Tag CPG 101

Taking the Reins

Tim Riecker, The Contrarian Emergency Manager 4 Comments

Through the past several years of my blog, the central theme of my posts has really been to ask ‘why?’. Why do we do the things we do in emergency management? Why do we accept things as they are? Why haven’t we endeavored to change, update, or improve upon some of these things that range, at best, from mediocracy to, at worst, absolute crap?

A boss of mine many (so many) years ago taught me the concept of ‘ask why five times’ if you want to get to the root of anything. Of course, you need to seek the proper people to ask or sources to conduct your research, but the concept still stands – often we can’t just ask ‘why’ once and expect that one answer to explain everything for us.

Our field of practice is filled with so many things which can be considered standards. They may be true standards, such as NFPA 1660, or simply a de facto standard – something that has become widely accepted in practice, such as CPG 101.

Standards are a double-edged sword. On the better side, they give us commonality. We can expect that, if reasonably applied, the outputs will have substantial similarity and will, at minimum, meet a base-line expectation. Consistency is generally viewed as good and beneficial in largely any application. On the other hand, standards can stifle innovation. They can encourage laziness. They often promote shortcuts like templates, which, while there are benefits, largely remove the inclination of critical thinking from the work that is done and assume that all applications can fit within someone else’s concept of how things should be.

As we face a significant possibility of a number of de facto standards from FEMA no longer being maintained due to changes in focus and reduction in force – things like the homeland security exercise and evaluation program (HSEEP), CPG 101, and even the National Incident Management System (NIMS) – how will things be done in what may become a new era of emergency management?

There are some that are shilling the downfall of emergency management. While I don’t think this extreme is quite realistic, there will most certainly be some significant changes and impacts to which we must adapt. In the realm of standards (and likely other gaps created), I feel the profession will realize the need to take care of itself, taking a path of self-determination and filling a role that has been, most successfully, done by FEMA. Early on, in the absence of a central coordinating entity (FEMA) maintaining these de facto standards, we will see several disparate efforts of upkeep, with results likely following a bell curve of quality – most will be deemed reasonable, though outliers will exist on both ends of the spectrum, with one side being garbage and the other fairly inspired and progressive. Here enters opportunity. Opportunity for improvement, innovation, different perspectives, and simply seeking better ways of doing things. Though this process begs some questions – Whose version will reign supreme? And what authority does the author have to publish any given standard? Is some measure of authority even required for such a thing for it to be, even unofficially, adopted by the profession?

I feel that regardless of this circumstance, we must periodically examine our standards of practice. Ask ‘why?’ five times (or really however many times is necessary). This can range from asking the same question over and over until you get to some foundational answer you are seeking, or asking a chain of related questions to poke at different sides of the standard. Consider questions like ‘Why does the standard exist?’, ‘Why does the standard exist as it is?’, ‘How did this standard evolve?’, ‘What are the strengths of the current standard?’, ‘What are the weaknesses of the current standard?’, ‘What can we do better and how?’.

There has been some effort lately (also spearheaded by FEMA) toward the concept and implementation of continuous improvement. Standards should also fit within this movement. Standards need to evolve and change and support the practice, though they should be constructed in such a fashion that does not limit a range of application (i.e. can it be used by states as well as small towns? Does it need to be?) or stifle innovation. And while evolution is necessary, I’ll also caution against wholesale change – unless a truly better way is developed and validated. Standards should not change based simply on someone’s good idea, a different perspective, or political influence. Standards (true or de facto) or any part thereof and in any industry should be peer developed and peer reviewed. Changes need to be carefully considered, but also not feared. While I feel FEMA has been a good steward of our standards of practice, that time may be coming to an end, at least for a while. The standards of practice across emergency management must be maintained if this disruption comes to fruition. This is a challenge. This is an opportunity. This is a necessity. We must rise to the occasion.

© 2025 – Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Stop Exercising Bad Plans

Tim Riecker, The Contrarian Emergency Manager 9 Comments

We know that the purpose of most exercises in emergency management (ref HSEEP) and related fields is to validate plans. That concept, though, is built on a fragile premise: that the plans are good.

