Tag CPG 201

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®℠

 

Preparedness: Integrating Community Lifeline Considerations

Tim Riecker, The Contrarian Emergency Manager 2 Comments

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℠®

An Updated Comprehensive Preparedness Guide 201 (THIRA/SPR)

Tim Riecker, The Contrarian Emergency Manager 1 Comment

In late May, FEMA/DHS released an updated version of Comprehensive Preparedness Guide (CPG) 201.  For those not familiar, CPG 201 is designed to guide communities and organizations through the process of the Threat and Hazard Identification and Risk Assessment (THIRA).  This is the third edition of a document that was originally released in April 2012.  This third edition integrates the Stakeholder Preparedness Review (SPR) into the process.  Note that ‘SPR’ has commonly been an acronym for State Preparedness Report, which is also associated with the THIRA.  The goal of the Stakeholder Preparedness Review appears to be fundamentally similar to that of the State Preparedness Report which some of you may be familiar with.

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First of all, a few noted changes in the THIRA portion of CPG 201.  First, FEMA now recommends that communities complete the THIRA every three years instead of annually.  Given the complexity and depth of a properly executed THIRA, this makes much more sense and I fully applaud this change.  Over the past several years many jurisdictions have watered down the process because it was so time consuming, with many THIRAs completed being more of an update to the previous year’s than really being a new independent assessment.  While it’s always good to reflect on the progress relative to the previous year, it’s human nature to get stuck in the box created by your reference material, so I think the annual assessment also stagnated progress in many areas.

The other big change to the THIRA process is elimination of the fourth step (Apply Results).  Along with some other streamlining of activities within the THIRA process, the application of results has been extended into the SPR process.  The goal of the SPR is to assess the community’s capability levels based on the capability targets identified in the THIRA.  Despite the THIRA being changed to a three-year cycle, CPG 201 states that the SPR should be conducted annually.  Since capabilities are more prone to change (often through deliberate activities of communities) this absolutely makes sense. The SPR process centers on three main activities, all informed by the THIRA:

  1. Assess Capabilities
  2. Identify and Address Gaps
  3. Describe Impacts and Funding Sources

The assessment of capabilities is intended to be a legacy function, with the first assessment establishing a baseline, which is then continually reflected on in subsequent years.  The capability assessment contributes to needs identification for a community, which is then further analyzed for the impacts of that change in capability and the identification of funding sources to sustain or improve capabilities, as needed.

An aspect of this new document which I’m excited about is that the POETE analysis is finally firmly established in doctrine.  If you aren’t familiar with the POETE analysis, you can find a few articles I’ve written on it here.  POETE is reflected on several times in the SPR process.

So who should be doing this?   The document references all the usual suspects: state, local, tribal, territorial, and UASI jurisdictions.  I think it’s great that everyone is being encouraged to do this, but we also need to identify who must do it.  Traditionally, the state preparedness report was required of states, territories, and UASIs as the initial recipients of Homeland Security Grant Program (HSGP) sub-grants.  In 2018, recipients of Tribal Homeland Security Grant Program funds will be required to complete this as well.  While other jurisdictions seem to be encouraged to use the processes of CPG 201, they aren’t being empowered to do so.

Here lies my biggest criticism…  as stated earlier, the THIRA and SPR processes are quite in-depth and the guidance provided in CPG 201 is supported by an assessment tool designed by FEMA for these purposes.  The CPG 201 website unfortunately does not include the tool, nor does CPG 201 itself even make direct reference to it.  There are vague indirect references, seeming to indicate what kind of data can be used in certain steps, but never actually stating that a tool is available.  The tool, called the Universal Reporting Tool, provides structure to the great deal of information being collected and analyzed through these processes.  Refined over the past several years as the THIRA/SPR process has evolved, the Universal Reporting Tool is a great way to complete this.  As part of the State Preparedness Report, the completed tool was submitted to the FEMA regional office who would provide feedback and submit it to HQ to contribute to the National Preparedness Report.  But what of the jurisdictions who are not required to do this and wish to do this of their own accord?  It doesn’t seem to be discouraged, as jurisdictions can request a copy from FEMA-SPR@fema.dhs.gov, but it seems that as a best practice, as well as a companion to CPG 201, the tool should be directly available on the FEMA website.  That said, if the THIRA/SPR is being conducted by a jurisdiction not required to do so, the tool would then not be required – although it would help.

Overall, I’m very happy with this evolution of CPG 201.  It’s clear that FEMA is paying attention to feedback received on the process to streamline it as best they can, while maximizing the utility of the data derived from the analysis.  A completed THIRA/SPR is an excellent foundation for planning and grant funding requests, and can inform training needs assessments and exercise program management (it should be used as a direct reference to development of a Training and Exercise Plan).

For those interested, EPS’ personnel have experience conducting the THIRA/SPR process in past years for a variety of jurisdictions and would be happy to assist yours with this updated process.  Head to the link below for more information!

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC ™

The POETE Analysis – Emergency Planning and Beyond

Tim Riecker, The Contrarian Emergency Manager 5 Comments

POETE stands for Planning, Organizing, Equipping, Training, and Exercising. These are the five elements that each jurisdiction should be examining their own capabilities by. By examining their capabilities through each of these elements, a jurisdiction can better define their strengths and areas for improvement.

