, including the CSTs, conduct WMD
response operations in a three-tiered approach based on the National
Response Plan and the National Incident Management System. The National
Response Plan represents a comprehensive all-hazards approach intended to
enhance the ability of the United States to manage domestic incidents.
Fire and rescue, law enforcement, and emergency medical personnel
constitute the first tier. If the extent of the event exceeds the ability
of the first tier to manage the consequences of the situation, the
state-level civil and military forces may be activated and deployed as the
second tier. If the governor determines that the forces and resources
available in the state require additional support, then the governor may
request assistance from the President of the United States, constituting
the third tier. The CSTs are generally included in the second tier of the
response.

In addition to preparing to respond to WMD and catastrophic terrorist
events in their respective states, the CSTs also adhere to NGB's Response
Management Plan. Under this plan, NGB monitors the readiness status of
each certified CST to ensure that at a given time, a designated number of
CSTs are always ready to respond to a national need or the need of a state
without an available CST. To facilitate planning for such responses, the
plan divides the nation into six response sectors, as shown in table 2.

Table 2: CST Response Management Plan Sectors

                                        

Response sector                   States or territories                    
1               Pennsylvania, New Jersey, New York, Connecticut, Rhode     
                   Island, Massachusetts, New Hampshire, Vermont, and Maine   
2               West Virginia, Virginia, District of Columbia, Maryland,   
                   Delaware, Illinois, Indiana, Ohio, Michigan, and Wisconsin 
3               Alabama, Georgia, South Carolina, North Carolina,          
                   Tennessee, Kentucky, Florida, Puerto Rico, and the U.S.    
                   Virgin Islands                                             
4               Louisiana, Texas, Oklahoma, Arkansas, Kansas, Missouri,    
                   Minnesota, Iowa, and Mississippi                           
5               New Mexico, Arizona, California, Nevada, Utah, Colorado,   
                   Hawaii, and Guam                                           
6               South Dakota, North Dakota, Wyoming, Montana, Idaho,       
                   Washington, Oregon, Alaska, and Nebraska                   

Source: National Guard Bureau.

Under the Response Management Plan, the CSTs are scheduled on either
"bronze," "silver," or "gold" status on a rotating basis. At any given
time one certified team per response region is in gold status and must be
ready to deploy a full CST (personnel and equipment) within 3 hours from
its home station to an incident site within its region, should the need
arise. At the same time, another certified team per response region is
placed in silver status. While this team is in a slightly lower state of
readiness it must be prepared to assume gold status in the event the gold
team is deployed. The remaining certified teams are in bronze status and
are focused more on training, block leave, equipment preparation, and
state-directed missions. Bronze teams must, however, be prepared to
respond to incidents within their region within 72 hours and to assume
silver or gold status within 48 and 96 hours, respectively.

Because the CSTs are state-controlled units, the respective governors are
the final deployment authority for CST missions and, unless the CSTs are
federalized, they remain under the command authority of the governors and
state adjutants general. The CSTs generally conduct three types of
mission: response, stand-by, and assist. Response missions are deployments
in support of requests from local, state, or federal agencies, such as a
CST deployment to help civil authorities identify a potentially toxic
chemical left by a suspected terrorist. Stand-by missions involve
providing CST expertise at special events, such as the national political
conventions. Assist missions include a range of CST involvement, including
technical assistance, reconnaissance, or assistance with CBRNE
vulnerability assessments. For example, CST commanders and team members
may provide technical assistance by phone to a local incident commander at
a hazardous materials scene. Table 3 summarizes deployments of the CSTs
for missions other than training exercises.

Table 3: Summary of CST Nontraining Deployments, 2001-05

                                        

        Mission type                  Number           Percentage of missions 
Response                              405                                8 
Stand-by                              580                               11 
Assist                              4,109                               81 
Total                               5,094                              100 

Source: GAO.

As shown in table 3, CSTs deployed on response missions far less often
than on stand-by and assist missions. The table does not show total
activity by the CSTs, since the majority of their time is devoted to
training in order to maintain individual and team readiness. It also may
not reflect all CST deployments to assist in states affected by hurricanes
in 2005.

Each CST costs approximately $7.7 million to establish, or approximately
$424 million to establish all 55 CSTs. This cost estimate includes initial
equipment, vehicles, personnel, and training support. Sustaining each CST
in these categories costs approximately $3.4 million a year, or $189
million a year to sustain all 55 teams. DOD funds the establishment and
sustainment of the CST program and NGB manages most of this funding. These
estimates do not include utilities for CST facilities, which are paid by
the states via a general calculation of all state facilities requirements
and funded through NGB. The estimates also do not include federally funded
costs for construction of CST facilities, since these costs vary widely
depending on how and where the states decide to station their teams. There
are also additional federal costs associated with the CST program that are
not associated with the specific teams themselves. For example,
approximately $65 million for fiscal year 2006 is associated with the
following categories:

o funding for CST airlift;

o various CST-unique training courses;

o equipment replenishment and modifications;

o maintenance of secure Internet access for CSTs;

o government-owned vehicles;

o communications links;

o Unified Command Suite maintenance and support;

o civilian personnel involved in CST oversight functions; and

o U.S. Army personnel whose mission is to evaluate, train, and develop
doctrine for CSTs.

NGB is also in the process of creating additional units meant to follow
CSTs in response to WMD events and to be part of larger National Guard
response forces. The mission of the 17 currently authorized National Guard
CBRNE Enhanced Response Force Packages (CERFP) is to support local, state,
and federal agencies managing the consequences of a CBRNE event by
providing capabilities to conduct personnel decontamination, emergency
medical services, and casualty search and rescue. Each CERFP comprises
approximately 186 personnel taken from existing Army and Air National
Guard medical, engineer, chemical, and other units. Unlike CST members,
CERFP personnel do not serve in their units on a full-time basis but
rather must be mobilized for duty. Like CSTs, however, CERFPs are intended
to be part of the state response to a WMD incident and can also be
federalized and placed under DOD authority.

CSTs Are Prepared to Conduct Their Mission, but the Role of Non-WMD
Missions Causes Confusion

Based on the CSTs' readiness measures for staffing, training, and
equipment; the data we obtained from the CSTs on each of these measures;
the process NGB has in place to maintain and monitor CST readiness; and
the discussions we had with CSTs and state, local, and federal officials
in the 14 states and territories we visited, we found that the certified
CSTs have thus far been trained, equipped, and staffed to conduct their
mission. Further, NGB, DOD, and the states have guidance in place for
operational command and control of the CSTs, specifying how and when teams
will operationally respond to a WMD event. However, confusion about the
types of non-WMD missions the CSTs conduct to help them prepare for WMD
missions could impede coordination between state, local, and federal
officials about the appropriate use of the CSTs.

Certified CSTs Are Ready to Perform Their Mission

The certified CSTs have thus far had the staff, equipment, and training
they need to conduct the mission that Congress intended for them.
Staffing, equipment, and training data we collected from 52 of the 55 CSTs
in late 2005 confirmed this state of readiness, as did the discussions we
had with CST personnel in the 14 states and territories we visited and
state National Guard command staff, CST program managers at NGB, and state
and local emergency responders. Additionally, NGB has a clear plan to
maintain, monitor, and periodically evaluate the teams' overall readiness.
For example, for the certified CSTs we visited, in addition to fulfilling
initial certification criteria that established strict standards for
staffing, equipment, and training readiness, these teams have passed the
external evaluations they are required to undergo every 18 months and have
continued to prepare and execute training and exercise plans to maintain
their readiness.

