Background Alaska’s location makes the United States an Arctic nation. Alaska has over 6,000 miles of coastline, and is bordered by the Beaufort, Chukchi, and Bering Seas; the Arctic Ocean; and the Bering Strait, whose jurisdiction is divided between the United States and Russia (see fig. 1). According to the 2010 Census, the U.S. Arctic coastal regions are home to about 26,000 people, including the cities of Nome, located near the Bering Strait, and Utqiagvik (formerly Barrow), the northernmost city in the United States. The U.S. Arctic coastal region is sparsely populated even by the standards of Alaska, which has the lowest population density of any state in the nation. Specifically, this region accounted for about 4 percent of Alaska’s total population of approximately 710,000 according to the 2010 Census. Alaska is also the largest state in the nation, and— given its size, terrain, environment, and population distribution—its transportation system is unique. Much of Alaska’s rail and highway infrastructure is located in the south central part of the state, and many U.S. Arctic cities and villages are accessible only by air or water. As Arctic waterways become more accessible due to declining sea ice, opportunities have increased to use maritime transportation to bring natural resources to market. The U.S. Arctic remains a frontier economy; many of its products and much of the value of commercial activities derive from natural resources. According to an assessment of undiscovered but technically recoverable oil and gas resources by the Bureau of Ocean Energy Management, the outer continental shelf regions of the U.S. Arctic’s Chukchi and Beaufort Seas contain about 24 billion barrels of oil and about 105 trillion cubic feet of natural gas. The U.S. Arctic also contains $1 trillion worth of minerals, such as zinc, nickel, and lead. The extraction of these natural resources presents technical challenges and requires large financial investments given the Arctic environment. Although warming over the past decades has made trans-Arctic maritime routes more accessible, Arctic sea ice extent remains seasonal, with most shipping occurring during a narrow window extending from summer to early fall. Arctic sea ice typically reaches its maximum extent in March and its minimum in September each year; as a result, the shipping season is typically from June through October. The minimum sea ice extent in September 2019 was tied with 2007 and 2016 as the second lowest on record since satellite observations began in 1979; the 13 lowest extents in the satellite record have all occurred in the last 13 years. As shown in figure 2, the September (minimum) sea ice extent in 2019 had a much smaller coverage area than the median September extent from 1981 to 2010. This contraction of sea ice over time has increased accessibility to the two key trans-Arctic maritime routes: the Northwest Passage (NWP) through the Canadian archipelago, and the Northern Sea Route (NSR) along the northern border of Russia. These two routes enable shipments between non-Arctic destinations, such as between Asia and Europe. However, most traffic in the U.S. Arctic is destinational, meaning it transports goods to and from the U.S. Arctic. Such traffic includes transporting natural resources extracted from the U.S. Arctic to the global marketplace and shipping supplies to U.S. Arctic communities. Maritime shipping in the U.S. Arctic involves challenges, given that the region lacks many of the typical elements of a maritime transportation system. See table 1 for examples of the types of maritime infrastructure gaps that CMTS and federal agencies have reported in the U.S. Arctic. Many federal agencies are involved with, and have a role in, U.S. Arctic maritime shipping and infrastructure (see table 2). Although these agencies’ missions are not specifically tied to the U.S. Arctic, they extend to the U.S. Arctic like any other geographic region of the country. Other state, local, and international organizations also play a role. For example, the state of Alaska’s Department of Environmental Conservation is involved with oil spill response. In addition, the North Slope Borough, a municipal government that encompasses an area of nearly 95,000 square miles along Alaska’s northern coast, has a search and rescue department that provides airborne emergency response. Alaska Native organizations represent communities that have inhabited the Arctic region for thousands of years and have cultures that are particularly sensitive to environmental changes, since they rely on hunting animals such as whales, seals, and walruses. To represent local concerns, the Arctic Waterways Safety Committee, which is comprised of subsistence hunters and others, was created in October 2014 to develop best practices for safe and efficient use of Arctic waterways. Alaska Native Corporations are private entities that manage land and assets on behalf of Alaska Natives. Lastly, international forums such as the Arctic Council and international organizations such as the IMO also have a role in establishing Arctic maritime policies and regulations. For nearly 50 years the U.S. government has articulated its interest in the Arctic through a series of strategies. For example, in 1971 a then- classified memo from National Security Council (NSC) under the Nixon Administration called for the sound and rational development of the Arctic, guided by the principles of minimizing adverse environmental effects, promoting international cooperation, and protecting security interests, including the preservation of the freedom of the seas. These same priorities, along with promoting scientific research, were underscored by the Reagan Administration in 1983. In January 2009, the George W. Bush Administration issued an Arctic Region Policy, which outlined priorities for maritime transportation in the Arctic including to facilitate safe, secure, and reliable navigation and protect maritime commerce and the environment. More recently, the Obama Administration issued a National Strategy for the Arctic Region (National Strategy) in May 2013, which identified three goals for the region: to advance U.S. security interests, pursue responsible stewardship, and strengthen international cooperation. Subsequent implementation plans for the National Strategy indicated maritime shipping and infrastructure fell under all three of these stated goals. For example, “preparing for increased activity in the maritime domain” fell under advancing U.S. security interests, “charting the Arctic region” fell under pursuing responsible stewardship, and “promoting waterways management” fell under strengthening international cooperation. As federal strategies related to the Arctic region have evolved over the years, so have the interagency groups to implement and guide these efforts. Interagency activity in the U.S. Arctic has historically been coordinated through the NSC, including the 1971 and 1983 strategies. In 1984, legislation established the U.S. Arctic Research Commission as well as the Interagency Arctic Research Policy Committee (IARPC). More recently, to enhance coordination of national efforts in the Arctic, particularly those related to the 2013 National Strategy, a 2015 Executive Order established the interagency Arctic Executive Steering Committee (AESC). AESC is chaired by the Director of the Office of Science and Technology Policy (OSTP), which is an office within the White House that leads interagency science and technology policy coordination efforts. AESC also includes NSC as a member, along with 20 other federal departments and entities. The 2016 National Strategy Implementation Framework assigned portions of the strategy’s areas of focus to interagency groups; specifically, NSC was assigned responsibility for advancing national security interests, OSTP for pursuing responsible stewardship, and the Department of State for strengthening international cooperation. The U.S. Committee on the Marine Transportation System (CMTS), which was required in 2010 to coordinate the establishment of domestic transportation policies in the Arctic to ensure safe and secure maritime shipping, has issued several relevant reports, including a 10-year projection of maritime activity in 2015, and a 10-year prioritization of infrastructure needs in the U.S. Arctic in 2016—both of which were directed by the 2014 National Strategy implementation plan. More recently, CMTS issued a 2018 report revisiting its 2016 near-term recommendations for prioritizing infrastructure needs in the U.S. Arctic and a 2019 update to its projections of Arctic maritime shipping activity from 2020 to 2030. These and other reports addressing maritime infrastructure in the U.S. Arctic are listed in appendix I. Maritime Shipping in the U.S. Arctic Generally Increased from 2009 through 2019 but Remains Limited and Was Affected by Several Factors Maritime Shipping in the U.S. Arctic Increased from 2009 through 2019 with a Range of Vessel Types Represented U.S. Coast Guard data indicate the number of vessels in the U.S. Arctic increased from 2009 through 2019 (see fig. 3). The types of vessels the U.S. Coast Guard tracks in the U.S. Arctic includes vessels conducting marine scientific research; tugs that provide communities with supplies; and adventurer vessels such as private yachts. U.S. Coast Guard data also include bulk cargo vessels from the Red Dog mine, one of the largest zinc mines in the world. The mine trucks its zinc ore to a facility on the Chukchi Sea, where it is stored for maritime transport during the shipping season. The U.S. Coast Guard District responsible for the U.S. Arctic counts more types of vessels in its area of interest—such as research, tug, and adventurer—than are typically counted for the purposes of tracking commercial shipping. Even at its peak, maritime shipping in the U.S. Arctic remained limited compared to global commercial shipping, although CMTS recently reported that the number of flag states, or countries where vessels are registered, has increased. Specifically, the 307 vessels in the U.S. Arctic in 2019 represented a small portion of the total number of shipping vessels operating globally. For comparison, according to the United Nations Conference on Trade and Development, in 2015 the world fleet of commercial shipping vessels was