I hope everyone is settling into the new year nicely.  One of the things I started off this year doing was going through CPG 101 and providing input to FEMA for the update of this foundational document.  (note: if you haven’t yet, get your comments in now as the deadline is soon approaching!)  CPG 101, and its predecessors, are time tested and well honed in the guidance provided on the process used for planning.  While it’s frustrating to see and hear that some people still don’t use it, that’s no fault of the document itself, but rather one of human implementation, or lack thereof.

I thought I’d share some of the feedback I sent along to FEMA on what I would like to see in the CPG 101 update.  Looking over my submission, there were two main themes I followed:

1. Integration of other doctrine and standards
2. Development of job aids to support use and implementation

I feel that integration of other relevant doctrine and standards into CPG 101 is incredibly important.  We know that preparedness covers an array of activities, but planning is the foundational activity, which all other activities reflect upon.  In past articles I’ve addressed the need to identify these various standards collectively, to show that while these are individual activities with their own outputs, identifying how they can and should be interconnected, offering greater value if used together.  Things like Community Lifelines, THIRA/SPR, HSEEP, and Core Capabilities need to not only be mentioned often, but with examples of how they interconnect and support planning and even each other.

Job aids are tools that support implementation.  I think job aids can and should be developed and included in the updated CPG 101 for each step of the planning process.  While some of us write plans fairly often, there are many who don’t or are going into it for the first time.  These are essentially the ideal conditions for job aids.  They help guide people through the key activities, provide them with reminders, and ultimately support better outcomes. Not only would I like to see job aids, such as check lists and work sheets, for each step, I’d also think that something that covers the whole process comprehensively, essentially a project management perspective, would be incredibly helpful to many people.

There were a couple of one-off suggestions that might not fit the categories mentioned above.  One of which was having more emphasis on the value of data from the jurisdiction’s hazard mitigation plan.  The hazard analysis conducted for hazard mitigation planning is considerably thorough, and can provide great information to support a hazard analysis (or even a THIRA for those brave enough) for purposes of emergency planning.  To be honest, this was something I didn’t really learn until about ten years into my career.  Many of the people I learned from in Emergency Management often leaned so far into response that they disregarded the value of things like mitigation or recovery.  I still find this a lot in our profession.  Once I finally took the time to go through a hazard mitigation plan, I realized the incredible amount of information contained within.  In many cases, there is more information than what is needed for the hazard analysis of an emergency plan, as the narrative and analysis in a hazard mitigation plan often goes into a measure of scientific detail, but this, too, can certainly have value for emergency planning.  Similarly, I also suggested that FP 104-009-2 (the Public Assistance Program and Policy Guide) be included as a reference in CPG 101.  Jurisdictions will strongly benefit from having plans, such as those on debris management, meeting FEMA’s reimbursement guidelines.

Lastly, I encouraged FEMA to include any content that will support plan writers in developing plans that are simply more useful.  So many plans are just a lot of boilerplate narrative, that in the end don’t tell me WHO is responsible for WHAT and HOW things will get done.  It’s so easy for us to be dismissive of action steps when writing a plan, assuming that people will know who has the authority to issue a public alert or the steps involved in activating an EOC.  CPG 101 should reinforce the need for plans to define processes and actions, identify authority, and assign responsibility.  Flow charts, decision trees, maps, charts, and other graphics and job aids are incredibly helpful to ensure that a plan is thorough while also being useful.

That’s the feedback I provided to FEMA, along with a bit of narrative as to why those things are important for inclusion in an updated CPG 101.  I’m curious to hear about the feedback that others provided.  We all tackle these documents from different perspectives, and that’s why I truly appreciate the efforts FEMA makes in these public calls for comment when they are updating certain key documents.

© 2020 – Timothy Riecker, CEDP

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