Based on our review of the mission and training standards for the CST
program and our interviews and observations of CST personnel during our
site visits, we found CST members to be motivated soldiers who have
mastered complex technical tasks and can perform them under duress. The
teams we visited reported that they maintain high morale in spite of the
training pressures, the need for around-the-clock availability, and the
added burden of training to perform the duties of other positions on the
team so that the CST will have added depth and flexibility. Their fitness
regimen is designed to keep them in superior physical condition, allowing
them to perform in physically challenging response environments for an
extended time. For example, teams are trained to conduct their work in
fully contained protective suits and masks while carrying their own oxygen
supply tanks on their backs. This is physically challenging even in
moderate climate conditions.

CST personnel are prepared for their mission through a regimen of
individual training that varies from 376 to 1,148 hours in the first 2
years, depending upon the duty position. The teams complete an initial
external evaluation in order to obtain DOD certification, and they undergo
a similar evaluation every 18 months thereafter. The teams are required to
conduct 12 collective training events each year to help them develop and
maintain the skills necessary to complete the WMD response tasks outlined
in the CST's Mission Training Plan. NGB further monitors the 55 CSTs
through two readiness reporting databases that inform NGB as to how well
teams are meeting basic readiness criteria and provide detailed
information on their personnel, equipment, and training status. One of
these systems is a primary mechanism for NGB's administration of the
Response Management Plan.

DOD assesses the teams' proficiency in their critical tasks through
external evaluations administered by U.S. Army subject matter experts. We
observed an external evaluation for a phase one CST that required the team
to locate and identify small amounts of chemical, biological, and
radiological substances hidden inside a large warehouse, and it was able
to do this successfully. Following the event, the Army experts and the CST
members held an after-action review during which they discussed and
assessed the team's performance in critical mission areas, highlighting
processes and procedures that worked well and those that required
improvement. Army experts administer external evaluations to each CST
every 18 months to assure both DOD and NGB of the team's continued
readiness.

In response to our data collection instrument, 94 percent of CST
commanders characterized external evaluations as an accurate indicator of
their readiness. Some CST commanders who responded to our data collection
instrument said the evaluations were good measures of the basic readiness
of the teams to conduct their mission but did not adequately assess teams
for their ability to interact with and support a civilian incident
commander while at a site in company with multiple other local, state, and
possibly federal authorities. CST members told us that a multiple-agency
incident response site will be the normal circumstance for an actual CST
WMD mission. In addition to the external evaluations, the CSTs conduct a
number of exercises every year that involve other civil responders with
which they would work in the event of an actual WMD response. CST members
and state, local, and federal officials we met with reported that these
exercises are invaluable for helping all stakeholders understand each
other's capabilities and how best to work together.

Emergency responders and state officials who work with CSTs in the states
and territories we visited gave generally positive reviews of the teams.
Reflecting mostly on their experience with the CSTs in exercises and other
coordinating venues, state and local officials we interviewed reported a
high degree of confidence in the readiness of the CSTs to conduct their
mission. They also reported that the CSTs' ability to provide on-scene
initial identification of CBRNE substances, along with their
communications capability, exceed that of most civilian response teams and
are vital assets for WMD response in their states.

Mechanisms Are in Place for CSTs to Operationally Respond to Missions

NGB, DOD, and the states have guidance in place for operational command
and control of the CSTs, specifying how and when teams will operationally
respond to a WMD event. The basis of CST operational deployment guidance
is the National Response Plan and the National Incident Management
System.10 States and territories we visited were in the process of
updating their emergency response plans, and these plans identify the
state National Guard's role, and sometimes specifically the CST role, in
the response. State officials acknowledged that their plans were being
revised to conform to the National Response Plan. Officials in states and
territories we visited expressed a need to become better organized to
address homeland security and WMD threats.

CSTs have successfully tested their command and control structures by
deploying to response, stand-by, and assist missions under the authority
of their respective state governors and adjutants general. To practice
operational command and control, the CSTs also participate in various
training exercises with federal, state, local, and nongovernmental
agencies and organizations. Evaluation data on these missions and
exercises are limited and often informal. However, the information
available indicates that CSTs met NGB, state, and local expectations about
coordination command and control, and comments by state and local
officials we interviewed were overwhelmingly positive.

In addition to operations within their states, CSTs have sometimes
deployed outside their state based on requests for assistance. In these
cases, the CSTs come under the command and control of the governors and
adjutants general of the states in which they are operating. The CSTs have
also been deployed to other states based on NGB requests that they respond
to an event or disaster. For example, NGB managed the deployment of the
CSTs to states affected by hurricanes in 2005 using the Response
Management Plan to maintain enough teams in a high state of readiness in
each response region. According to after-action reports on these events
and comments from officials we interviewed during our site visits, the
CSTs were integrated into the operational command and control of state
military commands in the Gulf states, reported to incident commanders when
responding to specific events, and performed their duties according to the
response plan.

DOD also has guidance in place for operational command and control of the
CSTs in the event the teams are federalized. In such an event, the CSTs
would come under the command of DOD's U.S. Northern Command. To date, no
CSTs have been federalized.

Role of Non-WMD Missions Causes Confusion

While the CSTs principally focus on responding to WMD and catastrophic
terrorist attacks,11 some CSTs are preparing for this mission by
responding to non-WMD events, causing confusion among civilian as well as
National Guard officials about when the CSTs should and should not be
employed. This confusion results from a lack of clear guidance
interpreting the legislation that establishes the CST mission to "prepare
for or to respond to" WMD or terrorist attacks12 and from DOD's use of the
term chemical, biological, radiological, nuclear, and high-yield
explosives (CBRNE) in its characterization of the CSTs' official mission.
In a 2004 memo, the NGB's Deputy Director for Domestic Operations advised
all state National Guard headquarters that approve missions for their
respective CSTs to ensure that their teams responded only to intentional
uses of WMD, to terrorist attacks, or to threatened terrorist attacks. He
cautioned that the military's formal definition of CBRNE included
unintentional events, such as accidental hazardous materials spills, that
were outside the scope of the CSTs' mission. As part of their coordination
efforts with state and local emergency management officials, CST members
highlight the WMD and catastrophic terrorism mission limitation of the
CSTs. While CST commanders and team personnel accepted this formal
limitation on their mission, they also reported that it is sometimes
necessary for mission readiness purposes to respond to events that have no
connection to WMD or terrorism. For example, 61 percent of CST commanders
who responded to our data collection instrument consider it to be part of
their respective CST's mission to respond to CBRNE incidents that are
known to be the result of accidents or acts of nature-that is, to
incidents that are not attacks. Additionally, 92 percent of commanders who
responded thought that this type of response should be part of their
mission, and many of those with whom we met endorsed responding to
non-CBRNE events as well.

CST commanders value non-WMD and nonterrorism responses for a variety of
reasons, and NGB officials agreed. Deployments to actual incidents,
regardless of the cause, can function as a valuable means of exercising
the CSTs' core capabilities, such as communication and coordination with
state, local, and federal responders and authorities, and help CSTs
prepare for responses to incidents that are WMD related. Moreover, CST
commanders and other officials explained that it is often difficult to
determine the cause of a destructive event until the CST arrives on
scene-only then can the possibility of terrorism be conclusively
dismissed.

The Hurricane Katrina response provides a recent example of CST
deployments that were not directly related to WMD or terrorism but
provided CSTs with real-life opportunities to exercise their capabilities
to respond to WMD events. Following an NGB request, 18 teams sent
personnel and vehicles to assist in the response effort. This assistance,
often in the form of satellite communications capabilities, enabled local
authorities to coordinate with each other as well as with state and
federal officials. For example, one southeastern CST sent personnel to
establish a communications outpost just outside the Louisiana Superdome.
According to NGB officials, there were lengthy discussions about whether
these types of responses were appropriate CST missions. They ultimately
concluded that response to large-scale disasters like Katrina were within
the CSTs' mandate to prepare for or respond to WMD or terrorism events.

