It’s Never Too Late: Restructuring the Department of Homeland Security’s Regional Framework

Lewis Carroll, “The Walrus and the Carpenter,” Through the Looking Glass and What Alice Found There (Macmillan: 1871).

Homeland Security Act, Pub.L. 107–296, 116 Stat. 2135, enacted November 25, 2002, www.dhs.gov/xlibrary/assets/hr_5005_enr.pdf.

Proverb attributed to W. E. Hickson, a 19^th-century British educational writer.

For information on component regional offices, operational centers, and other regional presences, see DHS, Bottom-Up Review Report (BUR) (Washington, DC, July 2010), A1–A8, www.dhs.gov/xlibrary/assets/bur_bottom_up_review.pdf.

These are the 10 “Standard Federal Regions” established by the Office of Management and Budget (OMB) in April 1974. Created 4 years later, FEMA structured its field organization on the basis of these regions, as approved by OMB. See OMB, Standard Federal Regions, Circular A-105, Federal Management Circular 73–4.

Horizontal means systematic interactions among operational units to ensure that they complement each other and work together in the field toward common objectives; vertical means sustained interactions between each operational unit and headquarters. These two reinforcing objectives were stressed in the past few years in connection with the “One DHS” goal of a unified department, which was supported by Secretary Tom Ridge as one of the major goals for making the new department effective; however, it remained dormant until Secretary Michael Chertoff stimulated this construct and Secretary Janet Napolitano made it a key part of DHS management reforms. See Harold C. Relyea, Homeland Security: Department Organization and Management—Implementation Phase, CRS Report PL 31751 (Washington, DC: Congressional Research Service, Library of Congress, January 3, 2005), www.fas.org/sgp/crs/RL31751.pdf; Memorandum, “DHS Policy for Internal Information Exchange and Sharing,” February 1, 2007, www.pierce.ctc.edu/dist/coe/pdfDocs/Guidelines/DHS_Policy_for_Internal_Information_Exchange_Sharing.pdf; and Booz Allen Hamilton, Securing the Future: Management Lessons of 9/11 (Washington, DC: Partnership for Public Service, 2011), 1, ourpublicservice.org/OPS/publications/viewcontentdetails.php?id=164.

This report reportedly took the form of a letter and typescripted report from Secretary Ridge to Pamela J. Turner, DHS assistant secretary for legislative affairs, on February 4, 2004. It was not officially approved by the White House, nor did Congress react in a formal manner. See Relyea, Homeland Security, 12.

Alice Lipowicz, “Lawmakers Suggest Major Restructuring for DHS,” Federal Computer Week, October 14, 2011, fcw.com/articles/2011/10/14/lawmakers-suggest-regional-consolidations-for-dhs.aspx. This piece includes a letter to GAO on October 11, 2011, from Rep. Susan Miller (R-MI), Rep. Henry Cuellar (D-TX), Sen. Joseph Lieberman (I-CT), and Sen. Susan Collins (R-ME) requesting a two-part study on DHS regional structures.

Homeland Security Act, Section 706.

For an excellent source of ideas regarding homeland security regional centers, see James Jay Carafano, Richard Weitz, and Edwin Meese III, “Organizing for Victory: Proposals for Building a Regional Homeland Security Structure,” Heritage Foundation Backgrounder, no. 1817 (January 21, 2005). There seem to have been very few subsequent analyses on this topic during the past 10 years, although this assessment is based on just a sample of available sources. But these analyses, although not focused directly on the overall issue, have still produced some ideas on management, integration, staffing, and logistics to inform the new DHS regional structure construct. See GAO, “DHS Multi-Agency Operation Centers Would Benefit from Taking Further Steps to Enhance Collaboration and Coordination,” GAO-07-686R (Washington, DC, April 5, 2007); and FEMA, Integration of Preparedness and Development of Robust Regional Offices: An Independent Assessment (the NAPA Report), report by a Panel of the National Academy of Public Administration (NAPA) for the US. Congress and Federal Emergency Management Agency (Washington, DC, October 2009), www.napawash.org/wp-content/uploads/2009/09-02.pdf.

DHS, FY2004 Budget in Brief (February 2003), 4, www.dhs.gov/xlibrary/assets/FY_2004_BUDGET_IN_BRIEF.pdf. As part of his proposal, Ridge would have directors within each geographic area in charge of all operations, and they would report directly to the secretary. The commandant of the Coast Guard would continue to report to the secretary, given this agency’s military missions. At a news conference in New Orleans in February 2004, Ridge said that, as part of overall restructuring plans, the department “made a decision to establish regional Homeland Security offices” (italics added). He later clarified this by saying that he had proposed establishing regional directors when the Bush administration was creating the new department, but that his plan was rejected. See Tom Ridge with Lary Bloom, The Test of Our Times: America Under Siege and How We Can Be Safe Again (New York: St. Martin’s Press, August 2010); Stephanie Blum, “Same Priorities, Different Perspectives: Tom Ridge and Michael Chertoff on Homeland Security,” Homeland Security Affairs 6, no. 1 (January 2010); and Rachel Maddow’s interview with Tom Ridge (The Rachel Maddow Show, MSNBC, September 1, 2009).

