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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: 

GAO-06-498: 

GAO Highlights: 

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 

Why GAO Did This Study: 

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 Found: 

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. 

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. 

[Hyperlink, http://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 dagostinod@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

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

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

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: CST Program Management Efforts: 

Appendix III: Data Collection Instrument: 

Appendix IV: Comments from the Department of Defense: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables Tables : 

Table 1: Examples of Civil Support Team Section Tasks: 

Table 2: CST Response Management Plan Sectors: 

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

Figures Figures : 

Figure 1: The Unified Command Suite: 

Figure 2: The Analytical Laboratory System: 

Abbreviations: 

CBRNE: chemical, biological, radiological, nuclear, and high-yield 
explosive: 
CERFP: CBRNE Enhanced Response Force Package: 
CST: Civil Support Team: 
DOD: Department of Defense: 
DOTMLPF: doctrine, organization, training, materiel, leadership, and 
education, personnel, and facilities: 
NGB: National Guard Bureau: 
WMD: weapons of mass destruction: 

May 31, 2006: 

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),[Footnote 1] Congress in 
1998 approved the development of federally funded, state[Footnote 2] 
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.[Footnote 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.[Footnote 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.[Footnote 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.[Footnote 6] Among 
the resulting efforts, Congress in fiscal year 1999 approved the 
development of National Guard WMD CSTs.[Footnote 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: Command; 
Number of personnel: 2; 
Examples of tasks: 
* Provides command and control of the team; 
* Interfaces with external agencies and organizations; 
* Provides advice to the first responder community; 
* Facilitates introduction of follow-on DOD forces into a consolidated 
response team; 
* Ensures that sample collection and handling procedures are conducted 
safely and are accurately documented and the chain of custody is 
maintained. 

Section: Operations; 
Number of personnel: 4; 
Examples of tasks: 
* Conducts hazard modeling; 
* Provides information for vulnerability analysis; 
* Coordinates and directs CBRNE surveys; 
* Coordinates and monitors unit training; 
* Prepares site safety and incident action plans. 

Section: Medical/ analytical; 
Number of personnel: 4; 
Examples of tasks: 
* Establishes and maintains medical surveillance and monitoring 
programs for the unit; 
* Conducts lab analysis of incident- related samples; 
* Conducts medical reach-back coordination with medical labs; 
* Secures and prepares samples for transport and subsequent transfer; 
* Provides emergency medical stability for CST members. 

Section: Communications; Number of personnel: 2; 
Examples of tasks: 
* Provides voice and data communications through a variety of networks 
designed to support CST operations; 
* Maintains communications within the team, with higher headquarters, 
with other responding agencies, and with subject matter experts; 
* Establishes secure communications links, as required. 

Section: Survey; 
Number of personnel: 8; 
Examples of tasks: 
* Conducts missions in appropriate protective equipment; 
* Enters a suspected hot zone to conduct search for CBRNE hazards; 
* Collects and preserves incident-related samples for delivery to 
analytical equipment; 
* Identifies, marks and reports contaminated areas. 

Section: Administration and logistics; 
Number of personnel: 2; 
Examples of tasks: 
* Sustains the ability of the CST to conduct operations; 
* Maintains logistics status reports; 
* Procures and stores unit equipment according to command guidance. 

Source: DOD. 

[End of table] 

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: 

[See PDF for image] 

Source: DOD. 

[End of figure] 

Figure 2: The Analytical Laboratory System: 

[See PDF for image] 

Source: GAO.

[End of figure] 

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.[Footnote 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.[Footnote 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: 1; 
States or territories: Pennsylvania, New Jersey, New York, Connecticut, 
Rhode Island, Massachusetts, New Hampshire, Vermont, and Maine. 

Response sector: 2; 
States or territories: West Virginia, Virginia, District of Columbia, 
Maryland, Delaware, Illinois, Indiana, Ohio, Michigan, and Wisconsin. 

Response sector: 3; 
States or territories: Alabama, Georgia, South Carolina, North 
Carolina, Tennessee, Kentucky, Florida, Puerto Rico, and the U.S. 
Virgin Islands. 