The use of CSTs for missions that do not involve catastrophic terrorist
acts or WMD, as well as deployment criteria that can differ across 54
state and territorial governments, can lead to confusion at the local
level and the potential for unmet expectations. Local responders we met in
the 14 states and territories we visited reported that they value the
CSTs' expertise and capabilities and think that they can be put to wider
use within their communities, although they recognized the need to protect
the CSTs from overuse. But there remains no guidance that would assist
CSTs or state and local officials in understanding what types of non-WMD
missions are appropriate for the CSTs to conduct in preparing for their
WMD terrorism mission. As a result, the parameters of allowable CST
missions vary across states and among state civilian authorities, state
National Guard headquarters staff, CST commanders, and others involved in
approving CST missions. For example, some states did not acknowledge NGB's
requests for use of their CSTs for hurricane response operations, and at
least one state refused to allow its team to participate. Following the
destruction of the space shuttle Columbia in February 2003, multiple CSTs
were involved in collecting debris across five states; but some state
authorities and CST commanders declined to assist because they did not
consider it to be a legitimate deployment. Further, in their responses to
our data collection instrument, 59 percent of CST commanders recognized a
need for their CSTs to provide operational support to local hazardous
materials teams prior to those teams' deployment to an incident scene,
while 41 percent did not. Seventy-eight percent of commanders who
responded identified a need to support hazardous materials teams during
the response itself, while 22 percent did not.

NGB officials acknowledged that while the conduct of non-WMD specific
operations by the CSTs is a valuable way for the teams to satisfy their
mission to prepare for or respond to WMD or catastrophic terrorist
attacks, some confusion results among the CSTs and state and local
officials. They also acknowledge that NGB needs to work with DOD to
clarify the types of missions that are appropriate for CSTs to perform as
part of the preparation to respond to a WMD or catastrophic terrorist
attack. A February 2006 report by the White House on lessons learned from
the Hurricane Katrina operations recommended that the option of expanding
the role of CSTs to an all-hazards approach should be explored.13 Further,
DOD has requested that Congress expand the CSTs' mission to include
man-made and natural disasters. If the types of such non-WMD missions in
which the CSTs participate are not made clear, this could exacerbate
confusion at the state and local levels about the mission of the CSTs.

DOD Plans to Expand Role of CSTs Outside the United States

The CSTs are currently limited to conducting operations within the borders
of the United States and its territories. However, DOD has requested that
Congress allow CSTs to operate in conjunction with officials in Mexico and
Canada in order to help accomplish their mission in states bordering these
countries. CST members and NGB and DOD officials also told us that there
have been informal discussions within DOD regarding a range of potential
overseas operations for CSTs, including training, cooperative programs
with foreign countries, prestaged support missions, as well as possibly
direct support to the warfighter. However, DOD officials could not
identify for us whether there is a validated requirement for CSTs to
operate overseas, and they told us they have no plans to request a further
expansion of the CST's mission to encompass overseas operations.

Legislation governing the CST program specifically prohibits the CSTs from
conducting operations outside the borders of the United States or its
territories.14 This law emphasizes this restriction by requiring that any
request by the Secretary of Defense for a legal change be submitted with a
justification for the request and a written plan to sustain the CSTs'
capabilities. Regulations detailing the composition, management, training,
and doctrine of the CSTs explicitly define the CST mission as supporting

civil authorities at a domestic CBRNE incident site, whether the CSTs are
operating in a state or federal status.15

DOD has requested that Congress allow CSTs to coordinate and operate with
Mexican and Canadian officials in the event of a cross-border WMD
incident. The CSTs in border states are currently not permitted to conduct
exercises and coordination that involve cross-border movement, which may
limit their effectiveness in planning for WMD events in their regions.
Therefore, the legislative change DOD proposed could improve the
effectiveness of state WMD emergency planning. DOD officials said that the
CSTs would be federalized in order to conduct operations across the
border.

Some CST members we spoke with during our site visits said they would like
to engage in training outside the United States in order to exploit unique
or superior training opportunities. For example, several CSTs expressed a
desire to train at facilities such as the Defense Research and Development
Center in Alberta, Canada, in order to undergo live-agent training, which
several CST members told us would significantly enhance their training and
exercise efforts. They also pointed out that the U.S. Marine Corps'
Chemical and Biological Incident Response Force has trained at the
Canadian facility and greatly benefited as a result. CST members with whom
we spoke said that permitting the CSTs to train at superior or unique
facilities in other countries could increase their knowledge, skills, and
experience, better preparing them to execute their mission.

DOD and NGB are also informally considering such limited overseas missions
as assisting foreign nations in developing CBRNE response teams similar to
the CSTs and prepositioning CSTs at international events, such as the
Olympics, to help provide critical monitoring and response support. CST
commanders with whom we spoke told us that limited overseas roles for
CSTs, such as foreign assistance and prestaged support missions, may
provide them valuable experience and therefore have a positive effect on
CSTs' readiness to perform their stated mission.

During the course of our work, we heard from NGB and DOD officials and
some CST commanders that NGB and DOD have also informally considered even
more demanding overseas missions for the CSTs, including assisting
warfighting forces in such places as Iraq and Afghanistan. DOD officials
could not identify for us whether a validated requirement exists for any
of these more expansive overseas missions, and they told us that they have
no plans to request that Congress expand the CSTs' mission to encompass
them. Should such overseas missions be contemplated in the future,
however, our review of CST capabilities, along with our discussions with
CST members, indicates that support to the warfighter in places like Iraq
and Afghanistan is not practicable because of inappropriateness of the
CSTs' commercial-grade equipment for use in austere conditions. Further,
such operations would likely have a negative effect on CST readiness and
availability, drawing much more heavily on existing CST equipment and
personnel and reducing states' access to CSTs, a critical component of the
domestic WMD response infrastructure.

CST Program Faces Management Challenges That Could Increase Risk to
Long-term Sustainment

NGB has made progress in establishing an institutional management approach
to sustain the CST program once all 55 teams are certified. However, NGB
faces several challenges to the program in such areas as staffing,
coordination planning, equipment maintenance and acquisition, training and
exercise oversight, readiness reporting, facilities, and varying state
oversight and support of their CSTs. Although these challenges have not
yet affected the overall readiness of the CSTs, if the current efforts to
address them are unsuccessful, they could impede the progress of the newer
teams and increase the risk to the long-term sustainment of the program.

NGB Is Pursuing Institutional Management Efforts

NGB recognizes that the CST program-with 19 teams not yet certified-is
still in the development process. In seeking to fully establish and
sustain the CST program, NGB has made progress in developing institutional
mechanisms that should facilitate standardization and continuous
improvement within individual CSTs and across the program as a whole. For
example, NGB's CST standardization program is an attempt to establish a
baseline level of interoperability among all CSTs in critical areas, such
as training, logistics, personnel administration, and budgeting. One of
the CST program managers responsible for developing the standardization
program explained that it was initiated to ensure total program oversight
and accountability for the CSTs and to assist the states in their CST
oversight responsibility. Under the standardization program, NGB will
evaluate each CST every 18 months. This evaluation will be coordinated
with state-level command inspections that the Army requires. Program
personnel have completed a series of test visits to uncertified CSTs, and
NGB expects to begin formal evaluative visits in May 2006.

NGB has also issued a CST regulation that details the processes and
procedures for CST management.16 One of the CST program managers described
the regulation as a desk reference guide for state officials as well as
for the CSTs themselves. It clarifies CST operations in many areas,
including mission requests and validation, command and control, personnel
and administration, reporting requirements, funding, and certification.