Over the years, the more plans I see from various jurisdictions, the more disappointed I am practically to the extent of losing near-total faith in our profession’s ability to develop quality plans. Most emergency plans out there are crap. Garbage. Not worth the effort that has been put into them. Typically, they don’t have enough detail. Not that they need to have procedure-level detail (but those procedures should be found somewhere), but they are often written so high level that they are merely conceptual or policy-esque.

The premise that exercises are intended to validate plans would indicate a belief that the plans themselves serve as quality standards of practice for the organization(s) they are built for. The sad truth is that they are not. So, what are our exercises proving?

Gaps in exercise evaluation are a significant hurdle which are often based upon poor evaluation practices, poor AAR writing, and/or the assumption of quality plans. I find many AARs to be very superficial. They provide observations and recommendations, but no analysis. Without analysis we have no context for the observation and no examination of root cause or other contributing factors. Absent this analysis, the AARs aren’t able to truly identify what needs to be addressed. So, with the superficial, come the obvious statements and recommendations that communication needs to be improved, more ICS training is needed, etc.

What I don’t see enough of are observations, ANALYSIS, and recommendations that indicate:

  1. Plans need to be drastically improved (updated and/or developed)
  2. Responders need to actually be trained in their roles to support implementation of the plans (ICS does NOT teach us how to implement plans… in fact ICS training largely ignores the importance of existing plans)

What of the AARs that are better and actually do recommend improved plans? This leads us to the next potential point of failure: implementation of corrective actions. I see so many organizations are simply bad at this. They seem content to exercise over and over again (typically at the expense of taxpayer dollars) and come up with the same results. They largely aren’t fixing anything, or perhaps just the proverbial low-hanging fruit (i.e. more ICS training), but they aren’t tackling the harder-to-do, yet more impactful development of quality plans.

We need to stop assuming our plans are good. Exercising bad plans has little value to us and is typically more wasteful than beneficial.

Just like the potential causes identified above, there are numerous issues to be addressed. First of all, we need to recognize that not every emergency manager has the acumen for writing plans. The development of emergency plans is a hybrid of art and science. It includes hard and soft skillsets such as technical writing, systems thinking, organization, research, collaboration, and creativity. We have standards for developing plans, such as CPG101, which overall is a good standard (though it could be improved to help people use it). We have some training available in how to develop emergency plans, but there are some issues.

  • The G-235 Emergency Planning course (now IS-235) was a great course, but the big push 15-20 years ago to put so many classroom courses online to make them more accessible and to save costs largely resulted in decreased learning outcomes.
  • The classroom training in emergency planning has largely been replaced by the E103 Planning: Emergency Operations course, which is part of the Emergency Management Basic Academy. This is a pretty good course but being part of the Basic Academy (which is a great concept) also limits access to some people as the general practice is (understandably) to give registration preference to those who are taking the entire academy. Sure, the entire academy makes for more well-rounded EMs, but if someone wants to focus on emergency planning, some of the other courses, while complimentary, constitute a larger investment of time and possibly money.
  • Finally, FEMA has the Planning Practitioner Program, which is a more intensive experience and certainly provides some improved learning outcomes, but with the expectation of a huge percentage of emergency managers (and those in related professions) to be proficient in emergency planning, this program simply isn’t available enough. (Note re training: yes, there are an abundance of other planning-related courses out there… I just highlighted these as examples).

I’ll also say that simply taking some classes does not make you a proficient emergency planner. Because there is art and science to it, it can’t simply be taught. It needs to be learned and experienced. Practice and mentorship are key – which is something else most EMs don’t have access to or even seek out. Training is not the only solution.

So, while this article started out with identifying the fallacy often seen in our exercise practices, I end up, once again, pointing out what I think is the biggest gap in the entirety of emergency management – bad plans. Plans are the foundation of our practice, yet we can’t seem to get it right. We are too dismissive of the necessity and process of plan development and upkeep. We are too accepting of inadequate plans that are not implementation ready. We don’t do enough to build personnel capability in plan development. So many of those who are writing plans, be they civil servants, consultants, or others, are simply bad at it. And while some have potential that is underdeveloped, others simply don’t have the acumen for it.

And the worst part about it all… we, as a practice and professional culture, are accepting it!

