The U.S. Department of Homeland Security (DHS) is preparing to create a new regional structure that will govern how the DHS interacts with state and local offi­cials and members of the private sector. The plan, which could take several years to implement fully, will undoubtedly engender controversy and debate. Local officials will rightly insist on upholding the principles of federalism. Others are actively lobbying for estab­lishing regional centers in their cities or states.¹ Mem­bers of Congress, many of whom have been advocating such a structure for years, will evaluate the rationale and costs of implementing the regional framework.

To make rollout of the plan as effective as possible, DHS leaders should first enunciate its goals and guiding principles. They also must explain how they will reorganize the DHS secretariat to provide effi­cient oversight of the new structure and achieve all these goals in a cost-effective manner. The DHS should create a regional framework that primarily serves the needs of states, local communities, and the private sector. Its purpose should be to improve coordination, planning, and information sharing, with an emphasis on strengthening intelligence and early warning, critical infrastructure protection, and the preparedness and response components of homeland security.

The Plan for the Plan

Although state and local officials will undoubtedly lead the initial response to any crisis, it is improbable that a major terrorist attack would affect only a single city or that a single municipal authority would have sufficient assets to manage such a calamity alone. At a minimum, response efforts would likely require mutual aid from multiple jurisdictions. In a major crisis, federal assets would supplement state and local resources. Effective cooperation among officials at all levels of government and the private sector is essential, yet the DHS lacks an adequate regional structure to facilitate coordination.^[1]

The National Response Plan (NRP) and the National Incident Management System (NIMS) provide a framework for this activity.^[2] These ini­tiatives provide a single "all-hazards" approach to directing federal resources for meeting any national emergency, ensuring that responses to future incidents, both natural and manmade, will be more coordinated effectively and effi­ciently. Additionally, the department has estab­lished an effective Homeland Security Operations Center (HSOC), a round-the-clock "nerve center" that provides a national hub for organizing the federal response to homeland security-related incidents.

The NRP, NIMS, and HSOC were prerequisites to establishing the objective requirements for a regional homeland security framework. The DHS, however, still lacks a suitable operational structure to support them.

The Homeland Security Act of 2002 merged over 22 federal organizations and programs into a single department. As part of this legacy, the DHS inherited at least a dozen different regional struc­tures. Each agency brought its own national framework for directing its operations. For exam­ple, the Federal Emergency Management Agency (FEMA) still has 10 regional offices and two area offices. Each region serves several states, and the regional staffs work directly with the states to help plan for disasters, both natural and man­made; develop mitigation programs; and meet needs when major crises occur.^[3] However, before the department was established, no national framework existed to coordinate all critical homeland security missions.

The Homeland Security Act requires the DHS to propose a regional framework but provides no guidance on how to implement the system or its purpose. It states only that:

Not later than 1 year after the date of the enactment of this Act, the [DHS] Secretary shall develop and submit to Congress a plan for consolidating and co-locating-

(1) any regional offices or field offices of agencies that are transferred to the Department under this Act, if such officers are located in the same municipality; and

(2) portions of regional and field offices of other Federal agencies, to the extent such offices perform functions that are transferred to the Secretary under this Act.^[4]

Although the department failed to meet the time line established by Congress, it has dedi­cated considerable effort to developing a national regional structure. DHS leaders intend to establish some eight to 10 regional homeland security centers. At a news conference in New Orleans in February 2004, DHS Secretary Tom Ridge said, "As part of our restructuring plans, we made a decision to establish regional Home­land Security offices."^[5] Ridge added that each office would employ 50-100 people, most of whom would be administrators.^[6]

The proposed regional organization is likely to arouse intense interest among state and local lead­ers and Members of Congress.^[7] Accordingly, DHS representatives should conduct an effective public information and awareness campaign before the department rolls out its reorganization strategy. At a minimum, this effort should:

• Enunciate the goals of the regional framework (i.e., what the regional offices are supposed to accomplish);
  
• Explain how the regional framework will be compatible
  with the principles of federalism;
  
• Include a plan for restructuring the DHS sec­retariat to provide effective oversight of the regional framework;
  
• Explain the criteria for selecting regional offices and their personnel (including their directors); and
  
• Include a sensible plan to fund the reorganiza­tion without detracting from other high-prior­ity DHS projects.

Above all, DHS leaders need to explain how the regional structure will assist state and local homeland security managers to protect their communities better with respect to all-hazard preparedness, mitigation, response, and recovery. Before the DHS releases its plans, important issues require resolution-including specifying the potential roles, missions, and functions of the regional offices, as well as their relationships with state and local officials and the private sector.