Other general management efforts NGB has led or helped coordinate include
the following:

o The recent consolidation of Army-directed training and external
evaluation responsibilities for the CSTs. This should facilitate progress
and consistency across the program in terms of collective training and
external evaluations.

o Establishment of working groups at both the CST and program management
levels to facilitate improvements in doctrine, organization, training,
materiel, leadership and education, personnel, and facilities for the CST
program.

o Development and oversight of doctrine and other guidance to assist the
establishment of the 55 CSTs.17 In creating this doctrine and guidance,
NGB and the Army organization responsible for writing the doctrine have
sought to incorporate lessons learned by the teams from the first few
phases of the program as they established themselves in their respective
states and territories.

Further information on DOD management efforts related to the CSTs can be
found in appendix II.

CSTs Struggle to Fully Staff Teams

NGB faces several challenges to the CST program that could impede the
progress of the newer teams as well as hinder the long-term sustainment of
the CST program. One challenge is that CSTs struggle to maintain their
official allotment of 22 fully trained, mission-capable personnel because
of turnover, team structure, and retention challenges.

NGB officials reported that CST positions exhibit an annual turnover rate
of 25 to 35 percent. This is due to team members departing after their
tours are complete, dismissal of team members for a variety of reasons,
and reassignments within teams to replace departed personnel. After vacant
positions are filled, new CST members are away from their teams for the
first year, satisfying training requirements. Once they return they must
be integrated into the team's collective exercises and other existing
operations. As a result, CSTs sometimes conduct their missions with less
than full unit strength, and 75 percent of CST commanders responding to
our data collection instrument reported that the ability of CSTs to
perform their mission is adversely affected by the lack of available
personnel because of training, leave, and other manpower issues. However,
the commanders also said that their teams remain ready to conduct their
mission, reporting, for example, that a CST can perform its mission with
less than 22 people as long as other members of the team can substitute
for a gap.

The CST structure also creates a staffing challenge because few of the
advanced military occupational specialties on the team are represented by
more than one person. For example, the nuclear medical science officer,
who is responsible for operating the CST's mobile laboratory and is
critical to the CST's ability to identify CBRNE substances, is the only
member of the team with that special skill. Likewise, there is a single
physician's assistant and a single modeler assigned to each team. If these
or other highly technical positions remain vacant for an extended period,
the team must rely upon cross-trained personnel within the team or borrow
key personnel from other teams. Seventy-nine percent of CST commanders
responding to our data collection instrument reported that this lack of
depth among key personnel adversely affects the team's ability to perform
its mission. Additionally, 88 percent of commanders who responded report
that there are too few duty positions in the team's eight-member survey
section. CST commanders reported to us that the survey teams should have
more people and that responding with too few personnel restricts a CST's
ability to make multiple entries into an incident scene in search of
suspected CBRNE substances, degrades its ability to remain on scene for
long periods without relief, and increases the time required for
resolution of an incident. CSTs reported that their teams have still been
able to conduct their missions and that cross-training other team members
to add depth to various team sections may actually increase their overall
capabilities.

CST staffing challenges are further exacerbated by recruiting and
retention difficulties. When key personnel such as the nuclear medical
science officer or physician's assistant depart, the resulting open spots
are especially hard to fill because qualified applicants are difficult to
attract from the civilian world and are not widely represented within the
military. CST commanders and NGB officials explained that the lack of
promotion opportunity within the teams was another major factor affecting
a soldier's decision to become or remain a CST member, and that career
progression is particularly limited for the team's Air Guard contingent.
They also listed other factors that frustrate a team's ability to recruit
and retain CST members, including the team's substantial training
requirements and its full-time alert status for possible deployment.

NGB has pursued a number of efforts aimed at addressing these staffing
challenges. For example, during live responses, NGB augments the lead CST
with additional individuals and sometimes with entire teams. NGB has also
been working to fund and conduct a limited operational experiment to
validate the CSTs' personnel and equipment list. Recommendations for
adjustments to the number of authorized personnel may result from this
experiment.

In a further attempt to address staffing challenges, NGB is currently
compiling the latest turnover data and other relevant personnel
information to send to the service secretaries to encourage them to
authorize $150 per month incentive pay for CST personnel in accordance
with Title 37 United States Code, Section 305(b).

Although these efforts may ease some of the staffing challenges discussed
above, it is too early to know whether they will fully address them.

CSTs Lack Guidance on Conducting Coordination in Their States

Another challenge is that NGB provides little guidance to the CSTs on how
they should coordinate with state and local emergency responders and
officials, potentially lengthening the amount of time it takes new teams
to become incorporated into their home state emergency response
infrastructure. CST coordination and outreach efforts vary in nature and
scope from state to state, and they include practices such as briefing
state and local officials and responders on the mission and capabilities
of the CST, developing protocols for working with emergency responders and
state officials, participating in training with other responders,
conducting exercises with other responders, and offering technical advice
to other responders.

Established CSTs, state and local officials, and state and local
responders have identified CST coordination and outreach efforts as being
critical to the success of CST operations. Such efforts increase the CSTs'
visibility at the local level, improve responders' understanding of the
CST mission (for example, when they can be legitimately deployed),
solidify working relationships and open communication between the CSTs and
state and local responders, and increase the CSTs' familiarity with the
vulnerabilities and strategic targets in all areas of their states.

Some CSTs reported a learning curve with respect to conducting successful
coordination and outreach. For example, a few CSTs initially did not have
good relationships with other emergency responders until outreach efforts
clarified the role of the CST as working to support local and state
emergency responders. One CST we visited coordinated closely with its
state and local partners to prepare a clear set of written protocols and
coordination mechanisms that it found to be highly successful. Some state
officials reported that their CSTs have not yet developed written
coordination protocols for state and local emergency responders, even
though responders expressed confusion regarding CST capabilities and
mission. NGB has not issued any guidance or requirements regarding the
development, implementation, or assessment of CST coordination plans and
outreach efforts. NGB has not included such outreach efforts in CST
regulations as a mission-essential task, there is no formal system in
place for sharing coordination best practices across teams, and there are
no requirements to develop written protocols with local and state
officials and responders.

NGB officials told us that they recognize the importance of coordination
and outreach to ensure the success of CSTs in their home states. However,
they have not yet considered formal guidance for the teams on the subject.

CSTs Face Equipment, Training, Readiness Reporting, and Facilities
Challenges

CSTs experience other challenges that NGB recognizes as important, and it
has efforts under way to address them. Many of these efforts are new or
ongoing, and it is therefore not clear how effective they will be in
addressing the specific challenges. While these challenges have not yet
affected the CSTs' overall readiness, if the current efforts to address
them are unsuccessful, the challenges could threaten the long-term success
and sustainability of the program.

One of challenges the CSTs face is maintaining and replacing military and
commercial equipment at the pace required to sustain CST readiness. CST
members told us that they experience varying or poor maintenance support
for their military equipment, which is the responsibility of the National
Guard in each state. They, as well as state National Guard and NGB
officials, told us that the varying degree of state National Guard support
stems mostly from the state National Guards' lack of understanding of the
unique nature of the CST as a unit as opposed to a more traditional
National Guard military unit. CST members reported that maintenance
support for their commercial equipment, which is done through the
NGB-managed Consequence Management Support Center in Lexington, Kentucky,
tends to be better. They also expressed concern that the pace of equipment
replacement and development is too slow to ensure that the CSTs have the
most relevant equipment available to accomplish their mission and that
their existing equipment is updated to prevent its being worn out. NGB
officials report that NGB and DOD have heard these concerns from the CSTs
and are taking the following steps to address these equipment-related
challenges:

o NGB is working with the Joint Program Executive Office for Chemical and
Biological Defense and the Army Maneuver Support Center to plan for future
generations of CST equipment.

o NGB Logistics is assessing the cost of each piece of CST equipment and
developing new items where appropriate.

o NGB Resource Management is requesting an increase in funds in future
years to maintain the CST equipment sets.