Many of my posts through the years have ended with a similar statement… we are treating emergency management like a game of beer league hockey. We aren’t taking it seriously enough. We need to do better and demand better. So what are you doing to support improved emergency planning practices?

© 2024 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Mutual Aid Preparedness

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Mutual aid is a great resource. We get help from our neighbors, or even those beyond our neighbors, providing additional numbers, capabilities, or support to aid our response to incidents and disasters. Mutual aid is mentioned in practically every emergency operations plan I’ve read, yet it’s clearly taken for granted. Most jurisdictions simply don’t have a plan for mutual aid, and most that do have a rather poor plan.

The fire service is by far the most frequent user of mutual aid. Most fire service mutual aid is for short-duration incidents, meaning that they’ve only scratched the surface in mutual aid management issues. Most fire departments don’t have their own mutual aid plans in place, instead relying on a county-based or regional plan. These also vary rather wildly in content and quality. It’s largely fine to use and be part of a county or regional plan, so long as SOMEONE is responsible for implementing the plan and all participants are familiar with it. Given issues of liability, there should also be a mutual aid agreement to which members are signatories consenting to the terms and conditions of the agreement as implemented by the plan.

The best mutual aid practitioners I’ve had experience with are utility companies, especially electric utilities. Be it hurricanes, winter storms, wildfires, or other hazards, most electric utility infrastructure is highly vulnerable to physical disruption. Even if not involved in managing or responding to an incident, we’ve all seen out-of-state utilities responding to our own areas for a major disruption, or utility trucks on the highway headed elsewhere toward a disruption. Utilities have highly detailed plans, often of their own as well as being part of regional consortiums. Those regional consortiums are then part of national-level mobilization plans. While the response details of the incident will change based on each deployment, the managers of every deployment know what to expect in terms of business operations. More strictly in the emergency management world, only the Emergency Management Assistance Compact (EMAC), used for inter-state mutual aid, is as thorough and well-used on such a large scale.

The foundation of mutual aid, regardless of duration or resources shared, is a written agreement. This is something that emergency managers and first responders have been beaten over the head with for years, yet so few actually have written agreements in place. There is no downside to having written agreements. While they may be combined into a single document, agreements and plans really should be different documents, as they have entirely different purposes. Agreements are attestations to the terms and conditions, but plans describe the means and methods. The provisions in a plan, however, may be the basis for the agreement. FEMA provides the NIMS Guideline for Mutual Aid that identifies all the necessary elements of a mutual aid agreement (and plan). The development of a mutual aid plan, just like any other emergency operations plan, should utilize FEMA’s CPG 101: Developing and Maintaining Emergency Operations Plans to guide development. Yes, many FEMA preparedness documents are actually complimentary!

So what about mutual aid planning is so important? Consider that you are having a really big pot-luck party, with hundreds of people invited. Everyone wants details of course: when should they arrive, where should they go, where should they park, how long will the party run? What food should they bring? Is there storage for cold food? How about frozen food? Are there food allergies? Is there alcohol? Are kids welcome? Will there be activities? Can I show up late? Can I show up early? What if I have to leave early? What’s the best way to get there? Are there any hotels in the area? Can I set up a tent or a camper? Can I bring my dogs? What if the weather is bad? You get the point. While most of these questions aren’t the types of questions you will get in a mutual aid operation, some actually are likely, and there will be even more! These kinds of questions are fine and manageable when it’s a few people, but when there are hundreds, it feels like asking for help is an entirely different incident to manage – that’s because it is! Of course, good planning, training, and exercises can help address a lot of this.

Mutual aid plans should address receiving AND sending mutual aid. There are dozens if not hundreds of bad stories coming from incidents like 9/11, Hurricane Katrina, and other benchmark incidents that involve poor mutual aid management – on the part of the receivers as well as those providing resources. Every agency should have policies and procedures in place about responding to mutual aid requests. There were numerous departments on 9/11 that were left non-operational because personnel responded to NYC, Shanksville, or the Pentagon, taking so many resources with them that it crippled their home department’s ability to respond. I wrote about deployment issues back in 2021.