Response sector: 4; 
States or territories: Louisiana, Texas, Oklahoma, Arkansas, Kansas, 
Missouri, Minnesota, Iowa, and Mississippi. 

Response sector: 5; 
States or territories: New Mexico, Arizona, California, Nevada, Utah, 
Colorado, Hawaii, and Guam. 

Response sector: 6; 
States or territories: South Dakota, North Dakota, Wyoming, Montana, 
Idaho, Washington, Oregon, Alaska, and Nebraska.  

Source: National Guard Bureau. 

[End of table]

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: Response; 
Number: 405; 
Percentage of missions: 8. 

Mission type: Stand-by; 
Number: 580; 
Percentage of missions: 11. 

Mission type: Assist; 
Number: 4,109; 
Percentage of missions: 81. 

Mission type: Total; 
Number: 5,094; 
Percentage of missions: 100. 

Source: GAO. 

[End of table] 

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: 

* funding for CST airlift; 

* various CST-unique training courses; 

* equipment replenishment and modifications; 

* maintenance of secure Internet access for CSTs; 

* government-owned vehicles; 

* communications links; 

* Unified Command Suite maintenance and support; 

* civilian personnel involved in CST oversight functions; and: 

* 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.[Footnote 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,[Footnote 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 attacks[Footnote 12] 
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.[Footnote 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.[Footnote 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.[Footnote 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.[Footnote 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: 

* 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. 

* 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. 

* Development and oversight of doctrine and other guidance to assist 
the establishment of the 55 CSTs.[Footnote 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: 

* 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. 

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

* 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: 

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

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

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

* 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.[Footnote 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: 

* 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. 

* 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. 

* 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 [Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-5431 or d [Hyperlink, dagostinod@gao.gov] 
agostinod@gao.gov. 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, 

Signed by: 

Davi M. D'Agostin: 
Director, Defense Capabilities and Management: 

[End of section] 

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: 

* Alabama: 
* Alaska: 
* Colorado: 
* Iowa: 
* Massachusetts: 
* Montana: 
* New Mexico: 
* New York: 
* North Carolina: 
* Puerto Rico: 
* Rhode Island: 
* Tennessee: 
* Texas: 
* 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.[Footnote 19] 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. 

[End of section] 

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 Center[Footnote 20] 
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. 

[End of section] 

Appendix III: Data Collection Instrument: 

Data Collection Instrument for the Weapons of Mass Destruction Civil 
Support Teams: 

[See PDF for image] 

[End of figure]  

[End of section] 

Appendix IV: Comments from the Department of Defense: 

Assistant Secretary Of Defense: 
2600 Defense Pentagon: 
Washington, DC 20301-2600: 

MAY 12 2006: 

Homeland Defense: 

Ms. Davi M. D'Agostino: 
Director, Defense Capabilities & Management: 
US Government Accountability Office: 
441 G St, N.W.: 
Washington, DC 20548: 

Dear Ms. D'Agostino: 

This is the Department of Defense response to the GAO draft report, GAO-
06-498, "Homeland Defense: National Guard Bureau Needs to Clarify Civil 
Support Teams' Mission and Address Management Challenges," dated April 
4, 2006, (GAO Code 350687). We appreciate the opportunity to provide 
comments to your draft report regarding your review of the Weapons of 
Mass Destruction- Civil Support Teams (WMD-CST). I have enclosed 
comments on your recommendations and administrative corrections to the 
report. 

Let me take this opportunity to thank you and your staff for including 
us in your review of the WMD-CST program and subsequent report. 

Sincerely, 

Signed by: 

Paul McHale: 

Enclosures: 
As stated: 

GAO Draft Report-April 4, 2006: 
GAO Code 350687/GAO-06-498: 

"Homeland Defense: National Guard Bureau Needs to Clarify Civil Support 
Teams' Mission and Address Management Challenges" 

Department Of Defense Comments To The Recommendations: 

Recommendation 1: The GAO recommended that the Secretary of Defense 
direct the Chief of the National Guard Bureau to clarify the types of 
non-weapons of mass destruction responses that are appropriate for 
civil support teams as part of their mission to prepare for domestic 
weapons of mass destruction and catastrophic terrorist attacks. 