These efforts may help address some equipment challenges, such as adequate
equipment update and re capitalization plans, but it is not yet clear
whether they will be successful in the near or long term. NGB's
standardization program may help the state National Guard organizations
provide better maintenance support for the CSTs' military equipment, but
it will take time and cooperation between NGB, the CSTs, and their
respective state National Guard commands to accomplish this.

Another challenge the CSTs face is a lack of oversight and evaluation of
exercises required of CSTs each year. Unlike the external evaluations the
CSTs undergo before certification and every 18 months thereafter, the 12
or more exercises the CSTs plan for and conduct each year do not follow
the same specific set of objectives and criteria and are not evaluated to
determine the extent to which those objectives were met. NGB officials
told us that they recognize the need for more oversight of these exercises
at the NGB and state levels. NGB and DOD have the following efforts under
way to help address the lack of exercise oversight and evaluation:

o NGB and the Army Maneuver Support Center revised the CST Commanders
Pre-Command Course to include instruction on training management.

o NGB is incorporating into its ongoing standardization initiative
training management components to ensure teams are adhering to Army
training regulation.

o NGB is bringing a member of the standardization initiative to NGB to
assist in training oversight.

o DOD is consolidating Army-directed external evaluations and related
training responsibilities under U.S. Army North to facilitate progress and
consistency across the CST program.

These efforts should help NGB and the states better oversee and evaluate
the effectiveness of the CST program. However, since many of the
initiatives are new, particularly the standardization program, it is not
clear how effective they will be.

The CSTs use two separate systems to report their readiness measures. CST
members we interviewed said that one system, the standard Army readiness
system (DOD's Status of Resources and Training System), is ill suited to
the unique nature of the CSTs. They also said that while the other
system-maintained by NGB-is better suited to the CSTs as a unit, the
system requires constant effort by team members to update and involves
using secure Internet connections the teams do not always have readily
available at their home stations. Many of the CST members we interviewed
said that because the two systems overlapped, they should be merged or one
should be eliminated. NGB officials explained that the system they
maintain is critical for administering the Response Management Plan and is
not meant to supplant the standard Army system. They also said that DOD is
transitioning to the new Defense Readiness Reporting System. NGB expects
the CSTs to replace the two existing systems with the new one in October
2006. This should solve the problem of having two separate readiness
reporting systems. However, until the new system is in place and NGB and
CST members can evaluate the extent to which it suits the unique nature of
the CSTs and helps NGB administer the Response Management Plan, it remains
unclear how fully the new system will address this challenge.

Finally, some CSTs have reported that their facilities are inadequate in
terms of vehicle, storage, and training space. NGB recognizes that some
CST facilities are not adequate and has issued revised planning templates
for CST facilities to the states. However, as we discuss further below,
the varying degree to which states understand how to use these templates
and fully meet the needs of their CSTs indicates that the challenge
remains to be fully addressed.

NGB Lacks Guidance to Help State National Guard Commands Oversee and
Support CSTs

NGB has made progress in issuing guidance that explains state National
Guard roles and responsibilities for overseeing and supporting their CSTs,
but this has been insufficient to fully inform the states about the unique
nature and requirements of the CSTs and how to integrate such a unit into
the state National Guard command structure. The result has been varied
oversight of the CSTs at the state level in important administrative areas
and varied support to their CSTs in areas such as staffing and equipment
augmentation and designing and building the facilities to house the teams.

According to NGB officials and the certified teams we visited, DOD
established the first CSTs without the benefit of a great deal of
direction and guidance that would help create a unique unit from scratch
and incorporate that unit into a state National Guard structure that is
unaccustomed to such units. Subsequently, NGB issued its CST management
regulation, which listed responsibilities for state National Guard
headquarters to exercise fiscal and administrative management and
oversight of the CSTs in their states or territories.18 This guidance
includes state National Guard responsibility for such CST oversight as
issuing training guidance, approving mid- and long-range training plans
and objectives, property accountability, and conducting readiness and
compliance inspections. While this guidance represents progress in
clarifying the roles of NGB and the states in overseeing and supporting
the CSTs, it is not as detailed as NGB's guidance on operational command
and control and mission-related topics in explaining roles and
responsibilities.

Although the CST program has been under way for over 7 years, CST members
and state National Guard officials with whom we met said the guidance on
how the states should integrate the CSTs into their National Guard
structures and how CST oversight and support should be conducted is still
lacking. NGB officials told us that they recognized that the states have
varied widely in how they have integrated the CSTs into their state
National Guard structures. They also said they are planning to issue
further guidance to clarify how states should integrate their CSTs into
the new state Joint Force Headquarters organizations but that they are
waiting for these organizations to be fully in place.

Because of the lack of clear guidance from NGB on how state National Guard
organizations should oversee and support their CSTs, the level and quality
of oversight and support for CSTs varies by state. Some states and
territories we visited did not have formal plans in place at their
National Guard headquarters or at the CST level for evaluating the
effective use of resources, and very few of those states conducted
periodic internal reviews of the CSTs. The states set up budget and
accounting records to ensure funds for the CSTs were available when and
where needed, but they conducted no regular program reviews for the CSTs.

Many of the states and territories we visited did not have specific
objectives for collective training, and they did not measure
accomplishments against previously determined specific mission objectives.
Therefore, those states could not identify deficiencies or make command
management decisions based on such analyses. As a result, NGB and the
states were not in a position to know if they were making the most
effective use of CST resources.

Again, because NGB has no clear guidance to the states, state National
Guard support of the CSTs also varies widely in terms of staffing,
equipment, and facilities. One state we visited provides additional
administrative support to its CST through the use of three or four regular
part-time National Guard members. This arrangement also allows those
part-time members access to some CST training and, in the event those
individuals apply for vacant permanent CST positions, can cut down on
hiring and training delays. Another state hired an additional full-time
duty member to support the team's logistics. Some states provided limited
amounts of additional equipment to support their CSTs, such as laptop
computers. Other states do not augment their CSTs. Among the reasons some
state National Guard officials reported for why their state's National
Guard headquarters did not augment their CSTs were a lack of money and
lack of interest by the headquarters in the CSTs because they are small
units. NGB officials acknowledged that they need to help the states
understand that the CSTs are unique units and should therefore be
considered high priority.

During our site visits, we found inconsistencies in how states interpret
and apply procurement guidance to CST equipment requests. As a result,
some states approved equipment for a CST while other states did not. For
example, NGB guidance permits the purchase of nonstandard uniforms with
state funds only and if necessary for CSTs to accomplish their mission by
blending in with other police and first responder personnel. However, some
states we visited refused to purchase uniforms for their teams, even
though the teams indicated a need. Other states did support the purchase
of the nonstandard uniforms. While NGB, state National Guard, and CST
officials stated that they believed it was important to have the
flexibility to make purchases that best support the CSTs' mission, some
CST commanders however thought this subjectivity sometimes negatively
affected the CSTs' ability to obtain material support.