Who will be responsible for receiving dozens or hundreds of resources if you ask for them? I’m not just talking about appointing a Staging Area Manager (something else we do VERY poorly in public safety), but is your organization prepared to receive, support, and manage all these resources? If you expect the operation to be longer than several hours, you may need to consider lodging. How about food and water? Supplies? Specialized equipment? Will you be ready to assign them, or will they languish in a Staging Area for hours? If these aren’t volunteers, who is paying them? How will reimbursement for expenses work?

What if something breaks? What if someone gets hurt? These are important questions not only from the perspective of actions to be taken, but also liability. How will you handle HR types of issues (substance abuse, harassment, etc.) involving mutual aid personnel? Are you prepared to provide these resources with critical incident stress debriefings?

How will mutual aid resources be accounted for and credentialed? What authorities, if any, will mutual aid resources have? What documentation will they be responsible for? How will you communicate with them? Do you have the essential ability to integrate them into your operations?

The bottom line is that if you invite someone to your party, you are responsible for them. It’s a matter of operational necessity, legal liability, professionalism, and respect.

What best practices have you seen when it comes to preparedness for and management of mutual aid resources?

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

A New CPG – 101 for Emergency Planning (v 3)

Tim Riecker, The Contrarian Emergency Manager 4 Comments

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

Emergency Preparedness Solutions, LLC®

ESFs Aren’t for Everyone

Tim Riecker, The Contrarian Emergency Manager 5 Comments

Through the years I’ve had numerous conversations with states, cities, and others about organizing their emergency operations plans (EOPs) around Emergency Support Functions (ESFs). In every conversation I’ve suggested against the use of ESFs. Why?

Let’s start with definitions. One definition of ESFs provided by FEMA states that ESFs ‘describe federal coordinating structures that group resources and capabilities into functional areas most frequently needed in a national response’.  Another states that ESFs are ‘a way to group functions that provide federal support to states and federal-to-federal support, both for Stafford Act declared disasters and emergencies and for non-Stafford Act incidents.’ The National Response Framework (NRF) states that ESFs are ‘response coordinating structures at the federal level’.

The key word in these definitions is ‘federal’. ESFs are a construct originally of the Federal Response Plan (FRP) which was in place from 1992 to 2004. The FRP was a signed agreement among 27 Federal departments and agencies as well as the America Red Cross that outlined how Federal assistance and resources would be provided to state and local governments during a disaster. The ESFs were carried into the National Response Plan in 2004 and the National Response Framework in 2008.

While the NRF, CPG 101, and other sources indicate that other levels of government may also organize their response structure utilizing ESFs, I think any attempts are awkward and confusing at best.

Jumping to present day, the following ESFs are identified in the NRF:

  1. Transportation
  2. Communications
  3. Public Works and Engineering
  4. Firefighting
  5. Information and Planning
  6. Mass Care, Emergency Assistance, Temporary Housing, and Human Assistance
  7. Logistics
  8. Public Health and Medical Services
  9. Search and Rescue
  10. Oil and Hazardous Materials Response
  11. Agriculture and Natural Resources
  12. Energy
  13. Public Safety and Security
  14. Cross-Sector Business and Infrastructure
  15. External Affairs

The ESFs work for the Federal government by providing organizations to address the legal, regulatory, and bureaucratic coordination that must take place across various agencies. These organizations are utilized before (preparedness), during (response and recovery… though ultimately most of these transition to the Recovery Support Functions per the National Disaster Recovery Framework), and after (AAR) a disaster as a cohesive means of maintaining relationships, continuity, and operational readiness. Each of the ESFs maintains a lead agency and has several supporting agencies which also have capabilities and responsibilities within the mission of that ESF.

Where does this fall apart for states and other jurisdictions? First of all, I view Emergency Support Function/ESF as a branded name. The ESF is a standard. When someone refers to ESFs, it’s often inferred that they are speaking of the Federal constructs. ESFs are defined by the Federal government in their current plans (presently the NRF). When co-opted by states or other jurisdictions, this is where it first starts to fall apart. This creates a type of ‘brand confusion’. i.e. Which ESFs are we speaking of? This is further exacerbated if names and definitions of their ESFs aren’t consistent with what is established by the Federal government.

