To: The U.S. Government Accountability Office, The Department of Homeland Security, The Federal Emergency Management Agency, and Members of Congress
From: The State Guard Association of the United States (SGAUS)
Subject: A Vanguard of Support: A Partnership to Ensure FEMA’s Mission Success
The State Guard Association of the United States (SGAUS) has thoroughly reviewed the Government Accountability Office report GAO-25-108598 dated September 2, 2025. We commend the GAO for its analysis, and we extend our profound respect to the dedicated personnel of FEMA, who face an operational tempo of unprecedented scale and complexity.
This letter is not a critique; it is an emphatic offer of support. The challenges identified in the report—where workforce availability can drop to a critical 4 percent during concurrent disasters—are not an indictment of any single agency. Rather, they are a clear sign that the current national response model requires a new vanguard of support to unburden FEMA’s dedicated staff and ensure their continued success.
Our organizations already have successful pillars for this partnership. The National Guard Bureau’s 2024 published authorization for our members to wear the Military Emergency Management Specialist (MEMS) badge on the U.S. Army uniform is a powerful testament to the standardized, professional training our members receive. Furthermore, the FEMA Supplemental Response Team (SRT) Program, which will allow our individual members to be activated for federal service, proves we are a trusted and capable resource.
Now, we must build upon this foundation. As authorized by Title 32, Section 109 of the U.S. Code, State Defense Forces (SDFs) are uniformed, trained, and organized military units. We propose that these SDFs, in accordance with each state’s laws and chain of command decision processes, can act as this vanguard of support. The next evolution of our partnership is to move beyond activating skilled individuals and begin integrating our cohesive, organized units. By deploying our teams for logistics, mass care, and operational support, we can absorb on-the-ground missions, allowing FEMA’s expert personnel to focus on their critical and uniquely federal responsibilities.
To strengthen FEMA and guarantee a more robust national response, we propose the following collaborative actions:
- Formalize a Framework for Unit Integration: Let us work together to create a system where governors can deploy intact SDF units as a force package, providing FEMA field leadership with a reliable and immediate surge of organized, uniformed personnel.
- Deepen our Strategic Alignment: We propose elevating our Annual Capabilities Briefing to a Joint Strategic Planning Session, where we can use GAO data and FEMA forecasts to align SDF training directly with the nation’s most critical capability gaps.
- Ensure Seamless Interoperability through Joint Exercises: We request the formal inclusion of SDF units in national-level exercises to perfect our joint capabilities, ensuring we operate as a single, seamless team when disaster strikes.
FEMA’s mission is vital to our nation’s security and well-being. You do not have to face these challenges alone. We stand ready, as a statutorily authorized and federally recognized partner, to serve alongside you. Let us move forward together, building on our established partnership to forge a disaster response enterprise that is truly worthy of the American people—one that is robust, resilient, and always ready.
The challenges we face are immense, but the spirit of service that defines this nation is greater.
Very Respectfully,
Barry R. Greene Lt. Colonel, NYG, Ret.
38th President The State Guard Association of the United States
