The current National Incident Management System (NIMS) doctrine document, dated December 2008, has guided NIMS for over seven years.  This iteration, as I recall, wasn’t much of a change from its predecessor (2004), with the most significant updates being some changes to the NIMS components and the inclusion of the concept and arrangement of the Intelligence function within ICS.  We now have a new draft NIMS document which has been posted for a national engagement period.  If you haven’t had a chance to review the document, it can be found here.

While I certainly intend on providing my comments directly to FEMA through their feedback mechanism (which I encourage you all to do), I wanted to provide a bit of an overview of the draft document to my readers, which of course will include some of my opinions on the changes they are proposing.  I remain a huge proponent of NIMS and fully believe in the positive impact it has had, although I have been quite outspoken (and will remain so) about the issues associated with ICS training.

In this NIMS refresh, as they are calling it, there are some significant changes to certain areas while largely maintaining the foundations of the system.  The significant changes include:

• NIMS has consolidated its five components to three, dropping the components of Preparedness and Ongoing Management and Maintenance.
• The introduction of the Center Management System (CMS) as part of the restructured Management and Coordination (formerly Command and Management) component
• Incorporation of the NIMS Intelligence and Investigations Function Guidance

First off, the consolidation of the five NIMS components to three.  While I’m disappointed with the preparedness component being deemphasized, especially with so much preparedness work to always be done, I found many of the concepts of preparedness to be sprinkled throughout the document, including a nod to the National Preparedness Goal (NPG) in the introduction of the draft document.  The NPG should certainly be the guiding document of all preparedness efforts related to emergency management.  While there are some aspects that are NIMS-specific, I’m fairly confident they won’t get lost in the shuffle.  Withdrawing the Ongoing Management and Maintenance component, similarly has seen some of these activities being mentioned elsewhere in the document, although only a few of them, with some of the important elements simply not being apparent.

In my review of the document, I was pleased with the inclusion (albeit small) of the concept of Unity of Effort as a newly introduced guiding principal of NIMS.  Unity of Effort is an concept essential to the success to all components of emergency management and homeland security and certainly in incident management.  This is definitely a positive.

Credentialing – the first major component discussed in the document is Resource Management.  Within Resource Management is the concept of credentialing.  Despite an intent of the document being to emphasize that NIMS isn’t just about ICS, the narrative on credentialing essentially focuses only credentialing through use of a position task book – which is generally only used for ICS positions.  While this is an important element of personnel qualifications, credentialing of personnel within ICS positions is not the only aspect of personnel qualifications.

Based upon the content of the NIMS Intelligence and Investigation function guidance published a few years ago, the NIMS refresh has officially decreed that the Intelligence and Investigations function will reside at the general staff level.  You might recall that the previous version of NIMS allowed for several options, including general staff, command staff, or imbedded within Planning or Operations.  While the flexibility of ICS is one of its greatest benefits, people didn’t seem comfortable with all those options.  It’s not to say those options still can’t be employed for incidents involving much smaller or potential criminal components, as the option of placing a technical specialist in any of those positions is still available.

Next up, the long awaited Center Management System (CMS).  To be honest, I’m not crazy about the name, and I’m not sure we need fully developed separate guidance on operations/coordination centers.  I feel that specific application of ICS concepts to an operations/coordination center should be kept simple and would be an addendum to the ICS portion of the NIMS document.  That said, the NIMS refresh has saw fit to include a whole section on the CMS as part of the revamped Management and Coordination component, so we’ll break down some of the highlights.  It’s important to note that the CMS is expected to be guidance and not a requirement.

While I can live with the introduction of a formal Center Management System, they have chosen to declare the title of the individual in charge of an operations/coordination center a Center Director.  If there is anything that I 100% disagree with in this document, it’s this title.  Let’s step back and look at the principles of ICS, which, thankfully ,the CMS is largely based upon.  From our common organizational terminology, we know that those in charge of facilities (which an operations/coordination center is) are called managers, not directors.  Directors are found at the branch level.  It’s for this reason I have always been in favor of the Center Manager title and will continue to be.

A positive about the CMS narrative is the important mention of a policy group, as a MAC concept, as those providing advice or direction to the Center Director.  Not only is the policy group a reality in many jurisdictions, inclusion of this in the CMS is an excellent compromise to those systems which centered on a policy group and operations group as their EOC organization.

Within discussion of the CMS, the NIMS refresh identifies primary functions or reasons a center might activate.  While they are headed in the right direction, they need their explanations to be a bit more inclusive of other options.  They only make a minor mention of the possibility of an incident actually being run from an operations/coordination center, such as a public health incident, which could be a departmental operations center or some type of a multi-agency operations center.  I just think this needs to be shored up some.  It should also be mentioned that EOCs may take primary responsibility for actions that are decided to be outside the scope of incident command, which may desire to remain focused on incident suppression activities.  Activities such as sheltering/mass care, evacuation, or assessment and evaluation may be run out of an EOC instead of an ICP.

Now on to the CMS organization.  Along with the Center Director, the NIMS refresh has tried to make several other positions distinct from their ICS counterparts (although not all of them).  While I certainly acknowledge that the focus of an operations/coordination center is often different than that of an ICP, I see little reason to change the titles of some of these positons.  I think this has more potential to add to confusion rather than detract from it.  While the command staff (yes, still being called ‘command staff’) positions have remained the same, the following has been identified as the CMS general staff positions:

• Strategic Operations Section
• Intelligence/Investigations Section
• Information and Planning Section
• Resource and Center Logistics Section
• Finance/Administration Section

As for some of the specific language within the sections, there are some positives.  Two particular ones are the inclusion of ‘future planning’ within the Information and Planning Section, and the acknowledgement that in most EOCs, the Logistics Section/Resource and Center Logistics Section tends to handle tracking of resources.

There is additional and expanded information on the CMS found in Appendix B.  These show some different organizational arrangements, particularly within the Information and Planning Section and the Resource and Center Logistics Section.  All in all, I think these proposed arrangements are practical and a reflection of reality in most operations/coordination centers.  Well done.

Lastly, Communications and Information Management has included mentions of different reports which may be required, including flash reports, status reports, and situation reports.  This is a good reflection of reality. They have also listed important considerations for elements of essential information (EEI) (I’d love to see this list added to a field operations guide!), which must be constantly monitored for the maintenance of situational awareness, and they have bolstered the incident information portion of this component.  All great positives!  Interesting to note that the term ‘common operating picture’ has been significantly de-emphasized.

After reviewing this document, I’m overall encouraged with the direction NIMS is taking, although I obviously have some reservations.  I’m confident that, over time, the kinks will shake out as they have done with other aspects of NIMS.  I’m looking forward to some of the other changes that will spin off of this central document, such as new planning guidance and training.

As always, I’m interested in your feedback on my ideas as well as your own reactions and analysis of the NIMS refresh.

Thanks for reading!

© 2016 – Timothy Riecker, CEDP

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