The POETE analysis, often completed as part of a THIRA (Threat and Hazard Identification and Risk Assessment) is actually a component of the State Preparedness Report (SPR), which incorporates THIRA data into this annual submission. When properly conducted, a POETE analysis will examine a jurisdiction’s capability targets. These capability targets, through the THIRA process, are individually defined by each jurisdiction, based upon the capability definitions of each of the 31 Core Capabilities. The Core Capabilities were identified in the National Preparedness Goal and are an evolution of the legacy Target Capabilities. Gone are the days when many jurisdictions struggled with the definitions of the Target Capabilities and trying to determine how they applied to jurisdictions large and small across the nation. The new Core Capabilities are divided amongst five mission areas – Prevention, Protection, Response, Recovery, and Mitigation. By referencing Core Capabilities in our preparedness efforts, we have a consistent definition of each area of practice.

When a jurisdiction’s stakeholders conduct a POETE analysis, each element is rated on a scale of 1 to 5 – a rating of 5 indicating that the jurisdiction has all the resources needed and has accomplished all activities necessary for that element within that capability area. Using the Core Capability of Fatality Management as an example the jurisdiction will identify a desired outcome and from that a capability target. CPG-201, the guidance published by DHS/FEMA for conducting a THIRA, outlines this process in detail and provides the following capability target for illustrative purposes:

“During the first 72 hours of an incident, conduct operations to recover 375 fatalities.”

The jurisdiction will examine their efforts and resources for each POETE element for this capability target. Below are thoughts on what could be considered for each element:

Planning: What is the state of their plans for mass fatality management? Do they have a plan? Is it up to date? Does it address best practices?

Organizing: Are all stakeholders on board with mass fatality preparedness efforts? Is there a member of the community yet to be engaged? Are lines of authority during a mass fatality incident clear?

Equipping: Does the jurisdiction have the equipment and supplies available to handle the needs of a mass fatality incident? Are MOUs and contracts in place?

Training: Do responders and stakeholders train regularly on the tasks associated with managing a mass fatality incident? Is training up to date? Is training conducted at the appropriate level?

Exercising: Have exercises been conducted recently to test the plans and familiarize stakeholders with plans and equipment? Has the jurisdiction conducted discussion-based and operations-based exercises? Have identified areas for improvement been addressed?

The jurisdiction’s responses to these questions and the subsequent ratings provided for each POETE element will help them identify areas for improvement which will contribute to the overall capability. From personal experience, I can tell you that the discussions that take place amongst stakeholders which reveal both the efforts applied for each element as well as the frustrations and barriers to progress for each are generally quite productive and great information sharing sessions. It is important to capture as many of the factual elements of this discussion as possible as they add context to the numerical value assigned. Having the right people participating in the effort is critical to ensuring that inputs are accurate and relevant.

Once the POETE analysis is completed, what’s next? As mentioned earlier, the POETE analysis is actually a required component of the annual State Preparedness Report, which must be submitted to FEMA/DHS by each state and territory. Ideally, the results of the POETE analysis should be translated from raw data (numbers) to a narrative, explaining the progress and accomplishments as well as future efforts and barriers; in other words, the ratings should be factually explained and these explanations should feed an actionable strategic plan. The priority rating inherent in the THIRA process will help establish relative priority for each Core Capability within the strategic plan. While this is a requirement for states and territories, a comprehensive strategic plan for any emergency management and homeland security program at any jurisdictional level is obviously beneficial and would reflect positively in an EMAP accreditation.

POETE elements should be incorporated into other emergency management activities as well. When needs are identified and defined based upon Core Capabilities, these should be outlined in the jurisdiction’s multi-year Training and Exercise Plan, which should serve as a guiding document for many preparedness activities. The focus that a POETE analysis provides for each Core Capability can help identify training objectives which can help maintain and improve capability

Consider integrating them into your evaluation of exercises. While the Homeland Security Exercise and Evaluation Program (HSEEP) doctrine makes no mention of POETE, much of HSEEP is based upon capabilities. With a POETE analysis being an integral component of measuring our progress toward a capability, I would suggest including it into exercise evaluations. POETE elements can be included in Exercise Evaluation Guides (EEGs) to capture evaluator observations and should be outlined in the After Action Report (AAR) itself for each observation – giving suggestions for improvements based upon each POETE element. Consider how you could incorporate the POETE elements into an AAR as an outline identifying areas for improvement for the EOC management activities of the Operational Coordination Core Capability. As an example:

Planning: The jurisdiction should update the EOC management plan to incorporate all critical processes. Job aids should be created to assist EOC staff in their duties.

Organizing: Lines of authority were not clear to exercise participants in the EOC. Tasks were assigned to agencies but status of tasks was not effectively monitored.

Equipping: There were not enough computers for participating agencies. EOC management software did not facilitate tracking of resources.

Training: EOC agency representatives were not all trained in the use of EOC management software, creating delays in action and missed assignments. The EOC Manager and Planning Section Chief were well versed in the Planning Process and used it well to facilitate the Planning Process.

Exercising: Isolated drills should be conducted to test notification systems on a regular basis. Discussion based exercises will assist in identifying policy issues associated with suspension of laws and their impact on EOC operations.

The POETE analysis is a process which can help us identify strengths and areas for improvement within our emergency management and homeland security programs. While the POETE analysis can be time consuming, the information gathered for each Core Capability is valuable to any preparedness effort. With such a variety of federally-driven programs and requirements extended throughout emergency management and homeland security, we can find the greatest benefit from those which have the ability to cross multiple program areas – such as the Core Capabilities – allowing us to consolidate the evaluation of these programs into one system, providing maximum benefit and minimizing efforts.

Have you conducted a POETE analysis for your jurisdiction?  Did you find it a worthwhile process?

Looking for help with a POETE analysis?  Emergency Preparedness Solutions, LLC can help!  www.epsllc.biz 

© 2014 Timothy Riecker