Further, the utilization of ESFs may simply not be the correct tool. It may be the same agencies responsible for transportation as well as public works and engineering. So why have two teams comprised of personnel from the same agencies – especially if bench depth is small in those agencies. Related to this, I’ll say that many jurisdictions (which may even include smaller states, territories, or tribes) simply don’t have the depth to staff 15 ESFs. This is why an organization should be developed for each jurisdiction by each jurisdiction based on their needs and capabilities. It’s simply silly to try to apply the construct utilized by our rather massive Federal government to a jurisdiction much smaller.

Next, I suggest that the integration of ESFs into a response structure is simply awkward. I think in many ways this holds true for the Federal government as well. Is ESF 7 (Logistics) an emergency support function or is it a section in our EOC? The same goes for any of the other ESFs which are actually organizational components often found in response or coordination structures inspired by the Incident Command System.

All that said, the spirit of ESFs is valuable and should be utilized by other jurisdictions in other levels of government. These are often referred to as Functional Branches. Similar to ESFs, they can be used before, during, and after a disaster. Your pre-disaster planning teams become the core group implementing the plans they developed and improving the plans and associated capabilities after a disaster. As functional branches, there is no name confusion with ESFs, even though there is considerable similarity. You aren’t constrained to the list of Federal ESFs and don’t have to worry about how they define or construct them. You can do your own thing without any confusion. You are also able to build the functional branches based on your own needs and capabilities, not artificially trying to fit your needs into someone else’s construct. I’ve seen a lot of states use the term State Support Function or SSF, which is certainly fine.

I will make a nod here though to a best practice inspired by the ESFs, and that is having certain standing working groups for incident management organizational elements (i.e. communications, logistics, information and planning, and external affairs) that may not be organized under the operations section or whatever is analogous in your EOC. Expand beyond these as needed. Recall that the first step in CPG 101 for emergency planning calls for developing a planning team. There is a great deal of benefit to be had by utilizing stakeholder teams to establish standard operating guidelines, job aids, etc. in these functions or others in your EOC or other emergency organizational structure. Often it’s the emergency manager or a staff member doing this, expecting others to simply walk in and accept what has been developed. If people want to work in a Planning Section for your jurisdiction, let them own it (obviously with some input and guidance as needed).

I think ESFs are a valuable means for the US Federal government to organize, but don’t confuse the matter or develop something unnecessary by trying to carbon copy them into your jurisdiction. Examine your own needs and capabilities and form steady state working groups that become functional entities during disaster operations.

© 2021 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

A Few Thoughts on Emergency Planning

Tim Riecker, The Contrarian Emergency Manager 3 Comments

A conversation I find myself having fairly often is about people not using plans. It’s amazing that we invest so much time, money, and effort into building plans to never see them used, even if the opportunity presents itself. Why is this? I see four primary reasons:

1. People don’t know the plans exist. There is really no excuse for this one. I find it shameful and wasteful, especially if these people are identified as action agents within that plan. There was practically no point in even developing the plan no one knows about it and their respective roles identified within. Socialization of plans once they are developed is extremely important. Minimalist effort can be made by simply sending the plan or a link to the plan, but I consider this to be inadequate as many people will dismiss it, never get to reviewing it, or not understand what they are reading. Structured briefings are the best way to initially familiarize people with the plans and their roles. It helps to have refresher training as well as ensuring that new hires are similarly trained. This can even be done as a recorded presentation or webinar, though providing a contact for questions is important. Along with socializing, remember the importance of exercises, not only to validate plans but also to help people become more familiar with plans their respective roles by taking a scenario-drive dive into the content. Does everyone in your organization or jurisdiction who has a role in a plan know about it?

2. People don’t remember the plans exist. This one is a bit more forgivable, especially for newer plans, rarely implemented plans, or for personnel who are used to “doing things the way they’ve always been done”. Still, I find these excuses to be weak at best. People’s inability to remember the plans, even granting them the distraction of the incident itself, means that the plans haven’t been socialized and reinforced enough (see item 1 above).

