Failures in Preparedness

In May the GAO released a report titled “National Preparedness: Additional Actions Needed to Address Gaps in the Nation’s Emergency Management Capabilities”. I encourage everyone to read the report for themselves and also reflect on my commentary from several years of National Preparedness Reports. I’ll summarize all this though… it doesn’t look good. The National Preparedness Reports really tell us little about the state of preparedness across the nation, and this is reinforced by the GAO report as they state “FEMA is taking steps to strengthen the national preparedness system, but has yet to determine what steps are needed to address the nation’s capability gaps across all levels of government”.

First of all, let me be clear about where the responsibility of preparedness lies – EVERYONE. Whole community preparedness is actually a thing. It’s not FEMA’s job to ensure we are prepared. As also made evident in the GAO report (for those who haven’t worked with federal preparedness grants), most preparedness grants are pretty open, and as such, the federal government can’t force everyone to address the most critical capability gaps. Why wouldn’t jurisdictions want to address the most critical capability gaps, though? Here are some of the big reasons:

  • Most or all funding may be used to sustain the employment of emergency management staff, without whom there would be no EM program in that jurisdiction
  • The jurisdiction has prioritized sustaining other core capabilities which they feel are more important
  • The jurisdiction has decided that certain core capabilities are not for them to address (deferring instead to state or federal governments)
  • Shoring up gaps is hard
  • Response is sexier

The GAO report provided some data to support where priorities lie. First, let’s take a look at spending priorities by grant recipients:

While crosscutting capabilities (Operational Coordination, Planning, and Public Information and Warning) were consistently the largest expenditures, I would surmise that Operational Coordination was the largest of the three, followed by Planning, with Public Information and Warning coming in last. And I’m pretty confident that while these are cross cutting, these mostly lied within the Response Mission Area. Assuming my predictions are correct, there is fundamentally nothing wrong with this. It offers a lot of bang for the buck, and I’ve certainly spoken pretty consistently about how bad we are at things like Operational Coordination and Planning (despite some opinions to the contrary). Jumping to the end of the book, notice that Recovery mission area spending accounts for 1% of the total. This seems like a poor choice considering that three of the five lowest rated capabilities are in the Recovery mission area. Check out this table also provided in the GAO report:

Through at least a few of these years, Cybersecurity has been flagged as a priority by DHS/FEMA, yet clearly, we’ve not made any progress on that front. Our preparedness for Housing recovery has always been abysmal, yet we haven’t made any progress on that either. I suspect that those are two areas, specifically, that many jurisdictions feel are the responsibility of state and federal government.

Back in March of 2011, the GAO recommended that FEMA complete a national preparedness assessment of capability gaps at each level of government based on tiered, capability-specific performance objectives to enable prioritization of grant funding. This recommendation has not yet been implemented. While not entirely the fault of FEMA, we do need to reimagine that national preparedness system. While the current system is sound in concept, implementation falls considerably short.

First, we do need a better means of measuring preparedness. It’s difficult – I fully acknowledge that. And for as objective as we try to make it, there is a vast amount of subjectivity to it. I do know that in the end, I shouldn’t find myself shaking my head or even laughing at the findings identified in the National Preparedness Report, though, knowing that some of the information there can’t possibly be accurate.

I don’t have all the answers on how we should measure preparedness, but I know this… it’s different for different levels of government. A few thoughts:

  • While preparedness is a shared responsibility, I don’t expect a small town to definitively have the answers for disaster housing or cybersecurity. We need to acknowledge that some jurisdictions simply don’t have the resources to make independent progress on certain capabilities. Does this mean they have no responsibility for it – no. Absolutely not. But the current structure of the THIRA, while allowing for some flexibility, doesn’t directly account for a shared responsibility.
  • Further, while every jurisdiction completing a THIRA is identifying their own capability targets, I’d like to see benchmarks established for them to strive for. This provides jurisdictions with both internal and external definitions of success. It also allows them an out, to a certain extent, on certain core capabilities that have a shared responsibility. Even a small town can make some progress on preparedness for disaster housing, such as site selection, estimating needs, and identifying code requirements (pro tip… these are required elements of hazard mitigation plans).
  • Lastly, we need to recognize that it’s difficult to measure things when they aren’t the same or aren’t being measured the same. Sure, we can provide a defined core capability, but when everyone has different perspective on and expectation of that core capability and how it should be measured, we aren’t getting answers we can really compare. Everyone knows what a house is, but there is a considerable difference between a double wide and a McMansion. Nothing wrong with either of them, but the differences give us very different base lines to work from. Further, if we need to identify how big a house is and someone measures the length and width of the building, someone else measures the livable square footage of a different building, and a third person measures the number of floors of yet another house, we may have all have correct answers, but we can’t really compare any of them. We need to figure out how to allow jurisdictions to contextualize their own needs, but still be playing the same game.