States have also had difficulties designing and renovating or building
facilities that meet the needs of the CSTs. State National Guard officials
said the unique nature of the CST mission made it more difficult for
states to understand the support requirements and expectations placed upon
their CSTs. For example, in addition to the need for climate controlled
spaces for sensitive equipment, most CST members we interviewed said that
there is a need for enclosed bays for all vehicle storage because it
facilitates ready-to-roll deployment, improves vehicle security, and
provides an all-weather maintenance and training area. However, 78 percent
of the CST commanders who responded to our data collection instrument
reported that their facilities are not large enough to hold all vehicles
and other CST equipment. Approximately half reported that their facilities
are not large enough for all personnel to have an adequate workspace.
National Guard officials in the states and territories we visited also
identified inadequacies with their facilities. They said they followed
Army procurement and budgeting guidance, which sometimes affected whether
identified changes could be made to the design or construction. Sometimes
the state National Guard did not recognize the unique mission of the CST
as compared to building an armory, and sometimes the design was set before
the CST commander or other members had a chance to review the plans.
Because of varying interpretations, some states have constructed new or
remodeled facilities that are in need of further remodeling. Other CSTs we
visited were satisfied with their facilities, despite believing that such
things as vehicle bay space were not completely adequate. These CST
members reported that their state National Guard headquarters worked well
with the CST to design the most effective facility they could to meet the
unique needs of the team.

In addition to the CST management regulation, NGB instituted the CST
standardization program partially in response to its concerns that states
were not adequately monitoring the CSTs' implementation of key Army
management controls in training, logistics, budgeting, and other areas.
According to preliminary standardization program reviews, state National
Guard headquarters have done few periodic reviews and inspections. NGB
officials told us they intend to use these reviews to increase state
participation in oversight of the CSTs and will also spell out in greater
detail for the states the type of interaction NGB believes is necessary
and required by regulation. If pursued consistently, the standardization
program should help NGB better coordinate with the states on how to
oversee and support the CSTs, though a significant NGB-state National
Guard cooperative effort will be needed to facilitate success.

Conclusions

In managing the CST program, DOD and NGB have made significant progress
toward establishing 55 highly specialized teams in every state and U.S.
territory. The focus has thus far been on reaching the goal of certifying
all 55 teams. As the CST program seeks to institutionalize its key
processes and sustain itself in the long term, we see four areas that
could increase the risk to that effort.

First, confusion about what types of non-WMD deployments the CSTs can and
should use to help them accomplish their mission of preparing for or
responding to WMD events could make it more difficult to effectively
coordinate efforts at the state and local levels and possibly inhibit
regional and national coordination between the states and the federal
government. Expanding the CSTs' mission to encompass natural and man-made
disasters may not sufficiently clarify what types of such missions are
appropriate for the CSTs to conduct, possibly exacerbating confusion among
state and local officials about the mission of the CSTs.

Second, some limited overseas missions, such as coordinating with
officials from Canada and Mexico or training at live agent facilities, may
be beneficial to CST training and operational effectiveness. Though DOD
indicates that it is not planning to request that Congress expand the
CSTs' role to encompass more demanding overseas missions, to the extent
missions such as regular CST support to overseas combatant commands are
considered in the future, they would likely have a detrimental impact on
the readiness and availability of the teams to perform their original
mission to support domestic WMD response.

Third, despite the progress NGB has made in fully establishing the CST
program and formalizing institutional sustainment plans for the teams,
many areas of the program face significant challenges that require
specific guidance and action from NGB. NGB understands these challenges,
particularly in the areas of team staffing, coordination guidance,
equipment maintenance and acquisition, training and exercise oversight,
readiness reporting, and facility adequacy. While individual team
readiness has not yet suffered, if current and planned NGB efforts to
address these challenges are not successful, the challenges could
eventually cause harm to overall CST readiness.

Fourth, despite NGB's progress in establishing such unique and specialized
units as the CSTs, there remains a need for additional guidance on the
administrative oversight structure for the CSTs at the state level. Small
differences between the way each state manages its CST may be expected,
given the fact of 54 different military commands. While NGB's plans for
additional guidance on the oversight and support of the CSTs and its
standardization program should help states better integrate the CSTs,
further guidance and coordination efforts between NGB, the CSTs, and the
state National Guard commands is warranted.

Recommendations for Executive Action

To help address management challenges and further efforts to sustain the
CST program, we recommend that the Secretary of Defense, in concert with
the Chief of the National Guard Bureau and the Secretaries of the Army and
of the Air Force, take the following three actions:

o Clarify the types of non-WMD responses that are appropriate for CSTs as
part of their mission to prepare for domestic WMD and catastrophic
terrorist attacks.

o Fully incorporate into ongoing management efforts to sustain the CST
program a plan with goals, objectives, and evaluation mechanisms to
address challenges such as team staffing issues, coordination guidance,
equipment maintenance and acquisition, training and exercise oversight,
readiness reporting, and facilities requirements.

o Develop clear guidance for the states on how CSTs should be integrated
into state National Guard commands in order to facilitate an effective
administrative oversight and support structure for the CSTs in each state
that reflects familiarization with the role, mission, and requirements of
these specialized units, and work with state adjutants general and federal
financial officers at the state level to find appropriate ways to exchange
ideas and best practices for ensuring effective NGB-state National Guard
partnership in overseeing the CST program. One such method could be to
create or modify an existing working group or team to allow state National
Guard membership.

Agency Comments and Our Evaluation

In comments on a draft of this report, DOD generally agreed with the
intent of our recommendations. DOD discussed steps it is currently taking
as well as actions it plans to take to address these recommendations. DOD
also provided technical comments, which we have incorporated into the
report where appropriate.

In response to our recommendation that DOD clarify the types of non-WMD
responses that are appropriate for CSTs, DOD reported that it has
requested that Congress authorize the CSTs to respond to catastrophic
events of intentional or unintentional origin and that if this is enacted,
DOD will direct the Chief of the National Guard Bureau to develop
implementing instructions. DOD reiterated its view that the CSTs have been
participating in non-WMD responses as training. Expanding the CSTs'
mission to include both WMD and non-WMD events should help clarify the
role of the latter in the CSTs' overall mission. We continue to believe
that as NGB develops implementing instructions, it should provide clear
guidance on the types of non-WMD responses that are appropriate for the
CSTs. This should help alleviate confusion about the CSTs' mission and
prevent their being overemployed to the detriment of their WMD-related
training and mission requirements.

In its comments on our recommendation regarding incorporation into ongoing
CST management efforts of a plan to address critical challenges to the CST
program, DOD highlighted some of the CST management efforts we discussed
in our report, such as the CST Working Group and the CST standardization
program. DOD further stated that additional management efforts should be
deferred until the effectiveness of the standardization program can be
assessed. We agree that the program offers the potential of a good
evaluation tool for NGB, the CSTs, and the states' National Guard
headquarters and that further information on many of the challenges we
highlight in our report may be gleaned from the results of the
standardization program. To the extent the program further highlights
these and other challenges for which no immediate corrective measures are
in place, we would expect the Chief of the National Guard Bureau to take
the appropriate management action.

In response to our recommendation that NGB develop clear guidance for the
states on how CSTs should be integrated into state National Guard commands
to facilitate effective administrative oversight and support, DOD
indicated that in addition to guidance on state oversight of the CSTs in
the recently published CST management regulation, the CST standardization
program and NGB-conducted formal training for state National Guard
leadership provide additional measures to review and reinforce state
National Guard administrative oversight of their CSTs. DOD further
recognized the value of currently available venues for coordination
between NGB, the CSTs, and the states' National Guard commands. As we
state in our report, we believe that if pursued consistently, the
standardization program should help NGB better coordinate with the states
on how to oversee and support the CSTs. This should help NGB and the
states provide an effective long-term partnership to sustain the CST
program. To the extent necessary based on the result of standardization
program evaluations, we would expect NGB to expand its efforts to assist
state National Guard commands to provide effective oversight and support
of their CSTs.

DOD's written comments are reprinted in appendix IV.

As agreed with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its date. At that time, we will send copies to the appropriate
congressional committees, the Secretary of Defense, and the Secretary of
the Army. We will also make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site at
http://www.gao.gov .

If you or your staff have any questions concerning this report, please
contact me at (202) 512-5431 or [email protected] . Contact points for
our Offices of Congressional Relations and Public Affairs may be found on

the last page of this report. Key staff members who contributed to this
report are listed in appendix V.