Whatever regional security structure the Admin­istration decides to support, the DHS should imple­ment the proposal in a way that allows stakeholders an opportunity to participate in the process to a greater extent than has been the case to date. Through speeches, publications, and other media events, DHS representatives should first announce the principles for regional design that underpin their recommendations. Stakeholders should then be allowed time to comment on them through for­mal and informal mechanisms. Ideally, such an interactive process would result both in a better proposal and in stakeholders' becoming more com­mitted to the subsequent reorganization.

DHS Management of a Regional Framework

As a first step, the DHS needs to create a leader­ship structure to oversee the regional framework. Vesting all responsibility for coordination and out­reach with state and local governments and the private sector in a single undersecretary in the directorate should be a priority.

The DHS should consolidate its critical infra­structure protection, preparedness, and state/local/ private-sector coordination efforts under an Undersecretary for Protection and Preparedness. This reorganization would merge the following agencies, components, and authorities:

1. The infrastructure protection component of the Information Analysis and Infrastructure Protection Directorate,
   
2. The Office of State and Local Government Coordination and Preparedness,
   
3. The non-operational transportation infrastruc­ture protection mission of the Transportation Security Administration,
   
4. The preparedness responsibilities of the Emer­gency Preparedness and Response Directorate,
   
5. The private-sector preparedness mission of the Office of Private Sector Liaison, and
   
6. DHS grantmaking authority.

Consolidating these disparate efforts would provide the DHS Secretary with a stronger plat­form from which to lead national efforts, deter­mine priorities, identify critical vulnerabilities, work with state/local/private-sector entities on securing those vulnerabilities and preparing for attacks, and make grants to accomplish missions and induce cooperation.^[8]

Roles, Missions, and Functions of the Regional Network

The DHS should construct a regional network of support offices reporting to the Undersecre­tary of Protection and Preparedness. The offices should be led by political appointees who enjoy sufficient clout to gain ready access to local lead­ers. Ideally, these individuals would include former politicians, police chiefs, and other peo­ple who have some background in both home­land security issues and their geographic areas of responsibility.

The DHS could organize periodic specialized training programs for the directors to ensure that they possess adequate expertise in all dimensions of homeland security. The department should also arrange for the directors to meet, perhaps as a group, at least bimonthly in Washington with DHS senior officials. These meetings would keep them knowledgeable about the latest developments at DHS headquarters and provide a nationwide per­spective to complement their regional focus. The personnel at the regional offices should number approximately 100 people and include a planning staff, a training staff to coordinate regional exer­cises, and information technology (IT) and other specialists to administer the office's small commu­nications/operations center.

The first priority of this regional organization should be to support the flow of information and coordinate training, exercises, and professional development for state and local governments and the private sector. The structure's key operational mission should be to enhance prevention, pre­paredness, response, and critical infrastructure protection at the regional level, as well as to coor­dinate activities like intelligence sharing and early warning with the Justice Department's regional Joint Terrorism Task Forces (JTTFs).

Although an important task would be to foster mutual aid compacts and joint planning, DHS regional directors should not have authority over existing DHS agencies (such as the Coast Guard or Customs and Border Protection Bureau) or have operational or policymaking responsibilities. For example, FEMA should continue as an indepen­dent agency responsible for coordinating federal response to natural and manmade disasters, including terrorism. Similarly, customs and border protection should remain federal responsibilities, with appropriate policies determined in Washing­ton, although reflecting local conditions. DHS regional directors will need to rely primarily on persuasion and on local actors' self-interest in using the regional offices to develop better ties and access to DHS leaders and assets in Washington, including grants and other funding.

As a secondary priority, the DHS regional frame­work could achieve cost savings and other efficien­cies by highlighting regional redundancies and promoting consolidations across geographic boundaries. The July 2002 National Strategy for Homeland Security called for enhanced coopera­tion among actors at the various levels of govern­ment and the private sector to avoid duplication and better integrate scarce national homeland security assets. Obvious candidates for improved regional integration of support functions include IT systems and administrative activities.

Even when state and local actors desire to pos­sess their own independent support structures, shared procurement could produce cost savings because sellers might lower unit prices in return for the larger purchases. Furthermore, the network could develop resource-sharing and cost-sharing plans for activation during a crisis and manage the coordinated stockpiling of equipment. Congress also might give regional offices discretion over some grant money and other forms of federal pre­paredness assistance to help correct suboptimal spending allocations within a region as well as to promote homeland security cooperation within regions more generally.^[9]

Third, regional offices could better integrate the homeland security programs of state and local entities, both public and private, with DHS policy­makers in Washington. Serving as conveniently located points of contact for state, local, and pri­vate actors, regional coordinators could assume a lead role in identifying the needs and resources that exist both nationally and within their regions.