3. People don’t care if the plans exist. This one has been underscored considerably over the past year related to pandemic plans, point of distribution (POD) plans, and other related plans. We’ve seen many senior leaders and elected officials be completely dismissive of established plans, choosing instead to “do it their way” in an effort to exert greater control or to ensure that their name is front and center. Since this one involves a lot of ego, particularly of senior leaders and elected officials, it can be difficult to work around. That said, this underscores the importance of ensuring that elected officials and newly appointed senior leaders are adequately briefed on the existing plans when they take office, and given confidence in the plans and the people identified to implement them, as well as the important roles of elected and appointed officials.

4. People think the plans are faulty. This option is the likely more well-intentioned version of #3, where people are intentionally not using the plan because they feel (maybe true, maybe not) the plan is inadequate and feel that “winging it” is the better option. Part of this lack of confidence may be unfamiliarity with and/or validation of the plans (see item 1 above re socialization and exercises). This could be a difference of opinion or even something intentionally obstructionist. Along with socialization and exercises, I’ll also add the value of including key people in the planning process. This gives them a voice at the table and allows their input to be heard and considered for development of the plan. While you can’t include everyone in the planning process, consider that the people you do choose to involve can serve as representatives or proxies for others, especially if they are well respected, giving less reason for others to push back.

A separate, but somewhat related topic (mostly to #4 above) is about people being often dismissive of or lacking confidence in plans by expressing the saying of “No plan survives first contact with the enemy”. This saying is credited to nineteenth century Prussian military commander Helmuth van Moltke. We see this saying tossed around quite a bit in various circles, including emergency management. While I understand and respect the intent of the phrase, I don’t think this necessarily holds true. I’ve seen great plans fail and mediocre plans be reasonably successful. Why? Circumstances dictate a lot of it. Implementation as well (this is the human factor). What we need to understand is that plans provide a starting point and hopefully some relevant guidance along the way. If a plan is so detailed and rigid, it is more likely to fail. So should our plans not be detailed? No, we should put as much detail as possible into our plans as these will help guide us in the midst of the incident, especially if certain activities are highly technical or process-oriented; but we also need to allow for flexibility. Consider a plan to be a highway. Highways have exits which take us off to different places, but they also have on-ramps to help us return. A deviation from a plan does not mean we throw the plan away, as we can always get back onto the plan, if it’s appropriate. It’s also smart to build in options, as possible, within our plans to help minimize deviations. 

How we develop plans is strongly related to step 2 of CPG-101, and that is “Understand the Situation”. Without an understanding of the situation, we can’t account for the various factors involved and may not account for the circumstances for which we must develop contingencies or options. And while this assessment is part of the planning process, as well as training, exercises, and other facets of preparedness, I feel that a wholistic assessment also has value. I’ve written a lot about the POETE preparedness elements and have begun advocating for APOETE, with the A standing for Assessment. This assessment is broad based to help guide our overall preparedness activity but is not a replacement for the element-specific assessments.

My last thought is about pandemic and POD plans. I’m curious about who has used their plans during this pandemic, and if not, why not? Of course many of the assumptions we used for pandemic planning weren’t realized in this pandemic. Does this mean our pandemic plans were faulty? Not entirely. Clearly there should have been many content areas that were still useful, and even though some of the assumptions we had didn’t apply to this pandemic, they may still hold true for future public health emergencies. We’ve also learned a lot about our response that needs to be considered for plan updates, and we need to weigh how much of the reality of political blundering we should account for in our plans. In the end, what I caution against is developing a pandemic plan that centers on the COVID-19 pandemic. Preparing for the last disaster doesn’t necessarily prepare us for the next one.

Those are some of my thoughts for the morning. As always, I welcome your thoughts and feedback.

© 2021 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

A New CPG 101 Draft

Tim Riecker, The Contrarian Emergency Manager 3 Comments

About a year ago, FEMA distributed a draft revision of Community Preparedness Guide 101: Developing and Maintaining Emergency Operations Plans (CPG 101). Since then we hadn’t heard much about the update progress, until yesterday. This latest draft, including in formation on how you can provide feedback, can be found here.