approximately 89,000. However, in its 2019 traffic projections report, CMTS analyzed U.S. Coast Guard data and other data sources and found that between January 2015 and December 2017, the number of flag states in the U.S. Arctic increased. CMTS noted this indicates a shift away from regionally focused operators toward a more diverse and international set of operators. CMTS found that the majority of vessels were flagged to the United States (about 41 percent) or Russia (about 24 percent) over this time period, with the remaining 35 percent from 35 other flag states, each with a considerably smaller percentage than the United States or Russia. Given that a single vessel can make multiple trips per shipping season, U.S. Coast Guard also measures maritime activity by the number of transits that vessels make per year through the Bering Strait, a key convergence point for trans-Arctic routes that connects the NWP and NSR to the Pacific Ocean. According to U.S. Coast Guard data, the number of transits through the Bering Strait has ranged from as few as 280 in 2009, to as many as 514 in 2015 (see fig. 4). There were far fewer transits through the Bering Strait than through some other convergence points for established major maritime transportation routes that have more developed maritime infrastructure. For example, the number of transits through the Panama Canal, which like the NWP connects the Atlantic and Pacific Oceans, was almost 14,000 in 2018 and the number of vessels that transited the Suez Canal, which like the NSR enables shipping between Asia and Europe, was over 18,000. Factors Affecting Arctic Maritime Shipping Included Changes in Domestic and International Demand and Unpredictable Conditions Stakeholders told us that along with factors such as demand that shape shipping trends worldwide, factors unique to the Arctic also play a role, such as potential cost savings due to shorter routes; additional operating costs incurred by Arctic-capable ships; environmental hazards like unpredictable weather and sea ice; and a lack of maritime infrastructure typically found along shipping routes. The 20 stakeholders we interviewed representing the shipping industry, research institutions, and state, local, and Alaska Native groups among others, described the following factors that affect U.S. Arctic maritime shipping. Domestic and International Demand As mentioned earlier, diminished sea ice has presented opportunities for maritime shipping of natural resources extracted from the Arctic, such as oil, gas, and minerals. However, such activities decreased domestically after Royal Dutch Shell, PLC (Shell) discontinued its offshore oil and gas exploration of the Burger prospect in Alaska’s Chukchi Sea in 2015. As shown in figure 4, the number of transits in the Bering Strait steadily declined from 514 in 2015 to 369 in 2018. Specifically, CMTS reported that Shell demobilized its drill ship, anchor handling vessels, and anti- pollution ships from the study area prior to the start of the 2016 shipping season. One stakeholder said there was a reduction in the number of seasonal transits after Shell suspended exploration activities, since Shell had previously accounted for more than a hundred transits through the Bering Strait. Other traffic related to domestic natural resource extraction stayed at consistent levels. Specifically, representatives from the Red Dog zinc mine reported that from 1999 to 2019 they consistently shipped between 21 and 26 cargo vessels per year, averaging 24 vessels per year over the 20-year period. Meanwhile, several stakeholders said international activities related to natural resource development, particularly in the Russian Arctic, have recently increased, and that Russia has been investing heavily in Arctic infrastructure. The U.S. Coast Guard attributed increased cargo traffic levels in 2016 to construction projects in the Russian Arctic, particularly a liquefied natural gas (LNG) facility on the Yamal peninsula (see fig. 3 above). In 2017, a Russian LNG tanker, the Christophe de Margerie, became the first ship to transit the NSR without being accompanied by an icebreaker. Demand for tourism cruises in the U.S. Arctic has increased slightly recently. A representative from an Arctic cruise industry association told us that the overall cruise industry worldwide grows 5 to 10 percent a year and that there is growing demand for expedition cruises to farther-flung areas like the Arctic. In both 2016 and 2017, the cruise ship Crystal Serenity transited the NWP with over a thousand passengers on board. Stakeholders noted that cruise ship voyages in the U.S. Arctic, such as the Crystal Serenity voyages, raised concerns for passenger safety given the lack of infrastructure, particularly for search and rescue. However, according to an Arctic cruise industry association representative, the number of smaller ships purpose-built for Arctic conditions is growing; the association estimates 25 to 30 such vessels are under construction. Domestic and foreign research vessels have also increased in number in the U.S. Arctic due to greater interest in the region’s changing environment. For example, according to National Science Foundation officials, their polar-capable vessel Sikuliaq entered service in 2016. Internationally, China has increased its activity in the Arctic since gaining observer status on the Arctic Council in 2013 and now operates two icebreaking research vessels. One stakeholder said that such investments by countries such as China may be the first step towards achieving longer-term economic goals for those countries. Cost of Operations Trans-Arctic routes can reduce travel time between certain destinations compared to traditional routes and may therefore reduce fuel and labor costs. For example, the route from Shanghai, China, to Northwestern Europe via the NSR is 27 percent shorter than via the Suez Canal. The operators of the Russian LNG tanker that transited the NSR in 2017, the Christophe de Margerie, reported they completed the journey in 19 days, 30 percent faster than the Suez Canal. For reasons such as these, according to news reports, Russia has announced plans to develop the NSR and ship 80 million tons of goods through the route by 2024. Similarly, an official from a Canadian ship owner and operator told us that, depending on the vessel’s origin and destination, using the NWP can be 10-15 days faster than using the Panama Canal, resulting in a cost savings of $100,000 to $150,000. Although trans-Arctic routes have the potential for cost savings due to shorter distances, they require additional investments not necessary for traditional routes that may offset those savings. For example, representatives of one carrier said Arctic-capable ships cost three to four times more than ordinary ships because they require more steel and higher power output to withstand ice conditions. The additional steel also limits the amount of cargo the vessel can carry; representatives from another carrier noted every ton of steel used to construct the ship is a ton of cargo that the ship cannot carry in order to recoup expenses. The size of vessels that can safely operate in the region is also constrained by draft limitations that specify the maximum weight and size at which ships can navigate the shallow waters of the Arctic. By contrast, the trend among ocean carriers over the past decades, which have capitalized on advances in fuel-efficient engine technology, is toward constructing increasingly larger vessels to capture economies of scale. In addition, stakeholders told us that shippers operating in the Arctic must invest in special onboard equipment and prepare for contingencies due to the lack of maritime infrastructure usually found in traditional routes, such as deep-draft ports, harbors of refuge, reliable communications, and search and rescue infrastructure. Stakeholders noted Arctic voyages also require additional training for crew members on navigating in ice conditions. Shippers must determine whether the cost savings obtained from shorter trans-Arctic routes outweigh the additional operating expenses. For example, although Maersk, one of the largest shipping companies in the world, successfully completed a trial passage of a container ship through the NSR in September 2018, the company emphasized at the time that the transit was a “one-off trial designed to gain operational experience in a new area and to test vessel systems” and that it did not view the route as a commercially viable alternative to existing routes. In a press release, Maersk noted that the NSR was only feasible for around 3 months a year and required the use of more costly ice-classed vessels. Despite this, news reports in June 2019 indicate Maersk is exploring sending more goods through the NSR in cooperation with a Russian icebreaker company in response to demand for the transport of goods from Asia to West Russia. Unpredictable Conditions and Lack of Infrastructure Although diminished sea ice has prolonged the shipping season and opened up shipping routes, environmental changes have also resulted in less predictable conditions, such as more volatile weather and sea ice. One stakeholder involved with Arctic research noted that the conditions that have led to open waters can also lead to harsher conditions such as strong low pressure systems, gale force winds, and storms. Such conditions pose challenges for shipping—one shipper representative said that it is difficult to load barges in shallow waters and that typically loading and unloading activities have to be suspended with swells above 3 feet. In addition, stakeholders told us variation in ice conditions from year to year makes planning Arctic voyages difficult to do with reasonable accuracy. For example, while warming trends might suggest that overall sea ice diminishes further each year, one carrier representative noted its vessel encountered severe ice conditions in June 2018. This representative noted that diminished overall ice coverage can lead to localized conditions with more mobile and older ice migrating into shipping lanes. The unpredictable and harsh weather and ice conditions, combined with the vast distances and lack of maritime infrastructure, pose safety risks. For example, according to stakeholders, the “tyranny of distance” in the Arctic stretches the limited