A Few Thoughts on Emergency Planning

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

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

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

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

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.

  • TR

EOC Management Organization

FEMA recently released a draft Operational Period Shift Brief Template for EOCs, open to public comment.  The document is fine, though there was one glaring issue… it assumes an ICS-based model is in use in the EOC.

With the release of the NIMS refresh, we were given some ‘official’ options for EOC management structures.  Unfortunately, we aren’t seeing much material that supports anything other than an ICS-based structure.  An ICS-based structure may certainly be fine, but every organization should examine their own needs to identify what works best for them.  Story time…

We recently completed a contract that included the development of a plan for a departmental operations center for a state agency.  The plan had to accommodate several considerations, including interaction with regional offices and operations, interaction with the State EOC, and integration of a call center.  When we talked to people, examined form and function, and looked at fundamental needs, the end result was an ICS-based organization.  While accommodations had to be made for translating their own agency structure and mission, it fit rather well.

For a contract we are currently working on, we are developing an EOC plan for a private utility.  Again, we reviewed documents, talked to people, and identified the fundamental needs of the company and the EOC organization.  The end result is shaking out to be something a little different.  At a glance, it’s largely ICS-based, but has some aspects of the Incident Support Model, while also having its own unique twists.  One particular observation was that their company’s daily structure has functions combined that we would normally break up in traditional ICS.  Breaking these functions up for an incident would be awkward, disruptive, and frankly, rather absurd.  Not only would personnel be dealing with something out of the ordinary, they would be changing the flow of corporate elements that have been placed together by necessity in their daily operations, which would detract from their efficiency during the incident.

My third example is a contract we are just getting started on.  This project involves developing an EOC plan for a municipality.  While we’ve had some initial discussions, we aren’t sure what the end result will be just yet.  The client isn’t set on any particular structure and is open to the process of discovery that we will be embarking on.  As I’ve thought about their circumstances and the recent and current work we’ve done on this topic, there are a few things that have come to mind.

  1. While NIMS is all about standardization and interoperability, the range of utility of emergency operations centers, in any form, and the mission, organization, an innate bureaucracy of the ‘home agency’ have a heavy influence on what the EOC’s organization will look like.
  2. While there still should be some standard elements to an EOC’s organization, there is generally less fluidity to the composition of an EOC, especially as it compares to a field-level incident command where the composition of the responding cadre of organizations can radically differ.
  3. Consider the doctrinal core concepts of ICS as really core concepts of incident management, thus we can apply them to any structure. These concepts are fundamental and should exist regardless of the organization used.  Some examples…
    1. Unity of Command
    2. Modular organization
    3. Manageable span of control
    4. Consolidated action plans
    5. Comprehensive resource management
  4. We need to acknowledge that the full benefit of organization standardization, exhibited by the ability of incident management personnel to be assigned to a new EOC and be able to immediately function, is potentially compromised to an extent, but that can be largely mitigated by adherence to the core concepts of ICS as mentioned previous. Why?  Because the system and processes of incident management are still largely the same.  These new personnel need just a bit of an orientation to the organizational structure being used (particularly if they are to be assigned in a leadership capacity at any level).

The most important consideration is to develop a plan.  That will provide extensive benefit, especially when done properly.  Follow the CPG 101 guidance, build a team, do some research, and weigh all options.  The end goal is to identify an organizational structure that will work for you, not one that you need to be forced into.  Bringing this around full circle, we need to know that with whatever system you decide to use, expect that you will need to develop your own training, job aids, and other support mechanisms since they largely don’t exist for anything outside of an ICS-based structure.  Note that even for an ICS-based model, there are needs… consider that there is no ‘official’ planning P for EOCs (one that is less tactics-focused), and, of course, that ICS training alone isn’t enough to run your EOC by.

I don’t place any blame for this need… consider that FEMA, with finite resources just like the rest of us, tries to produce things that are of the greatest utility to as much of the nation as possible, and right now, most EOCs are run on an ICS-based model.  While I hope this will expand over time, every entity will still be responsible for developing their own training on how they will organize and respond.  No training developed by a third party for a mass audience can ever replace the value of training designed specifically to address your plans.

