Don’t Plan Yourself into a Corner

I’ve long been an advocate for detailed planning. Plans should identify who (by position or title) are decision-makers, who are action agents, and how things are to be done. Without identifying these responsible parties and the processes necessary to execute planned actions, plans will generally lack the ability to be successfully implemented. Context is also important. To address this, plans have a preamble that identifies the scope and objectives of the plan. All of this tells us what circumstances the plan is intended to apply to and what it expects to accomplish. Details matter. That said, making plans too specific can also spell trouble.

(I figured putting up the cover Michael McCaul’s Failures of Imagination was suitable for this post, as it’s all about emergency management suffering from a lack of imagination.)

In terms of context, only some plans need to be very precise about when and how they are used. Give yourself some wiggle room. If you don’t provide a proper and wide enough scope and objectives to the plan, you are already poisoning the well. Case in point – a lot of entities have realized that their pandemic plans have failed them, and as such are re-writing their plans. I’m hearing of many totally scrapping their old pandemic plans and writing the new ones as if all future infectious disease outbreaks will behave exactly as Coronavirus has. The old plans largely failed not necessarily because our assumptions were wrong, but because they were too narrow. Don’t make the same mistake. A proper scope and objectives will help properly define what you want to address. If these are too focused or narrow, you leave out a lot of possibilities.

When it comes to strategies and procedures, plans often fail because they don’t have enough detail. But plans can also fail if they are too restrictive or if the strategies and procedures don’t align with the scope and objectives. Restrictive plans define rigid circumstances under which approaches are taken, and/or those approaches are so rigidly defined that they will only work under certain circumstances or with all the right personnel and resources. You’ve been through disasters, right? You realize that disasters impose extreme circumstances upon us; impacting health, safety, and infrastructure; and we rarely ever have all the resources we would like to have in resolving that disaster. In fact, I’d argue that if disasters only impacted us the way we want them to, it would be more of an inconvenience rather than a disaster.

So unless you expect your title to change to Inconvenience Manager, remember that all preparedness starts with planning. Do your research and know your hazards, threats, and vulnerabilities, but don’t be totally encumbered by them either. Broaden your planning assumptions where you can, which will open your scope. Ensure that your planning objectives truly define what you intend for the plan to accomplish. Plan with greater detail and fewer restrictions. Ensure that succession and chain of command are addressed, so it’s not just a certain title or position that has authority over certain actions. Ensure that people are cross trained and that both people and plans are exercised with a certain extent of random factors in scenarios. Our plans and our resources must be agile to be successful.

Sure, we can improvise and get out of a corner that our plans back us into or don’t address, but we are better prepared if we can acknowledge the possibility of other scenarios. This is why planning teams contribute to successful plans. It’s the different perspectives they bring, with a lot of ‘what ifs’ and different viewpoints. Open your eyes and look around. One of the biggest enemies of emergency management is tradition. Is it any wonder why the same corrective actions keep rising to the surface?  Do better. Be better.

Thoughts?

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

A NEW NYS Public Employer Emergency Planning Requirement

On Labor Day, NYS Governor Cuomo signed a bill requiring public employers to develop a very specific emergency plan for future public health emergencies. This may include a continuation of the Coronavirus pandemic, or another emergency. Some details and guidance below…

WHO

The requirement applies to public employers, including:

  • State, county, and local governments
  • Public authorities (bridge, water, airport, etc.)
  • Commissions
  • Public corporations
  • Agencies
  • School districts
    • It’s important to note that the requirement for school districts has also been codified into state education law through this bill, to be included in school safety plans.

WHAT

The new law requires these plans to include the following:

  • A list and description of positions and titles considered essential
    • Note that the definition of ‘essential’ in the bill means employees who must work on site.
  • Protocols which will enable non-essential employees to work remotely
  • A description of how work shifts can be staggered to reduce overcrowding on public transportation and in the workplace
  • Protocols for procuring, storing, and distributing PPE
  • Protocols to prevent the spread of disease if an employee is exposed, symptomatic, or tests positive for the disease in question
  • Protocols for documenting hours and work locations of all employees for contract tracing
  • Protocols for coordinating with applicable government entities for emergency housing for employees, if needed

WHEN

Though there were no timeframes included in the bill itself, the Governor’s website provided two benchmarks of time. It states that plans are to be submitted to unions and labor management committees within 150 days, and all plans must be finalized by April 1, 2021.

