Friday, April 15, 2011

It's Baaack! Bill to limit number of UASIs (Updated)

Updated 4-21-11

Once again, there are efforts afoot to limit the number of Urban Area Security Initiative (UASI) cities.  However, this legislative maneuvering may be moot.  A combination of less funding and a new risk formula may result in less UASIs without legislative action.  Read on for a full explanation.
UASI program funds address the unique planning, organization, equipment, training, and exercise needs of high-threat, high-density Urban Areas, and assists them in building an enhanced and sustainable capacity to prevent, protect against, respond to, and recover from acts of terrorism.
The  proposed legislation, H.R.1555, was recently introduced by Rep. Nita Lowey [D-NY18] as an effort to limit the number of cities and funnel more funding to New York City. The bill's stated purpose is: "To amend the Homeland Security Act of 2002 to limit the number of Urban Area Security Initiative grants awarded and to clarify the risk assessment formula to be used when making such grants, and for other purposes."
The bill proposes to make three changes:
  1. Limit then number of designated UASIs to "not more than 25".
  2. Change the risk formula process by requiring that, "when weighing considerations of threat, vulnerability, and consequences from acts of terrorism, assign a percentage value that is not less than 33."
  3. Change the law so that the minimum allocations apply only to the State Homeland Security Grants.
The text of the bill is now available on the GPO website. Number 2 seems to be missing some language at the end of the sentence. I believe the intend it to assign at least 33% of the formula's weight to threat. The third item would limit the amount that states receive as a minimum allocation by taking UASI dollar out of the base on which the minimum percentage is applied.

If the bill passes (I would not take a bet on it) in its current form, the Homeland Security Act would then read as follows (additions indicated):
The Administrator shall designate NOT MORE THAN 25 high-risk urban areas to receive grants under this section based on procedures under this subsection.
As of April 14, 2011, the bill status was: "Referred to the House Committee on Homeland Security."  I will try to keep an eye on this bill's progress and update the blog as needed.  Here is the latest status:

This widget should help keep you up-to-date with current bill. 

Note that this is not the fist time Rep. Lowey introduced legislation under this title. H.R. 4182 was introduced in the House during the 111th Congress on Dec 2, 2009. The original text of the bill as it was written by its sponsor and submitted to the House for consideration is available on GovTrack.
That bill called for limiting the number of UASI grant to "not more than 35".  Apparently, she is now setting her target at 25 UASIs. 

While everyone is focused on the Lowey bill we seem to be missing the elephant in the room.

The elephant? UASI funding was cut dramatically (by $162 million) and there is a new risk formula that will change the allocation of grant dollars among UASIs. These two changes, working together, will likely have a dramatic impact on the UASI allocation and may render the Lowey bill moot.  (Changes to the Tier I/II construct may also change the distribution.)  If more cuts are made in 2012, which sounds likely, this will exacerbate the situation further.

The situation?  With less money, and a new formula that may skew dollars further to the left of the curve (see chart below), there will be so little left on the right hand side of the curve that it may be necessary to drop cities due to little or no funding being available (based on a combination of the budget reduction and the formula). The question may become: How much does the grant need to be for a particular MSA for it to be worth the effort to follow the UASI program guidance? Will a million dollars be the threshold as it seems to have been in the past?  Will this cause 10 cities to drop off? 20? More?

Ultimately this decision is up to the DHS Secretary (as I understand it) although the process is influenced by Capitol Hill.  No matter the outcome, for 2011 the clock is ticking. Guidance will come out soon and it will include the list of cities allocated funds for 2011 so UASIs will soon know where they stand.

It is too late to influence the outcome for 2011 and the UASI allocation list will be an important indicator on the future of UASI funding.  The 2012 budget deliberation will be next and will likely be even more important to the future of UASI. This might be the issue to focus attention on as grants may be a further target.

UASIs and other grantees will need to have a way to explain the value and effectiveness of the program.  A topic which will be addressed at the UASI Conference (in the sessions and in the hallways, I am sure).

The New Formula

The new 2011 Risk Formula places 30% on Threat, 50% on Consequence, and 20% on Vulnerability. The graphic below describes the factors that go into the calculation.

It will be interesting to see if the allocation process repeats the use of "tiers" to shift funds to larger cities when the new formula should accomplish this with a greater emphasis on consequences.  If the new risk formula works well, the tiering is no longer needed in my view.  The resulting grant curve should be smooth, as opposed to how it was in 2010 based on the tiering and the previous formula (see below).

How Funds Were Allocated in FY 2010
Eligible candidates for the FY 2010 UASI program were determined through an analysis of relative risk of terrorism faced by the 100 most populous metropolitan statistical areas in the United States, in accordance with the 9/11 Act.  In the past, funds have been allocated to as few as 30 and as many as 64 metropolitan areas (the current number).  Based on the 2010 risk analysis, the eligible candidates were grouped into two tiers according to relative risk. Tier I included the 10 highest risk areas and was allocated 63% of the total UASI funding available; Tier II includes the other 54 candidate areas and will be allocated the remaining 37% of the total UASI funding available.

The tier approach was reportedly "employed to allow applicants with a similar level of risk to compete for funding on a level playing field." However, some see it as an arbitrary cut-off (it was seven cities previously) designed to skew the outcome of the risk formula "analysis".
Again, in my view, if you have a good formula you do not need to add an artificiality like tiering. You should expect to see a smooth curve IMHO.
What to Expect for 2011
Of course, the big question is what will the 2011 allocation process look like.  We will see soon enough as 2011 UASI grant guidance is expected within the next 30 days or so.  Given the almost 20% reduction in UASI dollars and the new risk formula, I think that the curve will steepen; meaning that the top ten UASIs will gain in terms of a percentage of funds received (however loosing overall due to the cuts).  I think that many of the cities on the right hand side of the curve (that long flat "tail" shown below) will get so little in funding that it may not be worth granting funds to them. While the minimum grants are now over one million dollars, if DHS attempts to keep the list at 64 cities, it will likely shrink to less than half of that as a product of less money and less consequences.  That being the case, I am expecting the list of cities to total no more than 50.  However, if the Lowey bill passes, this number would apparently be 25. See this previous blog for a look at what a list of 25 might look like and who might get left off the list.

2010 Funding Curve, Click to enlarge.
Of course, it would be nice if the funding did not shrink. Unfortunately, shrinking funding for first responders, seems to be the current trend.  Budget times are tight but everyone needs to remember that "All Disasters Are Local" is not a slogan, it is reality.

More when I know it.

Saturday, April 2, 2011

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