I’m interested in hearing what changes are being made to your EOC organizations and how you are addressing needs.

© 2019 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Preparedness: Integrating Community Lifeline Considerations

Much of preparedness is about getting us ready to conduct situational assessment and prioritization of actions.  We train people and develop resources, such as drones, field-deployed apps, and geographic information systems (GIS) to support situational assessment.  The information we obtain from these assessments help in the development and maintenance of situational awareness and, when shared across disciplines, agencies, and jurisdictions, a common operating picture.  Based upon this information, leaders at all levels make decisions.  These decisions often involve the prioritization of our response and recovery actions.  Ideally, we should have plans in place that establish standards for how we collect, analyze, and share information, and also to support the decision making we must do in prioritizing our actions.  Exercises, of course, help us to validate those plans and practice associated tasks.

One significant hurdle for us is how overwhelming disasters can be.  With just slight increases in the complexity of a disaster, we experience factors such as large geography, extensive damages, high numbers of lives at risk, hazardous materials, and others.  Certainly, we know from Incident Command System training that our broad priorities are life safety, incident stabilization, and property conservation – but with all that’s happening, where do we start?

One thing that can help us both assessment and prioritization are community lifelines.  From FEMA: “Community lifelines reframe incident information to provide decision-makers with impact statements and root causes.”  By changing how we frame our data collection, analysis, thinking, and decision-making, we can maximize the effectiveness of our efforts.  This shouldn’t necessitate a change in our processes, but we should incorporate community lifelines into our preparedness activities.

The community lifelines, as identified by FEMA, are:

  • Safety and Security
  • Food, Water, and Sheltering
  • Health and Medical
  • Energy
  • Communications
  • Transportation
  • Hazardous Materials

If this is your first time looking at community lifelines, they certainly shouldn’t be so foreign to you.  In many ways, these are identified components of our critical infrastructure.  By focusing our attention on this list of items, we can affect a more concerted response and recovery.

FEMA guidance goes on to identify essential elements of information (EEI) we should be examining for each community lifeline.  For example, the lifeline of Health and Medical includes the EEIs of:

  • Medical Care
  • Patient Movement
  • Public Health
  • Fatality Management
  • Health Care Supply Chain

Of course, you can dig even deeper when analyzing any of these EEIs to identify the status and root cause of failure, which will then support the prioritization of actions to address the identified failures.  First we seek to stabilize, then restore.  For example, within just the EEI of Fatality Management, you can examine components such as:

  • Mortuary and post-mortuary services
  • Transportation, storage, and disposal resources
  • Body recovery and processing
  • Family assistance

The organization of situation reports, particularly those shared with the media, public, and other external partners might benefit from being organized by community lifelines.  These are concepts that are generally tangible to many people, and highlight many of the top factors we examine in emergency management.

Back in March of this year, FEMA released the Community Lifelines Implementation Toolkit, which provides some great information on the lifelines and some information on how to integrate them into your preparedness.  These can go a long way, but I’d also like to see some more direct application as an addendum to CPG-101 to demonstrate how community lifelines can be integrated into planning.  Further, while I understanding that FEMA is using the community lifeline concept for its own assessments and reporting, the community aspect of these should be better emphasized, and as such identifying some of the very FEMA- and IMAT-centric materials on this page as being mostly for federal application.

Has your jurisdiction already integrated community lifelines into your preparedness?  What best practices have you identified?

© 2019 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC℠®

Airport Emergency Planning

Through my career I’ve had the opportunity to work with a number of airports on preparedness efforts.  In the past couple of years, that interaction has been greatly amplified through a contract my company successfully completed involving the development of exercises for airports.  As part of this effort, we designed, conducted, and evaluated exercises at ten airports of varying sizes across the nation, from Georgia to Alaska, Massachusetts to California.  Since the primary intent of exercises is to validate plans, we of course requested and reviewed airport emergency plans (AEPs) from each location as part of our preparation for each exercise.

