I know I’m a big nerd when it comes to this stuff, but I was really excited to receive the notice from FEMA that the new Comprehensive Preparedness Guide (CPG) 101: Developing and Maintaining Emergency Operations Plans has been published! This has been a long time coming. This update (version 3) replaces the previous version which was published in November 2010. The update process was also rather lengthy, with the first public review occurring in November 2019 and the second in November 2020.
Did a lot change? No.
Is it better? Yes.
Could it be even better? You bet.
The changes that are included in the new document are meaningful, with an emphasis on including accessibility concepts in plans; and references to current practices and standards, such as new and updated planning guides, CPG 201 (THIRA), Community Lifelines, and more. It even highlights a couple of lessons learned from the COVID 19 pandemic. I’m particularly pleased to see Appendix D: Enhancing Inclusiveness in EOPs, which I think is an excellent resource, though more links to other resources, of which there are many, should be provided in this appendix.
The format of the document is largely the same, with a lot of the content word-for-word the same. As a standard, a lot of change shouldn’t be expected. While we’ve seen some changes in our perspectives on emergency planning, there really hasn’t been anything drastic. Certainly “if it ain’t broke, don’t fix it”, but I think there could have been some better formatting choices, narrative, graphics, and job aids to enhance readability and implementation.
There is some added content as well as a bit of highlighting of planning approaches, such as the District of Columbia’s services-based emergency operations plan. While I advocated for heavy reference to newer implementations and standards, such as THIRA, into the document (which was largely done) I also advocated for more user-friendly approaches, such as a hazard analysis matrix, to be included. My feedback from both public comment periods heavily emphasized the need to develop a document that will mostly benefit novice emergency planners. To me this means the inclusion of more graphic depictions of processes and tasks, as well as job aids, such as checklists and templates. The new CPG 101 does include more checklists. At first glance these are buried in the document which is not very user friendly. However, they did make a separate Compilation of Checklists document available, which I’m really happy about. It’s not highly apparent on the website nor is it included as part of the main document, so it could be easily missed.
I would have really liked to see a comprehensive library of job aids provided in the appendices to support implementation by new planners. We have other doctrine and related documents that provide rather extensive job aids to support implementation, such as HSEEP and NIMS (and not only the ICS component of NIMS). Not including that kind of supporting material in this update is very much a missed opportunity. Planning really is the cornerstone of preparedness, yet it doesn’t seem we are providing as much support for quality and consistent planning efforts. Given the extent of time between updates, I expected better. While being largely consistent in the format and content between versions is practically a necessity, there really should have been a parallel effort, separate from document revision, to outline practices and approaches to emergency plan development. Integrating that content into the update, ideally, would have done more to support HOW each step of the planning process is accomplished, as well as providing some job aids.
Speaking of implementation support, I’m curious about how EMI’s new Advanced Planning course, which I didn’t get into the pilot offering of, builds on the Emergency Planning course and compliments use of CPG 101.
Be sure to update your own personal reference library with this new version of CPG 101. If you are interested in a review with FEMA personnel, they are providing a series of one-hour webinars. What are your thoughts on the new CPG 101?
© 2021 Tim Riecker, CEDP