DOD Response: Partially concur. The Secretary of Defense has requested 
that Congress clarify the authorization language for employment of 
civil support teams (CSTs). Specifically, CSTs should be permitted to 
respond, using the full range of capabilities developed for a response 
to an attack using WMD, to catastrophic events arising from 
unintentional or natural events. Should Congress change the law, the 
Secretary of Defense will direct the Chief, National Guard Bureau to 
develop implementing instructions. 

The CST Contingency Operations Plan in NGR 500-3/ANGI 10-2503 
highlights CST employment criteria used by the governor and the 
adjutant general to assess the mission requirements before committing 
the CST to a state mission. Teams have been participating in national 
security events and other high visibility events, to include natural 
disasters, i.e., the Columbia Shuttle Disaster and the aftermath of 
Hurricane Katrina, as a training opportunity. Participation in such an 
event is considered training, until/unless an event occurs which makes 
it a full operational response under the law. 

Recommendation 2: The GAO recommended that the Secretary of Defense 
direct the Chief of the National Guard Bureau to fully incorporate into 
the National Guard Bureau's on going management efforts to sustain the 
civil support team 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. 

DOD Response: Partially concur. WMD-CSTs are funded, trained, and 
supported under the management systems established by Department of the 
Army and the National Guard Bureau (NGB). In conjunction with the 
findings of the DoD WMD CST Program Review, the Army conducted a Force 
Management Analysis (FORMAL) Review and presented the findings to the 
Army Vice Chief of Staff in March 2003. The FORMAL Review developed a 
plan to "institutionalize" and fully integrate the WMD CST program into 
the DoD resource capabilities process, clarifying the proponency for 
WMD-CSTs as a joint effort between the NGB and the Army Training and 
Doctrine Command, and identified a process to identify and resolve 
doctrine, organization, training, leader development, material, 
personnel and facilities issues. In April 2005, NGB chartered the Civil 
Support Team Working Group to establish a systematic process to 
leverage WMD-CST unit member knowledge and experience and to resolve 
operational problems, issues and recommend program improvements. The 
Civil Support Team Working Group functions to increase operational 
effectiveness of the CSTs by providing operationally relevant advice on 
gaps, shortfalls, and improvements to CST doctrine, operations, 
training and education, material, leader development, personnel, and 
facilities requirements; assist with synchronized execution of 
resultant plans; and promote standardization and interoperability among 
the CSTs. Further, the NGB has established a Standardization Evaluation 
and Assistance Team (SEAT) program which will visit each state and 
territory on an 18-month rotational cycle. While it is clear that CSTs 
are unique to DoD, the argument for additional or exceptional 
administrative controls should be deferred until the SEAT program is 
fully implemented. Improvements can always be made to existing systems 
and the growth of additional management controls, above those currently 
in place, is considered premature until we are able to measure the 
effectiveness of the SEAT program. 

Recommendation 3: The GAO recommended that the Secretary of Defense 
direct the Chief of the National Guard Bureau to develop clear guidance 
for the states on how civil support teams should be integrated into 
state National Guard commands in order to facilitate an effective 
administrative oversight and support structure for the civil support 
teams in each state that reflects familiarization with the role, 
mission, and requirements of these specialized units, and to 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 National Guard Bureau - state National Guard 
partnership in overseeing the civil support team program. One such 
method could be to create or modify an existing working group or team 
to allow state National Guard membership. 