search and rescue capabilities, resulting in slow incidence response. Furthermore, a lack of a designated harbor of refuge means vessels do not have a place to moor safely in case of emergency. As a result, a representative from the International Union of Marine Insurance noted that in the Arctic even a minor incident, such as a small engine failure, can result in substantial damages and even loss of life. Environmental Concerns Some stakeholders we interviewed expressed concerns about impacts of shipping on wildlife, including the species that Alaska Natives rely on for food. One stakeholder noted that awareness has grown in the past 10 years of the environmental impact of shipping. Such impacts include emissions containing sulphur oxide and black carbon from ships’ engines that could damage the fragile Arctic ecosystem. As a result of such environmental concerns, the IMO is currently considering a ban on heavy fuel oil in the Arctic. In addition, in 2019 several major carriers, including CMA CGM, Hapag-Lloyd, and Mediterranean Shipping Company, announced they would not pursue trans-Arctic shipping. Furthermore, in 2019 Nike and Ocean Conservancy launched the Arctic Corporate Shipping Pledge, a voluntary commitment by consumer goods and shipping logistics companies to not send ships through the Arctic. The pledge also supports precautionary Arctic shipping practices to enhance the environment and human safety, which may include a heavy fuel oil ban and an evaluation of low impact shipping corridors that protect important ecological and cultural areas. A representative of one carrier we spoke with said a heavy fuel oil ban in the Arctic could increase the cost of transporting cargo and, as a result, severely impact shipping in the region. Agencies Have Taken Some Steps to Address Gaps in Maritime Infrastructure in the U.S. Arctic, but Federal Efforts Lack a Current Strategy and Consistent Leadership While agencies have taken actions to address maritime infrastructure gaps, federal efforts lack (1) a government-wide assessment of risks posed by gaps in maritime infrastructure, (2) a current government-wide strategy for addressing maritime infrastructure that includes goals, performance measures, and appropriate responses to prioritized risks, and (3) an interagency mechanism and consistent leadership to guide agency actions related to maritime infrastructure. Without these elements, federal agencies may lack information on which to base decisions and prioritize actions, assurance that their investments are directed to prioritized risks, and the ability to demonstrate progress in addressing maritime infrastructure. Furthermore, agencies may miss opportunities to work together and leverage resources towards achieving broader outcomes. Agencies Have Taken Actions to Address Navigation and Other Gaps in U.S. Arctic Infrastructure Agencies have taken some actions since 2013, when CMTS first reported on gaps in U.S. Arctic infrastructure. For example, U.S. Coast Guard reported that it has taken a flexible approach to addressing infrastructure gaps by establishing seasonal, forward operating bases in the U.S. Arctic as needed to provide search and rescue support in areas where major shipping activity is occurring. See table 3 for selected examples of agency actions. Federal Efforts Lack a Government-wide Risk Assessment to Inform Decisions in the U.S. Arctic Although federal agencies have taken some steps to address gaps in U.S. Arctic infrastructure, those efforts are not based on a government- wide assessment of the economic, environmental, and safety risks posed by maritime infrastructure gaps to inform investment decisions in the U.S. Arctic. Rather, agency officials said that they currently base Arctic infrastructure decisions on their agency-specific missions, strategies, and collaborative efforts. Specifically, agency officials said that securing the resources to address U.S. Arctic infrastructure is challenging because such projects must compete with other established agency mission areas. For example, officials told us that infrastructure investments may not compete as well against other agency-established priorities in other parts of the country, in part, because the Arctic is an emerging region and because of the considerable costs of developing infrastructure in the harsh Arctic environment. Leading management practices we reviewed note the importance of assessing risks in order to select and prioritize countermeasures to prevent or mitigate risks. A 2016 Office of Management and Budget (OMB) circular emphasized the importance of risk assessment and called for agencies to use a structured and systematic approach to identify risks and assess the causes, sources, probability of the risk occurring, and potential outcomes, and then prioritize the results of the analysis. Such an approach can be used by decision makers to evaluate the effectiveness of, and to prioritize, countermeasures relative to the associated costs. Risk management is a widely endorsed strategy for helping policymakers make decisions about allocating finite resources and taking actions in conditions of uncertainty. Such a framework is especially applicable to the U.S. Arctic given the uncertain conditions in the region and safety and environmental risks described above. Without a risk assessment, agencies lack assurance that their investments are addressing the highest-priority risks. In particular, we found that agencies’ actions to address maritime infrastructure gaps were not fully consistent with the areas that the stakeholders we interviewed identified as the most critical (see fig. 5). For example, 11 of the 20 stakeholders we interviewed identified charting Arctic waters as the highest priority to address, and in May 2019 NOAA reported that it had acquired nearly 1,500 square nautical miles of hydrographic survey data in the Arctic over the prior 3 years. This is, however, less than 1 percent of the over 200,000 square nautical miles of waters NOAA has identified as significant to navigation in the U.S. Arctic. In addition, nine stakeholders identified addressing gaps in communications in the U.S. Arctic as a key priority. However, CMTS reports indicate no change in the status of communications capabilities in the U.S. Arctic between 2013 and 2018. CMTS has in the past noted the importance of conducting a risk assessment to inform Arctic decision-making. Specifically, CMTS’s 2013 report noted that greater access to the U.S. Arctic and increased activity presents additional risks for people, vessels, and the environment in the fragile region and that managing that risk requires an in-depth understanding of the issues and trade-offs associated with key decisions. Although CMTS reported that developing an assessment tool that provides a quantifiable level of risk and that accounts for the unique risk elements in the Arctic was a challenge for the nation, it proposed a model for determining risk that considered the likelihood of adverse events actually occurring, vulnerability to damage, and potential consequences. CMTS further stated that, given the rate at which other nations are progressing with Arctic shipping and development, the United States should decide the acceptable degree of risk for Arctic operations. Although CMTS has provided useful information on maritime infrastructure gaps to decision makers and described possible risks to the U.S. Arctic, it has not systematically assessed the risks posed by these gaps. For example, in 2016, CMTS made near-, mid-, and long-term recommendations for addressing maritime infrastructure needs, but noted this ordering was not intended to create a hierarchy of infrastructure needs from most to least important. CMTS officials told us that they have not systematically assessed risks posed by maritime infrastructure gaps in the U.S. Arctic because CMTS’s priorities are established by its member agencies, and that CMTS has not been directed to conduct such an assessment by its members. However, CMTS is required by statute to, among other things, coordinate the establishment of domestic transportation policies in the Arctic to ensure safe and secure maritime shipping and make recommendations with regard to federal policies that impact the marine transportation system. Furthermore, according to CMTS officials, there is nothing in CMTS’s authority that would prevent it from doing a risk assessment. Given its previous reports and work in the U.S. Arctic and its coordinating role with its member agencies, CMTS is well suited to conduct a government-wide assessment of the risks posed by gaps in maritime infrastructure in the U.S. Arctic. For example, CMTS published a traffic projections report in September 2019 that aimed to provide decision makers with a wide-ranging portrait of potential changes in vessel activity in the U.S. Arctic over the next decade. To inform its risk assessment, CMTS can draw on the expertise of its member agencies, such as U.S. Coast Guard and NOAA. For example, U.S. Coast Guard officials told us that they have responded to the unpredictable economic changes in the U.S Arctic—including fluctuations in the level and type of maritime activity in the region—by investing in icebreakers and seasonal forward operating bases, rather than developing permanent infrastructure. In addition, CMTS can also draw on numerous reports discussing maritime infrastructure in the U.S. Arctic that have been published since 2013, as detailed in appendix I. For example, in 2019 the University of Alaska’s Arctic Domain Awareness Center held a series of workshops on the factors that impact the ability of the U.S. Coast Guard and other stakeholders to conduct safe, secure, and effective operations in the Arctic environment. A government-wide risk assessment could better enable agencies to evaluate potential U.S. Arctic infrastructure expenditures and assess the extent to which these expenditures will mitigate identified risks. For example, a report on the U.S. Coast Guard’s Arctic capabilities suggested that a systematic analysis of needs and risks in the U.S. Arctic could help the agency generate momentum for closing Arctic capability gaps. By conducting such a risk assessment, agencies would have better information on which to base decisions for agency expenditures in the U.S. Arctic and prioritize