This latest draft incorporates some newer policies and programs not included in last year’s revision. I was pleased to see that some of the items from my feedback (and I’m certain from many others) was integrated into this draft. Some parts of the document were expanded or restructured, while other aspects were appropriately reduced (like excessive reiteration of national-level plans). It’s a much better draft than the one we saw a year ago. That said, there are some changes I’d still like to see.

Perhaps it was simply because this document is a draft, but a number of the graphics they have reused from other documents were grainy and low resolution. Clearly, they should have access to the source files for those graphics. If not, they need to redevelop them.  Aside from that aesthetic feedback, I’d like to see the document written less doctrinal and more as a tool – especially considering that most people referencing the document are likely to be less experienced planners. The document needs more references, job aids, and best practices identified. This draft does include quite a number of checklists, but those are only integrated within the text of the document. I feel those should also be included as an attachment that planners can ‘pull out’ of the main document and use as their primary reference. I’d also like to see clearer connections with other doctrine, policy, and practices, such as NIMS, THIRA, Community Lifelines, integrated preparedness plans, etc. While most of these are identified in the document, the contextualization needs to be amplified, reinforcing that these aren’t necessarily all ‘standalone’ applications or practices; that they are best utilized when specific linkages can be identified and exploited. It’s the utility for less experienced planners that I feel most strongly about.

All that said, I’m hopeful we don’t have to wait another year for this draft to become an official next version of CPG 101.

What do you think of this draft? What do you want to see included in CPG101?

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

EOC Mission Planning

Tim Riecker, The Contrarian Emergency Manager 1 Comment

I’ve been wrong. I used to teach and otherwise espouse that emergency operations centers didn’t actually do operations. I was bought in to the traditional perspective that EOCs ONLY provided resource support and information coordination. I’m not sure how or why I bought into this when on incidents I was actually involved in planning and directing certain operations. This mentality goes back, for me, about 15 years. It’s important to break this myth and acknowledge the role that EOCs can and should play in incident management.  

EOCs being involved in directing field operations is certainly nothing new. If you don’t want to take my word for it, it’s also doctrinal. Check out the EOC section of the NIMS document. “EOC staff may share the load with on-scene incident personnel by managing certain operations, such as emergency shelters or points of distribution. When on-scene incident command is not established, such as in a snow emergency, staff in EOCs may direct tactical operations.”

This post has been in the works for a while. Several months ago, I was developing structured guidance on EOC mission planning for a client and realized it would be a good topic to write about. I recently made some social media posts on the topic, with responses encouraging me to write more. So, it was clearly time to do so.

As I had posted on social media, if you don’t think an EOC actually does operations, I’d suggest that the EOCs you are familiar with either haven’t had the opportunity to properly apply mission support or they are doing something wrong. Certainly not every incident will require an EOC to provide mission support, but EOCs should be ready to do so.

EOC missions are typically initiated one of three ways:

  1. A request by incident command to handle a matter which is outside their present area of responsibility or capability,
  2. EOC personnel recognize an operational need that isn’t being addressed, or
  3. The EOC is directed to take certain action from an executive level.

As the NIMS doctrine states, operations that are prime candidates for EOC-directed missions could be emergency shelters or points of distribution. Other operations, such as debris management, or (something recently experienced by many jurisdictions) isolation and quarantine operations are also often EOC-directed.

What makes these EOC-directed missions? Typically, they are planned, executed, and managed by an EOC. This could be a multi-agency EOC or a departmental operations center. Of course, there are ‘field’ personnel involved to execute the missions, but unlike tactical activity under the command of an Incident Commander, the chain of command for EOC-directed missions goes to the EOC (typically the EOC’s Operations Section or equivalent).

Ideally, jurisdictions or agencies should be developing deliberate plans for EOC-directed missions. Many do, yet still don’t realize that execution of the plans is managed from the EOC. These are often functional or specifically emergency support function (ESF) plans or components of those plans. For context, consider a debris management plan. As with many deliberate plans, those plans typically need to be operationalized, meaning that the specific circumstances of the incident they are being applied to must be accounted for, typically through what I refer to as a mission plan. In developing a mission plan, with or without the existence of a deliberate plan, I encourage EOCs to use the 6-step planning process outlined in CPG-101. As a refresher:

  1. Form a planning team
  2. Understand the situation and intent of the plan
  3. Determine goals and objectives of the plan
  4. Develop the plan
  5. Plan review and approval
  6. Plan implementation

The planning team for an EOC-driven mission should consist, at the very least, of personnel in the EOC with responsibility for planning and operations. If several mission plans are expected to be developed, the EOC’s Planning Section may consider developing a ‘Mission Planning Unit’ or something similar. Depending on the technical aspects of the mission, technical specialists may be brought into the planning team, and it’s likely that personnel with responsibility for logistics, finance, and safety, may need to be consulted as well.