For those not in the know, the requirement for AEPs originates with Federal Aviation Regulation 14 CFR Part 139, which wholly establishes the standards for the certification of airports.  The requirements for AEPs are further refined in DOT/FAA Advisory Circular 150-5200-31C published in May of 2010.   The Advisory Circular is largely implementation guidance.  It’s quite comprehensive and outlines a planning structure, references emergency management doctrine and standards of practice such as NIMS and the National Response Framework, and models a planning process, which mirrors that of CPG-101.  The NFPA also provides guidance in NFPA 424: Guide for Airport/Community Emergency Planning, which reflects on all these as well.

Just like any community emergency operations plan (EOP), AEPs I’ve reviewed run the full spectrum of quality.  Some plans are thorough and comprehensive, while other plans are so focused on meeting the letter of the regulation that they fall short of meeting real needs and being implementation-ready, even though they technically meet the requirements set forth in §139.325.  Regulated industries, which airports largely are, often have a challenge when it comes to emergency planning.  We see this same challenge in radiological emergency plans as well.  The laws and regulations seem to provide so much structure that it is perceived that local variables and subjective analysis aren’t allowed.  As an example, §139.325 states:

“the plan must contain instructions for response to:

  1. Aircraft incident and accidents
  2. Bomb incidents, including designation of parking areas for the aircraft involved
  3. Structural fires
  4. Fires at fuel farms or fuel storage areas
  5. Natural disaster
  6. Hazardous materials/dangerous goods incidents
  7. Sabotage, hijack, or other unlawful interference with operations
  8. Failure of power for movement area lighting
  9. Water rescue situations (as appropriate)”

While the planning process isn’t prescribed in §139.325, nor does it specify if other hazards can be included in the AEP, the Advisory Circular (AC) does expound on this and prescribes a planning process, including a hazard analysis.  The AC states “Through the hazards analysis program, guidance has been provided to assist in the identification of those hazards and disasters specific to an airport that warrant planning attention”.  That phrasing indicates that airports should be planning for hazards beyond what is required by §139.325, yet I’ve seen many that do not.

Obviously ‘natural disaster’ covers a considerable amount of proverbial territory.  Jurisdictions undergo extensive hazard analysis and hazard mitigation planning to identify the breadth and scope of these hazards (which should include all hazards, not just natural disasters).   Many jurisdictions develop very comprehensive EOPs and annexes to address the response needs of each of their primary hazards.  I saw this as a significantly missing component in many AEPs, which treated ‘natural disasters’ as a single hazard.  Further, as many airports stick to the minimum requirement for planning, they fail to address other hazards which could impact them, ranging from dam failure, and nuclear power facility incidents, to currently hot topics such as active shooter/hostile event response (ASHER) and communicable diseases.

Some airports have thankfully recognized the need for expanding beyond the required hazards and have developed plans that better address all of their needs.  On the unfortunate side, again as a regulated industry, I’ve also seen some airports having two sets of plans… one that meets regulation and the other that they feel is more practical for implementation.  Clearly this isn’t the way to go either.  A single, consolidated plan can be developed that meets all needs.

Airports are an interesting animal.  Regardless of governance structure, they are part of the communities which surround them.  Larger airports are also communities of their own, having significant capability, sometimes more than the surrounding jurisdictions.  Airport emergency planning should acknowledge and involve their community relationships and must address all hazards, not just the ones required by Part 139.  Just as with any other type of emergency plan, they must be implementation-ready.  To do so typically requires the added development of standard operating guidelines (SOGs) and job aids, such as check lists and forms.  Plans should also be developed to address recovery issues and business continuity, not just response.  An airport, regardless of governance structure, operates like a business, with many other stakeholders dependent upon their stability and ability to address and rapidly recover from incidents.  They are also obviously transportation hubs, dealing with large volumes of people and significant dollar figures in freight and commerce.