appropriate actions in response to risks. Federal Interagency Efforts Lack a Current Strategy and Consistent Interagency Leadership to Guide Agency Actions Related to Maritime Infrastructure We found that the federal interagency efforts to address U.S. Arctic maritime infrastructure lack a current strategy and consistent interagency leadership to guide agencies’ actions. Although several agencies have developed strategies to guide their own agencies’ efforts, these do not provide government-wide direction or establish current government-wide goals, objectives, and performance measures as leading management practices call for. Moreover, the federal agencies lack clarity on which interagency entity is responsible for guiding federal efforts and providing consistent leadership to ensure government-wide objectives are met. Current Strategy The federal government lacks a current government-wide strategy for addressing U.S. Arctic maritime infrastructure gaps that includes key characteristics, such as goals, objectives, and performance measures, and appropriate responses to risks. Agency officials and stakeholders said the 2013 National Strategy is outdated because conditions in the U.S. Arctic have changed since 2013. In particular, agency officials said national security is a growing concern in the Arctic. OSTP officials agreed that conditions had changed in the Arctic, but could not state whether the 2013 National Strategy was still current. Our past work on interagency collaboration found that written agreements documenting how participating agencies collaborate, such as strategies, are most effective when they are regularly updated and monitored. The changing conditions in the Arctic described above make a current government-wide strategy for maritime infrastructure in the U.S. Arctic particularly important. In our past work, we have reported that complex interagency efforts— such as those to address maritime infrastructure in the U.S. Arctic—can benefit from developing a national strategy. Our prior work has identified key characteristics of national strategies, which we refer to in this report as a government-wide strategy, including: (1) problem definition and risk assessment which addresses the threats the strategy is directed towards; and (2) goals, objectives, and performance measures to gauge and monitor results. Furthermore, our prior enterprise risk management work has noted that risk assessment should include a ranking of risks based on priorities in relation to strategic objectives, and that senior leaders should determine if a risk requires treatment or not based on risk tolerance or appetite. Leaders then review the prioritized list of risks and select the most appropriate response to address the risk. These key characteristics help managers determine the extent of investment needed and facilitate effective targeting of federal resources; this is especially important when multiple agencies are involved, as is the case with maritime infrastructure in the U.S. Arctic. Although several federal agencies have recently updated their Arctic strategies, these agency-specific Arctic strategies are not linked to a current government-wide strategy for the Arctic region and are not specifically focused on addressing Arctic maritime infrastructure gaps. Specifically: U.S. Coast Guard. In April 2019, U.S. Coast Guard published its Arctic Strategic Outlook, which supersedes its 2013 Arctic Strategy. The updated strategy established three lines of effort: (1) enhance capability to operate effectively in a dynamic Arctic domain, (2) strengthen the rules-based order, and (3) innovate and adapt to promote resilience and prosperity. We recommended in 2016 that the U.S. Coast Guard develop measures for assessing how its actions have helped to mitigate Arctic capability gaps and design and implement a process to systematically assess its progress. However, as of February 2020, the U.S. Coast Guard has not implemented these recommendations. U.S. Coast Guard officials state that they are currently developing an implementation plan and Strategic Metrics Framework for the Arctic Strategic Outlook. U.S. Navy. In January 2019, the U.S. Navy published its Arctic strategy, which updated its previous strategy from 2014. The updated strategy included the following strategic objectives: defend U.S. sovereignty and the homeland from attack; ensure the Arctic remains a stable, conflict-free region; preserve freedom of the seas; and promote partnerships to achieve the above objectives. Department of Defense. In June 2019, Department of Defense updated its 2016 Arctic strategy which included the following as part of its approach: (1) building Arctic awareness, (2) enhancing Arctic operations, and (3) strengthening the rules-based order in the Arctic. NOAA. NOAA officials originally told us that they were working to complete an update to NOAA’s strategic plan for the Arctic in 2019. However, as of February 2020, officials told us that this update is currently on hold pending the completion of a new government-wide National Strategy. As mentioned previously, OSTP staff said they could not state whether the 2013 National Strategy was still current, and OSTP provided no additional information as to whether a new strategy was in development. NOAA officials told us that the agency’s current three priorities in the Arctic are (1) weather and water (including weather and water research, observations, and Arctic contributions to global weather monitoring); (2) blue economy (including ocean mapping, seafood competitiveness, tourism, and coastal resilience); and (3) innovative partnerships in Alaska and the Arctic. CMTS has taken some steps to monitor agencies’ progress in addressing maritime infrastructure, but the current lack of performance measures makes it difficult to monitor agencies’ progress over time. We reported in 2014 that CMTS was developing a process to monitor such progress and noted that such monitoring would help agencies develop a shared understanding of current priorities and actions needed. However, while CMTS did issue reports that described the status of maritime infrastructure in the U.S. Arctic in 2016 and 2018, the reports did not include goals or performance measures to assess agencies’ progress. According to officials, CMTS did not develop or include performance measures to monitor agencies’ progress because it does not have the authority to designate agencies’ priorities, and that agencies are best situated to identify priorities in pursuit of their individual missions. Priorities in the U.S. Arctic are currently based on each agency’s mission, which makes it difficult to take a government-wide approach to responding to risks. To improve unity of effort, the U.S. Coast Guard has expressed support for a national approach to Arctic planning in both its 2013 and 2019 Arctic strategies. Without a current government-wide strategy that includes goals and objectives, agencies lack assurance that their investments are directed to prioritized risks. Furthermore, without performance measures, agencies are not able to demonstrate, and decision makers are unable to monitor, the extent to which agency actions have addressed maritime infrastructure gaps. Interagency Leadership We have previously reported that federal agencies use a variety of mechanisms, including interagency groups, to implement interagency collaborative efforts and that such mechanisms benefit from key features such as sustained leadership and inclusion of all relevant participants, such as stakeholders. We also reported that leadership should be sustained over time to provide continuity for long-term efforts and that having top-level commitment from the President, Congress, or other high- level officials can strengthen the effectiveness of interagency collaborative groups. We also found that lack of continuity is a frequent issue with interagency mechanisms that are tied to the Executive Office of the President, particularly when administrations change, and that transitions and inconsistent leadership can weaken a collaborative mechanism’s effectiveness. In addition, our prior work has noted the importance of ensuring that all relevant participants are included in the collaborative effort, such as participants with the appropriate knowledge, skills, and abilities to contribute. There are many interagency groups involved in the U.S. Arctic, including: AESC was established by Executive Order in 2015 to shape national priorities and set strategic direction in the Arctic. NSC Arctic Policy Coordinating Committee (PCC) is the current interagency forum for executive-level Arctic collaboration, according to agency officials. CMTS is the main forum for collaboration regarding maritime infrastructure according to agency officials. These interagency groups vary in the extent to which they meet the key features noted above. Specifically: Sustained leadership: Both the NSC, which, as mentioned previously, has traditionally played a role in Arctic collaboration dating back to 1971, and the AESC, which was chaired by the OSTP within the White House, would have top-level commitment given their proximity to the White House. However, according to agency officials, the AESC has not met in the past 2 years and is now dormant. OSTP staff told us that they are not aware of any current AESC activities. Meanwhile, although CMTS has been active in the area of U.S. Arctic maritime infrastructure for the past decade, CMTS officials said CMTS does not sit within the Executive Office of the President. As a result, CMTS officials note their role is to facilitate an interagency partnership, share information among member agencies, and provide information to decision-makers to support agencies’ efforts. CMTS’s statutory authority addresses, among other things, the coordination of federal policies that impact the maritime transportation system, including in the U.S. Arctic, rather than the development and execution of government-wide policies. Inclusion of relevant stakeholders: The AESC, when it was active, included a wide range of over 20 federal departments and entities, including those less associated with maritime infrastructure such as the Department of Agriculture. For the NSC Arctic PCC, we were unable to verify the participants, so it is unclear whether relevant stakeholders are