In late May, FEMA/DHS released an updated version of Comprehensive Preparedness Guide (CPG) 201. For those not familiar, CPG 201 is designed to guide communities and organizations through the process of the Threat and Hazard Identification and Risk Assessment (THIRA). This is the third edition of a document that was originally released in April 2012. This third edition integrates the Stakeholder Preparedness Review (SPR) into the process. Note that ‘SPR’ has commonly been an acronym for State Preparedness Report, which is also associated with the THIRA. The goal of the Stakeholder Preparedness Review appears to be fundamentally similar to that of the State Preparedness Report which some of you may be familiar with.
First of all, a few noted changes in the THIRA portion of CPG 201. First, FEMA now recommends that communities complete the THIRA every three years instead of annually. Given the complexity and depth of a properly executed THIRA, this makes much more sense and I fully applaud this change. Over the past several years many jurisdictions have watered down the process because it was so time consuming, with many THIRAs completed being more of an update to the previous year’s than really being a new independent assessment. While it’s always good to reflect on the progress relative to the previous year, it’s human nature to get stuck in the box created by your reference material, so I think the annual assessment also stagnated progress in many areas.
The other big change to the THIRA process is elimination of the fourth step (Apply Results). Along with some other streamlining of activities within the THIRA process, the application of results has been extended into the SPR process. The goal of the SPR is to assess the community’s capability levels based on the capability targets identified in the THIRA. Despite the THIRA being changed to a three-year cycle, CPG 201 states that the SPR should be conducted annually. Since capabilities are more prone to change (often through deliberate activities of communities) this absolutely makes sense. The SPR process centers on three main activities, all informed by the THIRA:
- Assess Capabilities
- Identify and Address Gaps
- Describe Impacts and Funding Sources
The assessment of capabilities is intended to be a legacy function, with the first assessment establishing a baseline, which is then continually reflected on in subsequent years. The capability assessment contributes to needs identification for a community, which is then further analyzed for the impacts of that change in capability and the identification of funding sources to sustain or improve capabilities, as needed.
An aspect of this new document which I’m excited about is that the POETE analysis is finally firmly established in doctrine. If you aren’t familiar with the POETE analysis, you can find a few articles I’ve written on it here. POETE is reflected on several times in the SPR process.
So who should be doing this? The document references all the usual suspects: state, local, tribal, territorial, and UASI jurisdictions. I think it’s great that everyone is being encouraged to do this, but we also need to identify who must do it. Traditionally, the state preparedness report was required of states, territories, and UASIs as the initial recipients of Homeland Security Grant Program (HSGP) sub-grants. In 2018, recipients of Tribal Homeland Security Grant Program funds will be required to complete this as well. While other jurisdictions seem to be encouraged to use the processes of CPG 201, they aren’t being empowered to do so.
Here lies my biggest criticism… as stated earlier, the THIRA and SPR processes are quite in-depth and the guidance provided in CPG 201 is supported by an assessment tool designed by FEMA for these purposes. The CPG 201 website unfortunately does not include the tool, nor does CPG 201 itself even make direct reference to it. There are vague indirect references, seeming to indicate what kind of data can be used in certain steps, but never actually stating that a tool is available. The tool, called the Universal Reporting Tool, provides structure to the great deal of information being collected and analyzed through these processes. Refined over the past several years as the THIRA/SPR process has evolved, the Universal Reporting Tool is a great way to complete this. As part of the State Preparedness Report, the completed tool was submitted to the FEMA regional office who would provide feedback and submit it to HQ to contribute to the National Preparedness Report. But what of the jurisdictions who are not required to do this and wish to do this of their own accord? It doesn’t seem to be discouraged, as jurisdictions can request a copy from FEMA-SPR@fema.dhs.gov, but it seems that as a best practice, as well as a companion to CPG 201, the tool should be directly available on the FEMA website. That said, if the THIRA/SPR is being conducted by a jurisdiction not required to do so, the tool would then not be required – although it would help.
Overall, I’m very happy with this evolution of CPG 201. It’s clear that FEMA is paying attention to feedback received on the process to streamline it as best they can, while maximizing the utility of the data derived from the analysis. A completed THIRA/SPR is an excellent foundation for planning and grant funding requests, and can inform training needs assessments and exercise program management (it should be used as a direct reference to development of a Training and Exercise Plan).
For those interested, EPS’ personnel have experience conducting the THIRA/SPR process in past years for a variety of jurisdictions and would be happy to assist yours with this updated process. Head to the link below for more information!
© 2018 – Timothy Riecker, CEDP
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