Sincerely yours,

Davi M. D'Agostino Director, Defense Capabilities and Management

Appendix I  Scope and Methodology

To assess the extent to which the Civil Support Teams (CST) are prepared
to conduct their mission, we gathered information on the categories and
process of the two CST readiness measurement mechanisms; reviewed
readiness-related documents for the 14 teams we visited; included similar
readiness information in a data collection instrument sent to all 55 CSTs;
and discussed CST readiness with local, state, and federal officials who
have worked with CSTs. We observed the external evaluation of 1 CST by
U.S. Army officials and attended the after action review following the
evaluation. We also observed an exercise that included one CST and a
number of local and state responders. During our site visits, we discussed
operational command and control mechanisms with CST members and their
National Guard headquarters officials. We compared the published mission
of the CSTs to the types of missions the CSTs are performing and discussed
the extent to which their mission is well understood with CST members and
local, state, and federal officials. Further, we discussed the potential
effect of overseas missions on CST readiness with CST members and civilian
emergency management officials in the states and territories we visited.

To assess the extent to which effective administrative mechanisms are in
place for the CSTs, we compared National Guard Bureau (NGB) regulations
and guidance on management of the CSTs with the practices in place at the
14 CSTs we visited. We also discussed operational and administrative
issues with CST members in those states and their National Guard
headquarters officials. We collected similar information in the data
collection instrument sent to all 55 CSTs. During our site visits, we
discussed with CST members those challenges they believed could inhibit
CST readiness in future. We categorized these challenges, discussed them
with NGB officials, and compared the challenges to information on NGB
efforts related to those areas. We also collected cost data related to the
establishment and sustainment of the CSTs from NGB, state National Guard
personnel, and the CSTs themselves. We did not independently verify cost
data, but we interviewed NGB officials who manage the data about data
quality control procedures. We determined the data were sufficiently
reliable for the purposes of this report.

To address our objectives, we visited and interviewed officials from the
Department of Defense (DOD), including the Office of the Assistant
Secretary of Defense for Homeland Defense, NGB, U.S. Army Forces Command,
First Army, Fifth Army, and United States Northern Command. During each
state site visit we met with members of the CST and officials from the
state National Guard headquarters, state emergency management and homeland
security officials, representatives from local community emergency
response agencies (such as fire and police departments), and
representatives of federal agencies and organizations (such as the Federal
Bureau of Investigation and Department of Energy).

Our site visits to 14 of the 55 CSTs were conducted from August through
December 2005. We selected the 14 teams in order to obtain a reasonable
sample of CSTs based on a number of criteria, including geographic
distribution, age of team, certification status, state size, state
population, state government emergency management and homeland security
organization, and DOD-related command structure. We visited the following
locations:

o Alabama

o Alaska

o Colorado

o Iowa

o Massachusetts

o Montana

o New Mexico

o New York

o North Carolina

o Puerto Rico

o Rhode Island

o Tennessee

o Texas

o Washington

To supplement the interviews we conducted during the site visits, we
collected supporting documents from the CSTs and individuals we
interviewed and made physical observations of CST facilities in every
state we visited.

To further address our objectives, we designed a broad data collection
instrument for all 55 CSTs that would collect information regarding CST
personnel, equipment, training, certification, costs, coordination, and
mission scope. Within these major topic areas, we developed and tested
relevant questions based upon previous GAO work, current research, and
interviews at both the NGB and CST level. After two formal pretests with
the command staff of 2 separate CSTs, we deployed the data collection
instrument simultaneously to the National Guard's state supervisory
auditors for all 55 teams and asked that they be forwarded to the CST
commanders in each of their respective states or territories. The data
collection instrument was administered via e-mail using an ActiveX-
enabled Microsoft Word attachment.

Although every team received an identical version of the data collection
instrument, we advised the team commanders that because of differing
experiences, locations, certification statuses, and lengths of service, we
recognized that not all teams would be able to respond to every question.
Each section of the instrument contained questions that could be answered
by both certified and uncertified teams, as well as questions that were
applicable to certified teams only. The data collection instrument was
addressed to the 55 unit commanders, and while these individuals were
explicitly responsible for the overall content of the completed data
collection instruments, we permitted them to delegate specific questions
or sections to other appropriate members within the CST. To ensure a full
and candid response, we noted that individual responses would be
attributed neither to individual CSTs nor to their individual members.
Further, we requested that the teams transmit their responses over a
secure e-mail channel to safeguard any sensitive information.

We distributed the data collection instrument via e-mail on September 26,
2005, and it was deployed through December 27, 2005. Out of the 55
deployed, we received 52 completed data collection instrument responses
during our 3-month response window.1 To analyze the results of the
completed responses, we noted responses for all questions and highlighted
those we deemed significant, such as responses where there was
overwhelming agreement among CST commanders. These responses and others
were compared with preliminary results from our site visits and used to
verify that the GAO site visit teams had not overlooked significant
widespread CST issues.

Percentage results from the data collection instrument are discussed in
the letter. In some cases, there are fewer than 52 respondents for a given
question. Because some respondents did not answer all questions, the
percentages we report are calculated using the base of respondents who
answered the question. In no cases did fewer than 48 of the 52 respondents
answer a question whose percentage results appear in the report.

Because this was not a sample survey, there are no sampling errors.
However, the practical difficulties of conducting any data collection
effort may introduce errors, commonly referred to as nonsampling errors.
For example, difficulties in how a particular question is interpreted, in
the sources of information that are available to respondents, or in how
the data are entered into a database or are analyzed, can introduce
unwanted variability into the survey results. We took steps in the
development of the data collection instrument, the data collection, and
the data analysis to minimize these nonsampling errors. For example, GAO
staff with subject matter expertise designed the data collection
instrument in collaboration with social science survey specialists. Then,
the draft questionnaire was pre-tested with the command staff of two CSTs
to ensure (1) the questions were relevant, clearly stated, and easy to
comprehend; (2) terminology was used correctly; (3) the questionnaire did
not place an undue burden on the respondents; (4) the information was
feasible to obtain; and (5) the survey was comprehensive and unbiased.
Finally, when the data were analyzed, a second, independent analyst
checked all computer programs.

The entire data collection instrument appears in appendix III.

We performed our work from April 2005 through March 2006 in accordance
with generally accepted government auditing standards.

Appendix II  CST Program Management Efforts

NGB has focused much of its management on establishing and certifying all
55 of the authorized CSTs. But NGB also recognizes that a significant
amount of effort is required to ensure that the CST program is sustained
for the long term, while it also provides for the continued improvement of
the process for establishing the teams and modifying doctrine, training,
equipment, and operational considerations as necessary. Some of the
institutional efforts NGB has coordinated or led include a CST
standardization program, coordinating Army-directed CST training and
evaluations, and establishing working groups to evaluate and recommend
improvements to the CST program.

Standardization and Evaluation Program

The standardization program is scheduled to evaluate each CST every 18
months and is intended to be coordinated with state-level command
inspections that the Army requires. The process begins with a
precoordination meeting 6 months prior to the scheduled standardization
visit that explains the purpose, evaluation method, and desired outcome
for the upcoming visit. Ninety days prior to the scheduled visit, a second
coordination meeting is held to resolve any remaining administrative
details and to allow the standardization team personnel responsible for
conducting the evaluation to become familiar with the CST's location.
During the visit itself, these personnel conduct compliance-oriented
evaluations using a series of checklists that monitor various subtasks
within the evaluated areas. For example, the training checklist assesses
55 items, including whether the CST has an approved Mission Essential Task
List, whether the team publishes quarterly training guidance, and whether
the team conducts after-action reports for all training. Each checklist
item is evaluated as "go," "no-go," or "not applicable." Items that are
initially characterized as needing improvement (no-go) may be upgraded to
satisfactory (go) as a result of on-the-spot corrections. At the
evaluation's conclusion, standardization team personnel will present the
results of their evaluation to the state adjutant general. They must issue
a formal report to the adjutant general within 6duty days after the end of
their visit. Among the standardization program's objectives is integrating
with state and intermediate command inspections that could reduce the
total amount of time committed to the inspection process, as well as
imposing CST-specific management controls to assist in the prevention of
fraud, waste, and abuse of Army resources. Program personnel have
completed a series of test visits to CSTs, and they expect to begin formal
evaluation visits in May 2006.