involved. However, agency officials noted the PCC’s focus is on national security rather than on maritime infrastructure, which may indicate not all maritime infrastructure stakeholders are included. Lastly, CMTS includes stakeholders involved directly with maritime transportation. For example, officials from the U.S. Army Corps of Engineers noted that they actively participate in CMTS, including its Arctic Integrated Action Team, but do not participate in other interagency groups, where they are often represented by higher- level Department of Defense officials. The Executive Office of the President has not designated an interagency group as responsible for developing or executing the administration’s strategy for maritime infrastructure in the U.S. Arctic. We have previously reported that interagency efforts can benefit from the leadership of a single entity to provide assurance that federal programs are well coordinated and based upon a coherent strategy. Agency officials said priorities in the U.S. Arctic have shifted to national security under the current administration, which may have led executive-level interagency collaboration efforts to move from AESC to the NSC Arctic PCC. However, it is unclear whether the NSC Arctic PCC includes the relevant stakeholders. Moreover, the shift in Arctic priorities to security issues does not diminish the importance of Arctic maritime infrastructure. As indicated in the 2013 National Strategy, maritime shipping and infrastructure are a key component of overarching goals in the region like advancing U.S. security interests, pursuing responsible stewardship, and strengthening international cooperation. Without an interagency mechanism with sustained leadership and inclusion of relevant stakeholders to direct federal efforts related to U.S. Arctic maritime infrastructure, agencies may miss opportunities to leverage resources toward achieving a broader outcome. For example, as noted earlier, stakeholders we spoke to identified communications as a key infrastructure gap. According to U.S. Coast Guard officials, communications is a whole-of-government effort, requiring partnerships across agencies including the Department of Defense. Without an interagency collaboration mechanism designated to lead these efforts, it is unclear who has responsibility for such whole-of-government efforts to address maritime infrastructure in the U.S. Arctic. Conclusions The U.S. Arctic, including the Bering Strait, is an essential part of the increasingly navigable Arctic and a key convergence point for maritime transportation routes connecting the Pacific and Atlantic oceans. The risks inherent to Arctic shipping—including vast distances, extreme ice conditions, and unpredictable weather—are exacerbated by gaps in maritime infrastructure in the U.S. Arctic. While agencies have taken some actions to address these gaps, without a government-wide assessment of risks posed by maritime infrastructure gaps in the U.S. Arctic and a current strategy to address those risks, agencies lack assurance that their actions are effectively targeting priority areas. Without a strategy that includes goals, objectives, and performance measures, agencies cannot demonstrate the results of their efforts, and decision makers cannot gauge the extent of progress in addressing maritime infrastructure gaps. In addition, without a designated interagency group to provide sustained leadership, agencies lack the ability to leverage resources to address maritime infrastructure and achieve government-wide priorities in the complex and changing U.S. Arctic. Recommendations for Executive Action The U.S. Committee on the Marine Transportation System should: Complete a government-wide assessment of the economic, environmental, and safety risks posed by gaps in maritime infrastructure in the U.S. Arctic to inform investment priorities and decisions. (Recommendation 1) The appropriate entities within the Executive Office of the President, including the Office of Science and Technology Policy should: Develop and publish a strategy for addressing U.S. Arctic maritime infrastructure that identifies goals and objectives, performance measures to monitor agencies’ progress over time, and the appropriate responses to address risks. (Recommendation 2) Designate the interagency group responsible for leading and coordinating federal efforts to address maritime infrastructure in the U.S. Arctic that includes all relevant stakeholders. (Recommendation 3) Agency Comments and Our Evaluation We provided a draft of this report to the Executive Office of the President’s Office of Science and Technology Policy (OSTP); the U.S. Committee on the Marine Transportation System (CMTS); and the Departments of Homeland Security, Commerce, Defense, Interior, State, and Transportation for comment. With the exception of the Department of Defense, all of these entities provided technical comments, which we incorporated as appropriate. Only CMTS provided written comments, which were transmitted via letter from the Department of Transportation, and are reprinted in appendix II. In its technical comments, the Department of Homeland Security’s U.S. Coast Guard provided Arctic traffic data for the 2019 shipping season. As stated in our report, we originally selected the decade of 2009 through 2018 for our analysis when designing our review, as 2018 was the most recent year for which data were available at that time. In response to the U.S. Coast Guard’s comments submitted in April 2020, we revised our report to include data from the 2019 shipping season on (1) the number of vessels in the U.S. Coast Guard District 17 Arctic area of interest and (2) the number of transits in the Bering Strait, to ensure the report contained the most current information available. In its written comments, CMTS partially concurred with our recommendation that CMTS complete a government-wide assessment of the economic, environmental, and safety risks posed by gaps in maritime infrastructure in the U.S. Arctic to inform investment priorities and decisions. However, CMTS also noted several areas of disagreement with our conclusions, which we address here: First, CMTS noted that GAO’s draft report contained dated information and that the 2019 data contradicts GAO statements that suggest a decrease in vessel activity since 2015. CMTS noted that the 2019 data shows that vessel traffic has increased steadily over the last decade, and that although growth slowed between 2015 and 2017, “it did not stall.” However, we dispute this characterization. The 2019 shipping data included in this report emphasizes the finding from our draft report that maritime shipping activity generally increased over the time period of our review. However, this trend does not reflect a steady increase throughout the entire timeframe or “slowed growth” between 2015 and 2017 as CMTS indicates. Specifically, the data show year-to-year decreases in the number of vessels from 2015 to 2017 in the U.S. Coast Guard District 17 Arctic area of interest (see fig. 3) and in the number of transits in the Bering Strait from 2015 to 2018 (see fig. 4). CMTS’s own 2019 report indicated that the number of vessels had decreased from a peak in 2015, after Shell’s decision in 2015 to not pursue further exploratory drilling efforts. As such, we stand by our description of the overall growth in maritime activity in the U.S. Arctic since 2009, as well as the pattern of declining traffic within that period from 2015 through 2018. Second, CMTS also noted in its written comments that our use of data from 2009 to 2018 in the draft report do not lead to the conclusions and recommendation to assess infrastructure risks and prioritize future investment in the Arctic. We dispute this characterization. Our decision to include the 2019 data further emphasizes the finding in our draft report of a general increase in maritime activity in the U.S. Arctic and the need for an assessment of risks posed by gaps in maritime infrastructure. As we note in the report, CMTS has reported that the U.S. Arctic does not have the typical elements of a maritime infrastructure system such as a deep- draft port or robust communications infrastructure. These infrastructure gaps exacerbate the inherent challenges of maritime activity in the Arctic—vast distances, dangerous weather, and extreme ice conditions— that can pose safety risks to mariners and environmental risks to the fragile Arctic ecosystem. While agencies have taken some steps to address infrastructure gaps, without a risk assessment, agencies lack assurance that their investments are addressing the highest-priority risks. As such, we stand by our conclusion and recommendation that increasing maritime traffic poses risks, and a government-wide assessment of those risks would inform federal decisions on investments to appropriately address risks. Third, CMTS disagreed with GAO’s statement that a government-wide risk assessment could better enable agencies to evaluate potential U.S. Arctic infrastructure expenditures. Although CMTS agreed that understanding infrastructure gaps is critical to improving the Arctic marine transportation system, CMTS contends that such risk assessments are the responsibility of each agency as directed by the Office of Management and Budget (OMB). As we note in the report, many agencies have a role in U.S. Arctic maritime shipping and infrastructure and although agencies and others have conducted many reviews of maritime infrastructure in the U.S. Arctic (see appendix I), agency-by- agency assessments do not reflect or analyze risks from a government- wide perspective. CMTS itself has previously noted the importance of evaluating risks on a government-wide basis. Specifically, in 2013 CMTS noted that increased activity in the U.S. Arctic presents additional risks for the people, vessels, and the environment and that managing that risk requires an in-depth understanding of the issues and trade-offs associated with key decisions, such as how to prioritize investments. As our report states, CMTS stated that developing a tool to assess the unique risk elements in the Arctic was a challenge for the nation, and it proposed a model for determining risk that considered the likelihood of adverse events actually occurring, vulnerability to damage, and potential consequences. This model is similar to the 2016 