In regard to implementation, funding is obviously a big piece. Thoughts on this:

  • I think states and UASIs need to take a lot of the burden. While I certainly agree that considerable funding needs to be allocated to personnel, this needs to be balanced with sustaining certain higher tier capabilities and closing critical gaps. Easier said than done, but much of this begins with grant language and recognition that one grant may not fit all the needs.
  • FEMA has long been issuing various preparedness grants to support targeted needs and should not only continue to do so, but expand on this program. Targeted grants should be much stricter in establishing expectations for what will be accomplished with the grant funds.
  • Collaboration is also important. Shared responsibility, whole community, etc. Many grants have suggested or recommended collaboration through the years, but rarely has it been actually required. Certain capabilities lend themselves to better development potential when we see the realization of collaboration, to include the private sector, NGOs, and the federal government. Let’s require more of it.
  • Instead of spreading money far and wide, let’s establish specific communities of practice to essentially act as model programs. For a certain priority, allocate funds for a grant opportunity with enough to fund 3-5 initiatives in the nation. Give 2-3 years for these programs to identify and test solutions. These should be rigorously documented so as to analyze information and potentially duplicate, so I suggest that academic institutions also be involved as part of the collaborative effort (see the previous bullet). Once each of the grantees has completed their projects, host a symposium to compare and contrast, and identify best practices. Final recommendations can be used to benchmark other programs around the nation. Once we have a model, then future funding can be allocated to support implementation of that model in other areas around the nation. Having worked with the National Academies of Sciences, Engineering, and Medicine, they may be an ideal organization to spearhead the research component of such programs.
  • Recognize that preparedness isn’t just long term, it’s perpetual. While certain priorities will change, the goals remain fundamentally the same. We are in this for the long haul and we need to engage with that in mind. Strategies such as the one in the previous bullet point lend themselves to long-term identification of issues, exploration of solutions, and implementation of best practices.
  • Perhaps in summary of all of this, while every jurisdiction has unique needs, grant programs can’t be so open as to allow every grantee to have a wholly unique approach to things. It feels like most grant programs now are simply something thrown at a wall – some of it sticks, some of it falls right off, some might not even make it to the wall, some slowly drips off the wall, and some dries on permanently. We need consistency. Not necessarily uniformity, but if standards are established to provide a foundational 75% solution, with the rest open for local customization, that may be a good way to tackle a lot of problems.

In the end, while FEMA is the implementing agency, the emergency management community needs to work with them to identify how best to measure preparedness across all levels and how we can best implement preparedness programs. Over the past few years, FEMA has been very open in developing programs for the emergency management community and I hope this is a problem they realize they can’t tackle on their own. They need representatives from across the practice to help chart a way ahead. This will ensure that considerations and perspectives from all stakeholder groups are addressed. Preparedness isn’t a FEMA problem, it’s an emergency management problem. Let’s help them help us.

What thoughts do you have on preparedness? How should we measure it? What are the strengths and areas for improvement for funding? Do you have an ideal model in mind?

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

The Future of NFPA 1600

NFPA 1600: Standard on Continuity, Emergency, and Crisis Management is a standard I often reference. The contents of the standard, applicable to all organizations including government, non-profit, and private sector; compliments other standards and doctrine well, and is regularly updated to integrate new practices. The latest editions have gained even more value with what can be collectively referred to as implementation notes, which really help support putting the standard into action. The NFPA has also been releasing ‘Handbook’ editions of their standards, with even more professional commentary to support implementation. There is news, though… NFPA 1600 is going away – but don’t worry!

Last year, the NFPA announced the Emergency Response and Responder Safety Document Consolidation Plan. This is part of a larger movement within the NFPA to pull together a variety of similar codes and standards. NFPA 1600 will be combined into a new consolidated standard, NFPA 1660. NFPA 1660 will consist of the present NFPA 1600, NFPA 1616 (Standard on Mass Evacuation, Sheltering, and Re-Entry Programs), and NFPA 1620 (Standard for Pre-Incident Planning). The respective scopes of each of these documents are very complimentary and it absolutely makes sense for them to be in a combined edition. I appreciate that the combined editions will better allow readers to connect the dots of the continuity of activity.

The new NFPA 1660: Standard on Community Risk Assessment, Pre-Incident Planning, Mass Evacuation, Sheltering, and Re-entry Programs is in a public input period for the first draft through November 13, 2020; with a second draft scheduled for release in 2021; and a final draft by the end of 2022. So, don’t worry, NFPA 1600, or the other two standards it is being combined with, are not yet ‘obsolete’, but these standards on their own will no longer be updated.

For many years, NFPA 1600 has been available free digitally. I’m hoping the new combined standard will also be available for free as it will be an even more valuable resource and reference for a very broad range of emergency management and business continuity professionals, as well as students of these professions. I certainly expect the new NFPA 1660 to include new or modified standards as the result of lessons learned from the Coronavirus pandemic.

Is there anything you would like to see in the new standard?

©2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®