Airport emergency managers have many of the same challenges as the emergency managers of any other community.  Staffing and funding rarely line up with requirements and other priority matters.  I encourage community emergency managers to reach out to their local airports and coordinate, as many hands make easier work for everyone.  Of course, if any airports are seeking assistance in enhancing their preparedness, please contact us as we would love to work with you!

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC™

 

 

Pre-Disaster Recovery Planning Guidance

So much of preparedness focuses on the Response mission area, which is necessary, given the need to protect life and property in the immediate aftermath of a disaster; but we should never leave disaster recovery by the way side.  I’ve blogged in the past about the significant lack of Recovery mission area exercises we typically see, but we shouldn’t forget that the foundation of preparedness is planning.  How does your pre-disaster recovery plan look?

If jurisdictions have a pre-disaster recovery plan at all (and I mean beyond two paragraphs in their comprehensive emergency management plan), it’s typically focused on debris management.  This isn’t without good cause.  Debris management is incredibly complex, has a lot of benchmarks to follow in terms of best practices, and must include all of FEMA’s requirements, which largely stem from lessons learned in debris management.  Having a debris management plan in place can also qualify a jurisdiction to receive a higher percentage of reimbursement.  That said, debris management isn’t the only aspect of recovery that must be planned for.

FEMA recently released the Pre-Disaster Recovery Planning Guide for State Governments (November 2016).  I’ll admit, the first thing I looked for in the document were references to CPG-101, which is FEMA’s established standard for planning.  I was thrilled to find that it’s not only mentioned, but much of the document is based upon CPG-101.  Found in the document’s early narrative are topics such as the importance of aligning disaster recovery with hazard mitigation, as well as aligning disaster recovery with response.  These are two important factors which make disaster recovery even more complex, as disaster recovery is clearly not only an end state itself, but also a bridge between response and mitigation.

The document also outlines the differences and similarities between pre-disaster recovery planning and post-disaster recovery planning.  Another important distinction.  Many give the excuse of not having a vigorous pre-disaster recovery plan because there are too many unknown variables to anticipate and plan for.  I usually throw my bullshit flag on this statement.  While there is some truth to the statement, it’s also a convenient excuse.  For the same reasons why we create emergency operations plans before a disaster ever strikes, we must develop recovery plans before a disaster strikes.  While there are unknowns, there are also many solid assumptions we can make for the foundation of our planning.  We can identify key activities, assign responsibility, and work toward identifying gaps and building capability and capacity.  Once a disaster does occur, we then pull people out of the response to begin drawing up more specific plans for disaster recovery, hopefully capitalizing on our pre-disaster planning efforts.

Much of the document is a breakdown of CPG-101 planning steps in the context of disaster recovery.  They give some great examples and references throughout the document.  From my quick review, this is a pretty solid document.  While the intended audience is state government, I see easy applicability of this document to most, if not all, local governments – so long as it’s approached with a scaled perspective.

I’m very pleased that FEMA continues to tie preparedness standards together, doing away with decades long practices of response-oriented preparedness tasks being handled one way, while the tasks of other mission areas are handled very differently.  Across the whole spectrum of preparedness, in consideration of every mission area and each of the POETE elements, we need to start identifying critical intersections which will help us capitalize on efforts.  We need to do away with the isolation and siloing of these, and begin working more collaboratively.  From this, we will see greater success.

Consume and ponder.  Feedback is always appreciated.

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Do We Need Different Systems for Catastrophic Incidents?

We’ve long heard, albeit in small pockets, people proclaiming that emergency management and public safety need different systems for larger incidents vs smaller incidents.  For years, the Incident Command System (ICS) fought that stigma, with many saying that ICS is only used for hazardous materials incidents (specifically because of OSHA requirements) or for large incidents that required such a high degree of organization.  Following the release of HSPD-5 and the resultant requirements for everyone to use the National Incident Management System (NIMS), we finally seemed to transcend that mentality – although we are still seeing people apply ICS poorly, and often with the thought that it will all work out fine when a large incident occurs.