OMB circular, which called for agencies to, among other things, assess the causes, sources, probability of the risk occurring, and potential outcomes. As stated in our report, given its previous work in the U.S. Arctic and its coordinating role with its member agencies, CMTS is well suited to conduct a government-wide assessment of the risks posed by gaps in maritime infrastructure in the U.S. Arctic. As such, we stand by our recommendation. Based on these items, CMTS did not agree to perform and lead a government-wide risk assessment. Instead, as an “alternate action” to address GAO’s recommendation, CMTS noted it plans to update a table of information published in its past reports on infrastructure gaps in the U.S. Arctic and provide an inventory of existing risk assessments and their criteria, which agencies can then use to improve their own assessments to inform decisions. In our view, the proposed action described by CMTS would not provide the same level of information proposed by CMTS itself in 2013 and by OMB’s 2016 circular, which calls for, among other things, assessing the causes, sources, probability of the risk occurring, and potential outcomes. As stated in our report, CMTS is uniquely positioned as a federal interagency coordinating committee focused on the maritime transportation system to draw on the expertise of its member agencies, such as U.S. Coast Guard and the National Oceanic and Atmospheric Administration, to complete this risk assessment. Moreover, CMTS is required by statue to coordinate the establishment of domestic transportation policies in the Arctic to ensure safe and secure maritime shipping and make recommendations with regard to federal policies that impact the marine transportation system. Furthermore, according to CMTS officials, there is nothing in CMTS’s authority that would prevent it from doing a risk assessment. As such, we stand by our recommendation as written and do not believe CMTS’s alternate action is sufficient to address the recommendation. In comments provided via email, OSTP neither agreed nor disagreed with the report’s recommendations. OSTP acknowledged the Arctic is of critical national importance and noted interagency coordination can be implemented through the entities of the National Science and Technology Council, which is located within OSTP. OSTP noted the need for, and role of additional federal coordination, such as the Arctic Executive Steering Committee, is under consideration by OSTP. We continue to believe that the appropriate entities within the Executive Office of the President, including OSTP, should designate the interagency group responsible for leading and coordinating federal efforts to address maritime infrastructure in the U.S. Arctic that includes all relevant stakeholders. As we note in our report, without an interagency collaboration mechanism designated to lead these efforts, it is unclear who has responsibility for whole-of- government efforts to address U.S. Arctic maritime infrastructure. In addition, we stand by our other recommendation to OSTP and other entities within the Executive Office of the President to develop and publish a strategy for addressing U.S. Arctic maritime infrastructure that identifies goals and objectives, performance measures to monitor agencies’ progress over time, and the appropriate responses to address risks. As we note in the report, without such a strategy agencies lack assurance that their actions are effectively targeting priority areas and decision makers cannot gauge the extent of progress in addressing maritime infrastructure gaps. We are sending copies of this report to the appropriate congressional committees; the Executive Office of the President; the U.S. Committee on the Marine Transportation System; the Secretaries of Homeland Security, Commerce, Defense, Interior, State, and Transportation; and other interested parties. In addition, this report is available at no charge on the GAO website at http://www.gao.gov. If you or your staff have any questions about this report, please contact me at (202) 512-2834 or vonaha@gao.gov. Contact points for our Office of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III. Appendix I: Reports Relevant to Maritime Infrastructure in the U.S. Arctic Published Since 2013 National Ocean Council. National Ocean Policy Implementation Plan. Washington, D.C.: April 2013. White House. National Strategy for the Arctic Region. Washington, D.C.: May 10, 2013. U.S. Coast Guard. United States Coast Guard Arctic Strategy. Washington, D.C.: May 2013. U.S. Committee on the Marine Transportation System. U.S. Arctic Marine Transportation System: Overview and Priorities for Action. Washington, D.C.: 2013. The White House. Implementation Plan for the National Strategy for the Arctic Region. Washington, D.C.: January 30, 2014. U.S. Navy. The United States Navy Arctic Roadmap for 2014 to 2030. Washington, D.C.: February 2014. GAO. Maritime Infrastructure: Key Issues Related to Commercial Activity in the U.S. Arctic over the Next Decade. GAO-14-299. Washington, D.C.: March 19, 2014. U.S. Department of Commerce. National Oceanic and Atmospheric Administration. NOAA’s Arctic Action Plan: Supporting the National Strategy for the Arctic Region. Silver Spring, M.D: April 2014. GAO. Arctic Issues: Better Direction and Management of Voluntary Recommendations Could Enhance U.S. Arctic Council Participation. GAO-14-435. Washington, D.C.: May 16, 2014. Brigham, L. W. Alaska and the New Maritime Arctic Executive Summary: Executive Summary of a Project Report to the State of Alaska Department of Commerce, Community and Economic Development. Fairbanks, A.K.: February 1, 2015. The International Council on Clean Transportation. A 10-Year Projection of Maritime Activity in the U.S. Arctic Region. Washington, D.C.: January 2015. This report was contracted and coordinated under the U.S. Committee on the Marine Transportation System. Executive Order No. 13689. Enhancing Coordination of National Efforts in the Arctic. 80 Fed. Reg. 4191. January 26, 2015. The White House. Arctic Executive Steering Committee. National Strategy for the Arctic Region Implementation Report. Washington, D.C.: January 30, 2015. Alaska Arctic Policy Commission. Final Report of the Alaska Arctic Policy Commission. Anchorage and Bethel, A.K.: January 30, 2015. U.S. Army Corps of Engineers. Alaska District. Alaska Deep-Draft Arctic Port System Study: Draft Integrated Feasibility Report, Draft Environmental Assessment (EA), and Draft Finding of No Significant Impact (FONSI). Nome, AK: February 2015. GAO. Arctic Planning: DOD Expects to Play a Supporting Role to Other Federal Agencies and Has Efforts Under Way to Address Capability Needs and Update Plans. GAO-15-566. Washington, D.C.: June 19, 2015. Arctic. Status on Implementation of the AMSA 2009 Report Recommendations. Tromsø, Norway: April 2015. World Economic Forum. Global Agenda Council on the Arctic. Arctic Investment Protocol: Guidelines for Responsible Investment in the Arctic. Geneva, Switzerland: November 2015. U.S. Coast Guard. Arctic Strategy Implementation Plan. Washington, D.C.: December 2015. Arctic Economic Council, Telecommunications Infrastructure Working Group. Arctic Broadband: Recommendations for an Interconnected Arctic. Tromsø, Norway: Winter 2016. Copenhagen Business School and Arctic Institute. Arctic Shipping: Commercial Opportunities and Challenges. CBS Maritime, January 2016. The White House. Arctic Executive Steering Committee. 2015 Year in Review: Progress Report on the Implementation of the National Strategy for the Arctic Region. Washington, D.C.: March 2016. The White House. Arctic Executive Steering Committee. 2015 Year in Review: Progress Report on the Implementation of the National Strategy for the Arctic Region; Appendix A, Implementation Framework for the National Strategy for the Arctic Region. Washington, D.C.: March 2016. U.S. Committee on the Marine Transportation System. Arctic Marine Transportation Integrated Action Team. A Ten-Year Prioritization of Infrastructure Needs in the U.S. Arctic. Washington, D.C.: April 15, 2016. GAO. Coast Guard: Arctic Strategy is Underway but Agency Could Better Assess How Its Actions Mitigate Known Arctic Capability Gaps. GAO-16-453. Washington, D.C.: June 15, 2016. Department of Defense. Report To Congress On Strategy To Protect United States National Security Interests In The Arctic Region. Washington, D.C.: December 2016. RAND Corporation. Maintaining Arctic Cooperation with Russia: Planning for Regional Change in the Far North. RR-1731-RC. Santa Monica, CA: 2017. U.S. Committee on the Marine Transportation System. Recommendations and Criteria for Using Federal Public-Private Partnerships to Support Critical U.S. Arctic Maritime Infrastructure. Washington, D.C.: January 2017. Arctic Council, Emergency Prevention, Preparedness and Response. Circumpolar Oil Spill Response Viability Analysis: Technical Report. March 7, 2017. Council of Foreign Relations. Arctic Imperatives: Reinforcing U.S. Strategy of America’s Fourth Coast, New York, N.Y.: March 2017. Ocean Conservancy. Navigating the North: An Assessment of the Environmental Risks of Arctic Vessel Traffic. Anchorage, A.K.: June 28, 2017. Center for Strategic and International Studies, Maritime Futures: The Arctic and the Bering Strait Region. Washington, D.C.: November 2017. RAND Corporation. Identifying Potential Gaps in US Coast Guard Arctic Capabilities.RR-2310-DHS. Santa Monica, CA: 2018. U.S. Committee on the Marine Transportation System. Revisiting Near- Term Recommendations to Prioritize Infrastructure Needs in the U.S. Arctic. Washington, D.C.: 2018. Department of Defense. Report to Congress on Assessment of Requirement for a Strategic Arctic Port. Washington, D.C.: January 2018. Department of Homeland Security, Office of the Chief Financial Officer. Arctic Search and Rescue: Fiscal Year 2017 Report to Congress. Washington, D.C.: March 13, 2018. International Union of Marine Insurance. IUMI Position Paper: Arctic Sailings. Hamburg, Germany: August 2018. U.S. Coast Guard Acquisition Directorate, Research & Development Center. Alaska AIS Transmit Prototype Test, Evaluation, and Transition Summary Report for the Near Shore Arctic Navigational Safety Information System (ANSIS). New London, C.T.: October 2018. GAO. Arctic Planning: Navy Report to Congress Aligns with Current Assessments of Arctic Threat Levels and Capabilities Required to Execute DOD’s Strategy. GAO-19-42. Washington, D.C.: November 8, 2018. Alaska Federation of Natives. Indigenous Engagement with Their Countries’ Military and Civilian Services/ Government on Maritime Arctic Issues. Anchorage, A.K.: December 2018. RAND Europe. The Future of Arctic Cooperation in a Changing Strategic Environment, PE-268-RC. Cambridge, United Kingdom: 2018. U.S. Navy. Strategic Outlook for the Arctic. January 2019. U.S. Coast Guard. Arctic Strategic Outlook. April 2019. Department of Defense. Office of the Secretary of Defense. Annual Report to Congress on Military and Security Developments Involving the People’s Republic of China 2019. Washington, D.C.: May 2, 2019. Pompeo, Michael, R. Secretary of State. U. S. Department of State. Looking North: Sharpening America’s Arctic Focus. Remarks. Rovaniemi, Finland, May 6, 2019. Pompeo, Michael R. Secretary of State. U.S. Department of State. Remarks. Arctic Council Ministerial Meeting. Rovaniemi, Finland, May 7, 2019. Department of Defense. Office of the Under Secretary of Defense for Policy. Report to Congress on Department of Defense Arctic Strategy. Washington, D.C.: June 2019. U.S. Committee on the Marine Transportation System. A Ten-Year Projection of Maritime Activity in the U.S. Arctic Region. 