DOD Response: Partially concur. The intent of Congress to have these 
teams under the control of the governor is clear in the authorizing 
language. As such, the National Guard Bureau (NGB) has provided 
guidance for effective management rather than strict control measures. 
The adjutants general in 23 states are the heads of the state emergency 
management agencies; therefore, 31 states have different structures. As 
such, command and control of the CST is left to the state to determine 
the best fit in order to maximize training and command and control 
functions. As indicated in this finding, several groups have been 
created to exchange ideas. These groups provide a valuable venue to 
share effective management techniques. To ensure that the existing 
state structure provides the necessary oversight, NGB has recently 
published the CST Management Regulation, NGR 500-3/ANGI 10-2503, which 
delineates guidance on the responsibilities, policies and procedures 
for the management for these teams. Further, NGB has established a 
Standardization Evaluation and Assistance Team (SEAT) program which 
will visit each state and territory on an 18-month rotational cycle. 
These visits will provide the adjutant general with an independent 
review and validation of state support to the CST and provide 
recommendations for management controls and changes to ensure that CSTs 
meet the guidance issued by the Chief, National Guard Bureau. NGB also 
provides a formal training for state leadership which focuses on the 
unique requirements of establishing and sustaining CSTs under the CST 
Concept of Operations. Continued effort will be applied to keep, and 
possibly expand, the venues currently available to exchange ideas and 
information. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Davi M. D'Agostino (202) 512-5431 or d [Hyperlink, dagostinod@gao.gov] 
agostinod@gao.gov: 

Acknowledgments: 

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): 

FOOTNOTES 

[1] For the purposes of this report, "weapons of mass destruction" 
means any weapon or device that is intended, or has the capability, to 
cause death or serious bodily injury to a significant number of people 
through the release, dissemination, or impact of (1) toxic or poisonous 
chemicals or their precursors, (2) a disease organism, or (3) radiation 
or radioactivity. 50 U.S.C. § 2302 (1). 

[2] For purposes of this report, "state" includes the 50 United States; 
the territories of Guam, Puerto Rico, and the Virgin Islands; and the 
District of Columbia. 

[3] The teams were originally called Rapid Assessment Initial Detection 
Teams. 

[4] GAO, Reserve Forces: Actions Needed to Better Prepare the National 
Guard for Future Overseas and Domestic Missions, GAO-05-21 (Washington, 
D.C.: Nov. 10, 2004). 

[5] One system is DOD's Status of Resources and Training System and the 
other is NGB's CST-specific Operational Reporting System. 

[6] Pub. L. No. 104-201, § 1411 (1996). 

[7] Pub. L. No. 105-261, § 510 (1998). 

[8] 10 U.S.C. § 12310(c)(5). 

[9] National Guard Bureau, Weapons of Mass Destruction Civil Support 
Team Management, NGR 500-3/ANGI 10-2503, ch. 14 (Jan. 12, 2006). 

[10] In Homeland Security Presidential Directive-5, dated February 28, 
2003, the President directed the development of a new National Response 
Plan to align federal coordination structures, capabilities, and 
resources into a unified all-discipline, and all-hazards approach to 
domestic incident management. It covers coordination among federal, 
state, local, and tribal organizations by increasing the speed, 
effectiveness, and efficiency of incident management. Under the 
National Response Plan, state, local, and other organizations are, 
among other things, to utilize established incident reporting protocols 
and modify their existing incident management and emergency operations 
plans to align with National Response Plan coordinating structures, 
processes, and protocols. 

[11] In 2002 Congress added to the CST's mission "preparation for or 
response to a terrorist attack or threatened terrorist attack in the 
United States that results, or could result, in catastrophic loss of 
life or property." Pub. L. No. 107-314, § 514 (2002). 

[12] 10 U.S.C. § 12310(c). 

[13] White House, The Federal Response to Hurricane Katrina Lessons 
Learned (Washington, D.C.: February 2006). The report also acknowledges 
that increased costs and other resources would be necessary to support 
an expanded CST mission. 

[14] 10 U.S.C. § 12310(c)(3). 

[15] National Guard Bureau, Weapons of Mass Destruction Civil Support 
Team Management, ch. 1-1. 

[16] National Guard Bureau, Weapons of Mass Destruction Civil Support 
Team Management. 

[17] Department of the Army, Weapons of Mass Destruction Civil Support 
Team and Chemical, Biological, Radiological, and Nuclear Installation 
Support Team Tactics, Techniques, and Procedures, Field Manual 3-11.22 
(January 2004). 

[18] National Guard Bureau, Weapons of Mass Destruction Civil Support 
Team Management. 

[19] The three CSTs that did not submit responses included one phase 2 
team and two phase 5 teams. 

[20] Part of the Army's Training and Doctrine Command. 

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