Not being based in Washington, DHS officials posted at regional offices might be more attuned to the peculiar needs of state and local stakeholders within their areas, including public officials, first responders, commercial actors, National Guard commanders, and other community leaders. In effect, they would serve as the eyes and ears of the DHS Secretary at the regional level. They could also sponsor pilot projects that, if successful, could be adopted in other regions if not nationally.

Regional offices should also improve situational awareness and transparency among homeland secu­rity actors by promoting information sharing among them. Increased data exchanges could occur both electronically, through an expansion of the horizon­tal communication provided by the Joint Regional Information Exchange System (JRIES) and related networks, and through additional opportunities for personal encounters. People involved with home­land security at the state and local levels-including first responders, public health experts, and law enforcement officials-have diverse backgrounds and expertise, so their approaches to these issues (as well as their insights regarding them) likely differ. State-level actors in particular could benefit from more frequent interaction with their nearby col­leagues given that many crises could easily spill across state boundaries.

The National Incident Management System could provide a framework for sharing regional response assets. It might be appropriate to estab­lish separate Regional NIMS Centers (perhaps with associated Regional Homeland Security Opera­tions Centers or Regional Emergency Operations Centers) within each DHS regional office to super­vise and implement this process.^[10] These centers could help to shape the elements of the National Response Plan that most concern their regions so that they complement the specific response activi­ties that federal, state, and local agencies are already tasked with developing and implementing.

DHS regional offices could also receive author­ity over "force packages" consisting of baskets of homeland security resources available within their geographic areas. Supplemented by federal assets, these force packages could bolster state and local entities responding to natural and man-made emergencies.

An Exception to the Plan: The National Capital Region

As defined in U.S. law, the National Capital Region (NCR) encompasses the District of Columbia; Montgomery and Prince George's Counties in Maryland; Arlington, Fairfax, Lou­don, and Prince William Counties and the City of Alexandria in Virginia; and all cities and other units of government within those jurisdictions.^[11] Following the terrorist incidents of September 11, 2001, which included an attack on the Penta­gon in Arlington, authorities in the NCR enhanced their cooperation on homeland secu­rity issues, including emergency preparedness and response. For example, regional working groups (such as the Emergency Preparedness Council, the Senior Policy Group, and the Criti­cal Infrastructure Protection Steering Group) have begun to meet, and NCR-wide exercises have increased in terms of frequency and dimen­sion. The U.S. Northern Command also recently established a new subordinate command, the Joint Force Headquarters-National Capital Region (JFHQ-NCR), to coordinate Department of Defense involvement in the NCR's homeland security activities.

Although the NCR today represents the most prominent regional homeland security organization, the DHS should not attempt to replicate its struc­ture elsewhere. The NCR is atypical in many respects. It does not border a foreign country, and it has a high concentration of closely located federal, state, and local government entities with multiple and often overlapping jurisdictions. It also pos­sesses many high-value terrorist targets, including public officials and national monuments.^[12]

Furthermore, Congress singled out the NCR for special treatment when it created an Office of the National Capital Region Coordination (ONCRC) within DHS in the Homeland Security Act of 2002. The ONCRC is tasked with enhancing information sharing within the NCR, coordinating its diverse preparedness programs, and pooling homeland security resources among NCR-based entities with the intention of encouraging them "to think, plan and prepare regionally" when it comes to security.^[13] The ONCRC does not have an operational mission or crisis-management responsibilities.

Despite these caveats regarding the appropriate­ness of generalizing from the NCR, designers of future regional DHS offices should examine it closely for lessons that might be applicable elsewhere.

Conclusion

The DHS should create a regional framework with the primary aims of enhancing information sharing and other coordination among the states, the private sector, and the DHS headquarters in Washington. The regional offices should not have operational or policymaking responsibilities.

For the most effective rollout of the plan, DHS leaders should first enunciate its goals and guiding principles. They also must explain how they will reorganize the DHS secretariat to provide effective oversight of the new structure. Stakeholders should be allowed time to comment on the plan's goals and objectives, which should result both in a better proposal and in stakeholders' becoming more committed to the subsequent reorganization.

Edwin Meese III is a Distinguished Fellow at The Heritage Foundation, where he holds the Ronald Reagan Chair in Public Policy. James Jay Carafano, Ph.D., is Senior Research Fellow for National Security and Homeland Security in the Kathryn and Shelby Cullom Davis Institute for International Studies at The Heritage Foundation. Richard Weitz, Ph.D., is a mem­ber of the senior staff at the Institute for Foreign Policy Analysis.