That political forces were at work is consistent with Ridge’s statement that, “while the White House was initially supportive, it ultimately made an ‘about-face’ and rejected the idea” (Ridge and Bloom, Test of Our Times, 218). This assessment is also supported in an analysis of how the department managed itself over the 10 years since 9/11: “DHS regional [plans were] undercut by forces from within and without. … Others from within the component agencies, the White House, and Congress did not share the same aggressive interest in organizing the department regionally, and the plan remained on the shelf” (Booz Allen Hamilton, Securing the Future, 24).

DHS, BUR, 35. This statute required an assessment of the organizational alignment of the department with the national homeland security strategy and homeland security missions set forth in the Quadrennial Homeland Security Review Report: A Strategic Framework for Secure America (QHSR) (Washington, DC: DHS, February 2010), www.dhs.gov/xlibrary/assets/qhsr_report.pdf.

Ibid., 34.

Ibid., 35. The referenced legislative authority is to restore the secretary’s ability to reorganize DHS headquarters and realign component regional configurations. The BUR report also says that regional restructuring can play its part in the effort to unify the DHS (i.e., One DHS).

Homeland Security Act, Section 706.

U.S. House of Representatives, Making Appropriations for the Department of Homeland Security for the Fiscal Year Ending September 30, 2005, and for Other Purposes, H. Rpt. 108–774, 108^th Cong., 2^nd Sess., October 9, 2004, 29, www.gpo.gov/fdsys/pkg/CRPT-108hrpt774/pdf/CRPT-108hrpt774.pdf.

This is the letter referred to in footnote 8: See “Miller, et al Request GAO Study of Homeland Security Regional Headquarters,” press release, October 14, 2011, candicemiller.house.gov/press-release/miller-et-al-request-gao-study-homeland-security-regional-headquarters.

No time frame seems to have been set for completion of this study or for when at least the first part of it might be available. Its current status is unclear.

“The New Look” is best known as the name given to a US. Cold War strategy under the Eisenhower administration: see Branislav L. Slantchev, “National Security Strategy: The New Look, 1953–1960” (lecture given at the University of California, San Diego, CA, December 25, 2009).

As part of such a comprehensive analysis, all the terms used in connection with restructuring, such as streamline, consolidate, realign, co-locate, and even restructure, would need to be carefully defined in an operational context.

Early ideas about regional restructuring, including those offered by former Secretary Ridge and a few nongovernmental sources, led to these principles, which may not be fully applicable now in all their details.

The Department of Defense uses the phrase “forward deployed” with reference to forces stationed near an area of potential conflict; such forces can provide a rapid response if needed and exert a deterrent effect on an adversary, while giving visible assurance to allies and friends that the US. commitment to their security and safety is real. In a homeland security context, it means maintaining US. capabilities close to areas that can used to help stakeholders in particular regions prepare for and respond to major threats or hazards (and, in the case of terrorists, possibly inhibit attacks).

The deputy secretary could chair a DHS regional restructuring steering committee, which would include key headquarters’ representatives and heads of the affected components, to guide detailed development and subsequent execution of the plan. This committee, as a first order of business, would select directors and core staffs for each DHS regional office.

The division of labor recommended by the 2009 NAPA report for FEMA can be considered in developing a DHS regional office structure: headquarters should focus on “policy development and dissemination, the maintenance of effective business practices across the agency, and monitoring the system’s performance,” while regional offices should focus on “implementing these policies and programs, as well as establishing and nurturing the critical relationships with stakeholders” (FEMA, Integration of Preparedness and Development of Robust Regional Office, 1).

The proposal put forth here is indeed modest in that it represents one of many ways of going about correcting DHS regional problems, and many details have yet to be addressed.

Pursuant to the Post Katrina Emergency Management Reform Act, FEMA established 10 regional advisory councils (RACs) that “incorporate state, local, and tribal government and private sector input in development and revision of [… various] plans and strategies … [and] advise the Regional Administrators on ‘emergency management issues specific to that region’” (FEMA, Integration of Preparedness and Development of Robust Regional Office, 39). RACs could be broadened to support each new DHS regional office director to address not only FEMA issues but also the regional responsibilities of other components, such as CBP, ICE, and USSS.

This is a highly classified and sensitive facility, with operational and other details not openly discussed.

For more about PPD-8 and its Implementation Plan, see “Presidential Policy Directive/PPD-8, National Preparedness,” at www.FEMA.gov.

Remaining in place are the small number of specialized TSA federal air marshal offices located near key airports, enabling air marshals to respond rapidly and board flights that receive last-minute intelligence information about potential terrorist threats.

For more on command arrangements and districts, see the USGC home website at www.uscg.mil.

Ideas for identifying and realizing many of the management, operational, and cost factors needed to make the new system functional can be found in Secretary Ridge’s ideas (his book and speeches), the Heritage Backgrounder, the NAPA Report, and the (ongoing) GAO study cited earlier.

“Rolling out” is shorthand for ensuring that any proposal with impact across a range of stakeholders has been coordinated with a representative cross-section of public and private stakeholders, reviewed by the White House and other relevant federal agencies, and made part of informal consultations with key members of Congress. See Appendix A of the QHSR for how it was “rolled out,” and see also relevant ideas from the Heritage Backgrounder.