2020-2030: Washington, D.C.: September 2019. Congressional Research Service. Changes in the Arctic: Background and Issues for Congress. Washington, D.C.: November 27, 2019. U.S. Army Corps of Engineers, Alaska District. Port of Nome Modification Feasibility Study: Draft Integrated Feasibility Report and Supplemental Environmental Assessment. Nome, A.K.: December 2019. Congressional Research Service. Changes in the Arctic: Background and Issues for Congress. Washington, D.C.: January 23 2020. Appendix II: Comments from the U.S. Committee on the Marine Transportation System Appendix III: GAO Contact and Staff Acknowledgments GAO Contact Staff Acknowledgments In addition to the contact named above, Susan Fleming, Director; Matt Barranca, Assistant Director; Emily Larson, Analyst in Charge; Chuck Bausell; Geoff Hamilton; Georgeann Higgins; Ned Malone; John Mingus; Jan Montgomery; Kaleb Mount; Fatima Sharif; Curtia Taylor; Sarah Veale; and Laurel Voloder made key contributions to this report.


Background SAMHSA and other organizations recognize recovery homes—peer-run and peer-managed supportive homes—as an important step in SUD treatment and recovery. Definitions of and terms for recovery homes can vary, and recovery homes may differ in the types of services offered and resident requirements. Alcohol- and drug-free homes for individuals recovering from SUD may be referred to as “recovery residences,” “sober homes,” or other terms. For the purposes of our March 2018 report, we used the term “recovery homes” to refer to peer-run, nonclinical living environments for individuals recovering from SUD in general. Recovery homes generally are not considered to be residential treatment centers, are not eligible to be licensed providers for the purposes of billing private insurance or public programs—such as Medicaid—and residents typically have to pay rent and other home expenses themselves. Recovery home residents may separately undergo outpatient clinical SUD treatment, which is typically covered by health insurance. In addition, recovery homes may encourage residents to participate in mutual aid or self-help groups (e.g., 12-step programs such as Alcoholics Anonymous) and may require residents to submit to drug screening to verify their sobriety. Residents may be referred to recovery homes by treatment providers, the criminal justice system, or may voluntarily seek out such living environments. Nationwide Prevalence of Recovery Homes Was Unknown In our March 2018 report, we found that the prevalence of recovery homes nationwide was unknown, because complete data were not available. We found these data are not collected at the federal level to provide a nationwide picture, in part, because there was no federal agency responsible for overseeing them. However, as we reported in March 2018, two national organizations with missions dedicated to recovery homes collect data on the prevalence and characteristics for a sub-set of recovery homes and the number of homes that were not affiliated with these organizations was unknown. NARR collected data on recovery homes that sought certification by one of its 15 state affiliates that actively certify homes. As we previously reported, as of January 2018, NARR told us that its affiliates had certified almost 2,000 recovery homes, which had the capacity to provide housing to over 25,000 individuals. Oxford House, Inc. collected data on the prevalence and characteristics of its individual recovery homes (known as Oxford Houses). In its 2018 annual report, Oxford House, Inc. reported that there were 2,542 Oxford Houses in 45 states. Most Selected States Had Investigated Potential Fraud Related to Recovery Homes and Taken Steps to Enhance Oversight Four of Five Selected States Had Conducted Investigations of Recovery Homes Officials from four of the five selected states we reviewed for our March 2018 report (Florida, Massachusetts, Ohio, and Utah) told us that since 2007, state agencies had conducted, or were in the process of conducting, law enforcement investigations of unscrupulous behavior and potential insurance fraud related to recovery homes. According to the state officials, the outcomes of some of these investigations included criminal charges and changes to health insurance policies. Across the four states, officials told us that the potential insurance fraud may have relied on unscrupulous relationships between SUD treatment providers (including laboratories that perform tests to check for substance use) and recovery home operators. Officials explained that recovery home operators establish these relationships, because they cannot directly bill health insurance themselves due to the fact that recovery homes are not considered eligible providers for the purposes of billing health insurance. For example, treatment providers may form relationships with recovery home operators who then recruit individuals with SUD in order to refer or require residents to see the specific SUD treatment providers. This practice is known as patient brokering, for which recovery home operators receive kickbacks, such as cash or other remuneration from the treatment provider, in exchange for patient referrals. The extent of potential fraud differed across the four states, as discussed below. Florida Officials from several state agencies and related entities described investigations into fraud related to recovery homes in southeastern Florida as extensive, although the scope of the fraud within the industry is unknown. In 2016, the state attorney for the 15th judicial circuit (Palm Beach County) convened a task force composed of law enforcement officials tasked with investigating and prosecuting individuals engaged in fraud and abuse in the SUD treatment and recovery home industries. The task force found that unscrupulous recovery home operators or associated SUD treatment providers were luring individuals into recovery homes using deceptive marketing practices. These practices included online or other materials that willfully misdirected individuals or their family members to recruiters with the goal of sending these individuals to specific treatment providers so that the recruiters could receive payments from those treatment providers for each referral. According to officials from the Florida state attorney’s office, these individuals—often from out of state—were lured with promises of free airfare, rent, and other amenities to recover in southern Florida’s beach climate. Recruiters brokered these individuals to SUD treatment providers, who then billed their private insurance plans for extensive and medically unnecessary urine drug testing and other services. Officials from the Florida state attorney’s office told us that SUD treatment providers were paying $300 to $500 or more per week to recovery home operators or their staff members for every individual they referred for treatment. In addition, these officials cited one case in which a SUD treatment provider billed an individual’s insurance for close to $700,000 for urine drug testing over a 7-month period. Officials from the state attorney’s office noted that the recovery homes that the task force investigated were not shared homes in the traditional, supportive sense, but rather existed as “warehouses” intended to exploit vulnerable individuals. As a result of these investigations, as of December 2017, law enforcement agencies had charged more than 40 individuals primarily with patient brokering, with at least 13 of those charged being convicted and fined or sentenced to jail time, according to the state attorney’s office. In addition, the state enacted a law that strengthened penalties under Florida’s patient brokering statute and gave the Florida Office of Statewide Prosecution, within the Florida Attorney General’s Office, authority to investigate and prosecute patient brokering. Massachusetts An official from the Massachusetts Medicaid Fraud Control Unit told us that the unit began investigating cases of Medicaid fraud in the state on the part of independent clinical laboratories associated with recovery homes in 2007. The unit found that, in some cases, the laboratories owned recovery homes and were self-referring residents for urine drug testing. In other cases, the laboratories were paying kickbacks to recovery homes for referrals for urine drug testing that was not medically necessary. According to the Medicaid Fraud Control Unit official, as a result of these investigations, the state settled with nine laboratories between 2007 and 2015 for more than $40 million in restitution. In addition, the state enacted a law in 2014 prohibiting clinical laboratory self-referrals and revised its Medicaid regulations in 2013 to prohibit coverage of urine drug testing for the purposes of residential monitoring. Ohio At the time of our March 2018 report, Ohio had begun to investigate an instance of potential insurance fraud related to recovery homes, including patient brokering and excessive billing for