Army Training and Evaluation Support

As of October 1, 2005, Fifth Army assumed sole responsibility for all CST
external evaluations and related training, with the exception of CSTs in
Hawaii, Alaska, and Guam, which remain under U.S. Army Pacific. Under
Fifth Army, the organization and protocols of all CST training and
evaluation teams should be standardized. Army, NGB, and CST officials
report that training, education, and experience requirements of
trainer/evaluators will also be standardized. They indicate that this
standardization should increase the consistency of external evaluations
and related collective training across all teams. Consolidation of Army
training, readiness, and oversight responsibilities could also promote
better information sharing and guidance development both across the Fifth
Army training and evaluation teams and the program as a whole.
Responsibility for all CST external evaluations and related training was
previously divided geographically between the First Army and Fifth Army
under the U.S. Army Forces Command, with the exception of Hawaii, Alaska,
and Guam. Although both First and Fifth Armies were required to train and
evaluate teams to the standards set forth in the CSTs' Mission Training
Plan, Army field manuals and other regulations, each Army organized its
CST training and evaluation teams differently and followed different
protocols for executing training and external evaluations.

CST Working Groups

In April 2005 NGB formally established the Civil Support Team Working
Group to (1) increase the operational effectives of CSTs by providing
operationally relevant advice on gaps, shortfalls, and improvements to CST
doctrine, organization, training, materiel, leadership and education,
personnel, and facilities (DOTMLPF); (2) assist in implementing any
resulting plans, and (3) promote standardization and interoperability
among CSTs. The working group process had already been working informally
since the establishment of the first 10 CSTs. In addition to NGB, working
group membership includes the CST commanders and representatives from the
Army Maneuver Support Center1 and the joint service Chemical and
Biological Defense Program. The working group is organized to include
several technical working groups and subgroups that focus on specific
aspects (e.g., equipment, personnel, and training) or components (e.g.,
operations, survey, medical and science assessment, communications,
computer and information systems, and logistics/sustainment) of the CST
program. In June 2004 the Army Maneuver Support Center and NGB initiated
the Integrated Concept Team to determine the tasks, schedules, milestones,
and products required to develop operational concepts and provide DOTMLPF
solutions to support the CST program. In addition to directing the efforts
of the other CST working groups with regard to DOTMLPF responsibilities,
the Integrated Concept Team is also tasked with more broadly addressing
CST issues within the larger scope of DOD force management and operational
capabilities plans.

Appendix III  Data Collection Instrument

Appendix IV  Comments from the Department of Defense

Appendix V  GAO Contact and Staff Acknowledgments

Davi M. D'Agostino (202) 512-5431 or [email protected]

In addition to those named above, Ann Borseth, Assistant Director; Bari L.
Bendell; Jaclyn A. Bowland; David A. Brown; Carole F. Coffey; Lee Cooper;
Joseph W. Kirschbaum; David A. Mayfield; Walter K. Vance; and Tamika S.
Weerasingha made key contributions to this report.

(350687)

www.gao.gov/cgi-bin/getrpt? GAO-06-498 .

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Davi M. D'Agostino at (202) 512-5431 or
[email protected].

Highlights of GAO-06-498 , a report to the Chairman, Subcommittee on
National Security, Emerging Threats, and International Relations,
Committee on Government Reform, House of Representatives

May 2006

HOMELAND DEFENSE

National Guard Bureau Needs to Clarify Civil Support Teams' Mission and
Address Management Challenges

To prepare for potential attacks in the United States involving weapons of
mass destruction (WMD), Congress approved the development of National
Guard Civil Support Teams (CST) tasked to identify chemical, biological,
radiological, nuclear, or high-yield explosive weapons; assess
consequences; advise civil authorities on response measures; and assist
with requests for additional support. Thus far, 36 of the 55 approved
teams have been fully certified to conduct their mission. The National
Guard Bureau (NGB) is in the process of establishing, certifying, and
planning for the long-term sustainment of the CSTs. GAO was asked to
address the extent to which (1) the CSTs are ready to conduct their
mission and (2) effective administrative mechanisms are in place for the
CSTs.

What GAO Recommends

To ensure the sustainment of CSTs, the Secretary of Defense should work
with NGB and the Secretaries of the Army and of the Air Force to clarify
the types of non-WMD response efforts that belong in the CST mission;
develop guidance to address CST management challenges; and develop
guidance and work with state adjutants general to clarify administrative
oversight and support structures for CSTs. The Department of Defense (DOD)
generally agreed with our recommendations.

The established CSTs have thus far been trained, equipped, and staffed and
have command and control mechanisms in place to conduct their domestic
mission. However, confusion resulting from a lack of guidance on the types
of non-WMD missions the CSTs can conduct to prepare for their WMD
terrorism mission could impede coordination between state authorities and
local emergency management officials on the appropriate use of the CSTs.
CSTs were created to focus on assisting civil authorities in domestic WMD
events. Based on its review of the CSTs' training, equipment, and staffing
criteria; analysis of CST readiness data; site visits to 14 CSTs; and
discussions with state, local, and federal responders, GAO found the
certified teams visited to be ready to conduct their mission. NGB and the
states have a clear structure for operational command and control of the
CSTs. Though current NGB guidance and the CSTs' message to state and local
officials emphasize the CST mission as being focused on WMD events, some
CSTs have responded to non-WMD events, such as providing emergency
assistance to the Gulf Coast states after the 2005 hurricanes. While NGB
views such missions as useful preparations for WMD events, guidance has
not been clarified to reflect the type of non-WMD missions that would be
appropriate. This lack of clarity has caused confusion among state, local,
and NGB officials, potentially slowing coordination efforts. Also, DOD is
proposing a limited role for the CSTs to coordinate and operate with
Mexican and Canadian officials in the event of a cross-border WMD
incident. DOD and NGB are informally considering limited overseas missions
for the teams, though they have no plans to request a further expansion of
the CSTs' mission to encompass overseas operations. According to NGB and
the CST commanders, some overseas missions could provide valuable
experience and have a positive effect on CST readiness, while other, more
demanding missions, such as supporting the warfighter, could be
detrimental to the readiness and availability of the CSTs.

Although NGB continues to develop a long-term sustainment plan for the CST
program, going forward, it faces challenges to the administration and
management of the CSTs that could impede both the progress of newer teams
and the long-term sustainment of the program. NGB has made progress in
establishing an administrative management structure for the CSTs,
including issuing a broad CST management regulation and initiating a
standardization and evaluation program. However, the CSTs face challenges
in personnel, coordination plans, equipment acquisition and planning,
training objectives, readiness reporting and facilities. Further,
insufficient NGB guidance on state National Guard roles and
responsibilities for overseeing and supporting their CSTs has resulted in
varied support at the state National Guard level. NGB is aware of the
challenges and has efforts under way to address them. While these
challenges have not yet undermined CST readiness, if NGB efforts are
unsuccessful, the progress of newer teams could be impeded and the
long-term sustainment of the CST program put at greater risk.
*** End of document. ***