Since the mid-2000s, coupled with the push for ‘catastrophic planning’, I’ve been hearing people proclaiming that catastrophic incidents require different systems – be it for planning or management.  Recently, I’m hearing this mentioned again.  Yet, interestingly enough, none of the arguments identify specifically what it is about our current systems of preparedness or incident management that fail at the sight of a catastrophic incident.

While I’m a critic of various aspects of our current systems, I’m a believer in them overall.  Do we need a new system of planning?  No, we just need to do it better.  When we plan for a catastrophic level event, we must consider that NOTHING will work in the aftermath of such an incident.  I’m shocked that some people are still counting on the existence and functionality of critical infrastructure following a catastrophic event.  No roads, no communications, no life lines.  These surprised disclosures are revealed in the After Action Reports (AARs) of incidents and exercises that test catastrophic incidents, such as the recent Cascadia Rising exercise.

Fundamentally, are these losses all that different than what we experience in smaller disasters?  Not so much.  Smaller disasters still take out our roads and disable our communications systems – but such disasters are small enough that we can work around these issues.  So how is it a surprise that a large hurricane or earthquake will do even more damage?  It really shouldn’t be.  It’s essentially a matter of scale.

That said, I certainly acknowledge the difficulties that come with the combined impacts of a catastrophic disaster, coupled with the sheer magnitude of it all.  There are challenges offered that we don’t normally see, but a new system of planning is not the answer.  The current frameworks and standards, such as CPG-101 and NFPA 1600 are absolutely substantial.  The processes are not flawed.  The issue is a human one.  We can’t blame the standards.  We can’t blame the plans.  The responsibility lies with the people at the table crafting the plan.  The responsibility lies with them to fully understand the hazards and the potential impacts of those hazards.  Conducting a hazard analysis is the first step for a planning team to accomplish, and I think this is often taken for granted.  While the traditional hazard analysis has value, the current standard is the Threat and Hazard Identification and Risk Assessment (THIRA).  It is an exhausting and detailed process, but it is highly effective, with engaged teams, to reveal the nature and impacts of disasters that can impact a community.  Without a solid and realistic understanding of hazards, including those that can attain catastrophic levels, WE WILL FAIL.  It’s that simple.

As we progress through the planning process and identify strategies to accomplish objectives, alternate strategies must be developed to address full failures of infrastructure and lack of resources.  Assumptions are often made in plans that we will be able to apply the resources we have to fix problems; and if those resources are exhausted, we will ask for more, which will magically appear, thus solving our problems.  Yes, this works most of the time, but in a catastrophic incident, this is pure bullshit.  This assumption needs to be taken off the table when catastrophic incidents are concerned.  The scarcity of resources is an immediate factor that we need to address along with acknowledging that a severely damaged infrastructure forces us out of many of the technological and logistical comforts we have become accustomed to.  It doesn’t require a new system of planning – just a realistic mentality.

This all logically ties to our incident management system – ICS.  ICS is fully able to accommodate a catastrophic-level incident.  The difficulties we face are with how we apply it (another human factor) and integration of multiple ICS organizations and other incident management entities, such as EOCs.  The tenant in ICS is that one incident gets one incident command system structure.  This is obviously not a geo-political or practical reality for a catastrophic incident that can have a large footprint.  This, however, doesn’t mean that we throw ICS out the window.  This is a reality that we deal with even on smaller disasters, where different jurisdictions, agencies, organizations, and levels of government all have their own management system established during a disaster.  Through implementations such as unified command, multi-agency coordination, agency representatives and liaison officers, and good lines of communication we are able to make effective coordination happen.  (Side note: this is absolutely something I think we need to plan for and tighten up conceptually.  It’s often pulled together a bit too ad-hoc for my comfort).

While some time and effort needs to be applied to develop some solid solutions to the issues that exist, I’m confident that we DO NOT need to create alternate preparedness or response systems for addressing catastrophic incidents – we simply need to apply what we have better and with a more realistic perspective.  The answers won’t come easy and the solutions might be less than ideal, but that’s the nature of a catastrophic event.  We can’t expect it to be easy or convenient.

© 2016 – Timothy Riecker, CEDP

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