urine drug testing. Officials from the Ohio Medicaid Fraud Control Unit told us that the unit began investigating a Medicaid SUD treatment provider for paying kickbacks to recovery homes in exchange for patient referrals, excessive billing for urine drug testing, and billing for services not rendered, based on an allegation the unit received in September 2016. Officials from other state agencies and related state entities, such as the state’s substance abuse agency and NARR affiliate, were not aware of any investigations of potential fraud on the part of recovery home operators or associated treatment providers when we interviewed with them. According to these state officials, this type of fraud was not widespread across the state. Utah In our March 2018 report, we reported that officials from the Utah Insurance Department told us that the department was conducting ongoing investigations of private insurance fraud similar to the activities occurring in Florida, as a result of a large influx of complaints and referrals the department had received in 2015. These officials told us that the department had received complaints and allegations that SUD treatment providers were paying recruiters to bring individuals with SUD who were being released from jail to treatment facilities or recovery homes; billing private insurance for therapeutic services, such as group or equine therapy, that were not being provided, in addition to billing frequently for urine drug testing; and encouraging individuals to use drugs prior to admission to qualify them and bill their insurance for more intensive treatment. In addition, insurance department officials told us that they believed providers were enrolling individuals in private insurance plans without telling them and paying their premiums and copays. According to these officials, when doing so, providers may lie about the individuals’ income status in order to qualify them for more generous insurance plans. Officials found that providers were billing individuals’ insurance $15,000 to $20,000 a month for urine drug testing and other services. Officials noted that they suspect that the alleged fraud was primarily being carried out by SUD treatment providers and treatment facilities that also own recovery homes. The officials said the department had not been able to file charges against any treatment providers, because it had been unable to collect the necessary evidence to do so. However, according to the officials, the state enacted legislation in 2016 that gave insurers and state regulatory agencies, such as the state’s insurance department and licensing office, the authority to review patient records and investigate providers that bill insurers. As we noted in our March 2018 report, this authority may help the insurance department and other Utah regulatory agencies better conduct investigations in the future. Three Selected States Have Established Oversight Programs, and Two Selected States Are Taking Other Steps to Support Recovery Homes In addition to actions taken in response to state investigations, our March 2018 report described steps taken by three of the five selected states (Florida, Massachusetts, and Utah) to formally increase oversight of recovery homes by establishing state certification or licensure programs. Florida enacted legislation in 2015 and Massachusetts enacted legislation in 2014 that established voluntary certification programs for recovery homes. Further, Florida established a two-part program for both recovery homes and recovery home administrators (i.e., individuals acting as recovery home managers or operators). According to officials from the Florida state attorney’s office and Massachusetts Medicaid Fraud Control Unit, their states established these programs, in part, as a result of state law enforcement investigations. Utah enacted legislation in 2014 to establish a mandatory licensure program for recovery homes. According to officials from the Utah substance abuse agency and the state licensing office, Utah established its licensure program, in part, to protect residents’ safety and prevent their exploitation and abuse. In our March 2018 report, we found that although state recovery home programs in Florida and Massachusetts are voluntary, there are incentives for homes to become certified under these states’ programs, as well as incentives to become licensed under Utah’s programs. Specifically, all three states require that certain providers refer patients only to recovery homes certified or licensed by their state program; therefore, uncertified and unlicensed homes in the three states are ineligible to receive patient referrals from certain treatment providers. Further, state officials told us that state agencies are taking steps to ensure providers are making appropriate referrals. For example, according to officials from the Florida substance abuse agency, treatment providers may refer individuals to certified recovery homes managed by certified recovery home administrators only and must keep referral records. To become state-certified or licensed, recovery homes in Florida, Massachusetts, and Utah must meet certain program requirements, including training staff, submitting documentation (such as housing policies and a code of ethics), and participating in onsite inspections to demonstrate compliance with program standards. However, specific requirements differ across the three states. For example, while all three state programs require recovery home operators or staff to complete training, the number of hours and training topics differ. In addition, for recovery homes to be considered certified in Florida, they must have a certified recovery home administrator. Similar to Florida’s certification program for the homes, individuals seeking administrator certification must meet certain program requirements, such as receiving training on recovery home operations and administration, as well as training on their legal, professional, and ethical responsibilities. Features of the state- established oversight programs also differ across the three states, including program type, type of home eligible for certification or licensure, certifying or licensing body, and initial fees. As we noted in our March 2018 report, the state-established oversight programs in Florida, Massachusetts, and Utah also include processes to monitor certified or licensed recovery homes, and take action when homes do not comply with program standards. For example, an official from the Florida Association of Recovery Residences—the organization designated by the state to certify recovery homes—told us that the entity conducts random inspections to ensure that recovery homes maintain compliance with program standards. State-established oversight programs in the three states also have processes for investigating grievances filed against certified or licensed recovery homes. Further, officials from certifying or licensing bodies in all three states told us their organizations may take a range of actions when they receive complaints or identify homes that do not comply with program standards, from issuing recommendations for bringing homes into compliance to revoking certificates or licenses. According to officials from Florida’s certifying body, the entity has revoked certificates of recovery homes that have acted egregiously or have been nonresponsive to corrective action plans. Officials from the certifying and licensing bodies in Massachusetts and Utah told us that they had not revoked certificates or licenses, but had possibly assisted homes with coming into compliance with certification standards or licensure requirements. Officials from Ohio and Texas told us that their states had not established state oversight programs like those in Florida, Massachusetts, and Utah, but said their states had provided technical assistance and other resources to recovery homes in an effort to increase consistency, accountability, and quality. Officials from the Ohio substance abuse agency told us that since 2013 the state has revised its regulatory code to define recovery homes and minimum requirements for such homes. Officials also told us that the agency did not have authority to establish a state certification or licensure program for recovery homes. According to these officials, the state legislature wanted to ensure that Ohio’s recovery homes community maintained its grassroots efforts and did not want a certification or licensure program to serve as a roadblock to establishing additional homes. However, officials from the Ohio substance abuse agency told us that the agency encourages recovery homes to seek certification by the state’s NARR affiliate—Ohio Recovery Housing—to demonstrate quality. In addition, these officials told us that the state substance abuse agency also provided start-up funds for Ohio Recovery Housing, as well as continued funding for the affiliate to provide training and technical assistance, and to continue certifying recovery homes. According to officials from Ohio Recovery Housing, the NARR affiliate regularly provides the state’s substance abuse agency with a list of newly certified recovery homes, as well as updates on previously certified homes as part of ongoing efforts to develop a recovery home locator, under its contract with the agency. Officials from the Texas substance abuse agency told us that establishing a voluntary certification program would be beneficial. However, the state legislature had not enacted legislation establishing such a program at the time of our review. At the time of our report, the agency was in the process of developing guidance for providers on where and how to refer their patients to recovery housing, which includes a recommendation to send patients to homes certified by the Texas NARR affiliate. Chairman Grassley, Ranking Member Wyden, and Members of the Committee, this concludes my prepared statement. I would be pleased to respond to any questions that you may have at this time. GAO Contact and Staff Acknowledgments If you or your staff members have any questions concerning this testimony, please contact me at (202) 512-7114 or deniganmacauleym@gao.gov. Contact points for our Office of Congressional Relations and Public Affairs may be found on the last page of this statement. 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