If a deliberate plan is already in place, that plan should help support the intent, goals, and objectives of the mission plan, with a need to apply specific situational information and context to develop the mission plan.

Developing the plan must be comprehensive to account for all personnel, facilities, resources, operational parameters, safety, support, reporting, documentation, and chain of command. These may need to be highly detailed to support implementation. The mission may be organized at whatever organizational level is appropriate to the incident. This is likely to be a group within EOC Operations (or equivalent). Obviously having a deliberate plan in place can help address a fair amount of this proactively. Outlining processes and position descriptions, and providing job aids will support implementation considerably.

Plan review often seems an easy thing to do, but this needs to be more than an editorial review. The review should be comprehensive, considering the operations from every possible perspective. Consider various scenarios, notionally walking through processes, and even using a red team concept to validate the plan. While this is likely going into immediate implementation, it’s best to spend some time validating it in the review stages instead of having it fail in implementation. Approval will come at whatever level is appropriate within your organization.

Plan implementation should certainly include an operational briefing for the staff executing the plan, and it should ideally be supported through an incident action plan (IAP) or EOC action plan, or a part thereof. As with any implementation, it needs to be properly managed, meaning that progress must be monitored and feedback provided to ensure that the mission is being executed according to plan and that the plan itself is effective. Understand that complex missions, especially those of longer duration, may need to be adjusted as lessons are learned during implementation.

As is typically said in ICS courses, we should begin demobilization planning as early as possible. Missions may have a completion in whole, where the entire mission is demobilized at once, or there may be a phased demobilization. Many EOCs aren’t used to developing tactical-level demobilization plans, so they need to be prepared for this.

As with any operation, identifying and documenting lessons learned is important. Deliberate plans should be updated to reflect lessons learned (and even a copy of the mission plan as a template or sample), or if a deliberate plan didn’t exist prior to the mission, one should be developed based upon the implementation.

EOCs can, in fact, run operations. I’m sure a lot of you have seen this if you have been involved in responses such as the current Coronavirus pandemic, a hurricane response, and more. Sometimes in emergency management we aren’t good at actually acknowledging what’s going on, for better or for worse. We get stuck with old definitions and don’t realize that we need to evolve, or even already have evolved; or we don’t recognize that current ways of doing things simply don’t work as intended. We seem, sometimes, to be our own worst enemy.

How does your EOC execute mission planning?

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Thoughts on How to Improve the Planning Standard

Tim Riecker, The Contrarian Emergency Manager Leave a comment

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

Emergency Preparedness Solutions, LLC®℠

 

A New CPG-101 is Coming

Tim Riecker, The Contrarian Emergency Manager 4 Comments

FEMA has recently announced an upcoming update to CPG-101.  CPG-101 is short hand for the “Community Preparedness Guide 101: Developing and Maintaining Emergency Operations Plans” document.  CPG 101 is a legacy document, which through its own versions and previous iterations has for decades has served as the standard guidance for emergency operations planning in the US.  The last update to CPG 101 was released in November of 2010.  That update introduced some best practices and lessons learned of the time, but with more recent changes to NIMS, better inclusion of EOC structures and function, the addition of Community Lifelines, updates to the National Preparedness Goal, National Response Plan, National Recovery Plan, and other lessons learned and best practices realized, an update to CPG 101 will be significant.  If you are looking for more information on CPG 101, here are a few articles I’ve written that reference it.

FEMA is soliciting input through direct feedback and a series of webinars.  Information on that can be found here: https://www.fema.gov/plan.  The deadline for feedback is January 14, 2020.  I heavily encourage participation in this effort by stakeholders across all of emergency management, public safety, and homeland security.

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