The 150-day timeframe is obviously a bit confusing, as it doesn’t give a start date (i.e. 150 days from when?). I’ve sent inquiries to the Governor’s office, as well as my State Assemblyman and State Senator for clarification. Once I have an answer, I’ll provide it as a comment to this post. I will note that if the 150 day clock started on Labor Day, that alarm will go off on Friday February 4, 2021.

Once finalized, the plan must be included in any existing employee handbook and made otherwise available to employees. In terms of any kind of oversight or audit, there is no provision for such identified in the legislation. Aside from the requirement for school districts to meet this requirement being appended to state education law, this bill appends state labor law. As such, the NYS Department of Labor would have enforcement oversight, if they chose to or are directed to do so. That said, the bill does direct the NYS Department of Labor to establish procedures to allow for public employees to contact and inform the Department of any alleged or believed violations of the provisions of the law. Further, they are directed to establish a webpage and hotline to facilitate such.

HOW

Unfortunately, no existing planning requirement or standard will meet this requirement. While there are elements of continuity of operations planning in this, the focus is shifted and hits some very specific elements which are likely not included in many continuity of operations plans. That said, a new plan needs to be developed to meet this requirement. These elements certainly can be appended into a continuity of operations plan, but it’s important to note that these provisions are intended for future public health emergencies (not that some couldn’t be used for other hazards), and that, should any kind of audit occur, for those purposes it’s usually better to meet requirements through stand-alone documents.

As most public employees are members of labor organizations (unions), and the bill itself was endorsed by the AFL-CIO, there is a requirement for employers to submit the plans to unions and labor management committees for review. These entities have an option to provide comment, to which the employer is required to provide written responses prior to finalizing the plan.

There is some thought and coordination required to make this an effective and meaningful plan which also meets the legal requirements. Detail will need to be developed, specific to each public employer and their circumstances, for the protocols required in the plan. When developing procedure and protocol, be sure to:

  1. identify specifically what needs to be done,
  2. who the action agents are,
  3. what the ideal end state is,
  4. the timeframe in which it should be accomplished, and
  5. who has decision-making authority over those actions

Of course, in developing the plan, the best guidance I can give is to follow the planning process identified in FEMA’s CPG 101. Lastly, be sure to consider that the specific actions we have taken in response to the Coronavirus pandemic may not be the actions we take for another disease. Plans must maintain this flexibility.

NEED HELP?

Recognizing the challenges associated with developing this plan for small and large entities alike, my company – Emergency Preparedness Solutions (EPS) – has developed a template to support these planning requirements. We are making this template free for use by NYS public employers. I continue to have concerns with templates, cautioning against people simply ‘pencil whipping’ the document, but the developed template includes a lot of guidance and identifies content areas which need to be specifically developed by the public employer, so if the planning process is properly followed, I don’t expect that will be a problem with this template.

A BIT OF AN AD

Further, if jurisdictions want assistance in developing these plans, EPS is available to assist (contractually, of course). We’ve spent a lot of time reviewing these new requirements since they were signed and we’re already slated to discuss these in some webinars for specific public employer groups in New York State. Knowing that some small jurisdictions may be in a bit of a bind to meet this requirement, we are offering our services relative to this plan at not cost for the first 10 NYS public employers which employ between 1 and 10 full time employees if we have an executed contract by November 30th of this year – so be sure to contact us soon!

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Different Perspectives on Disaster Recovery

It seems a lot of the things we have been dealing with relative to the Coronavirus pandemic have brought us a different perspective, or at least have revealed a perspective that public health and emergency management have been concerned about for a while.  The pandemic given us a more accurate perspective on the impacts of a truly major public health event and the things we need to do to manage it.  We also find ourselves looking ahead to recovery and needing to view that through a different lens as well. 

Most disaster recovery, and in fact the way the Stafford Act is written, reflects physical damage from disasters such as floods, earthquakes, tornadoes, or hurricanes.  We are dealing with debris, damaged infrastructure, displaced masses, and the like.  The pandemic is something completely different.  While we may see shades of some more traditional recovery activity, recovery from the pandemic is giving us a very different way of seeing things. 

Before we get into the details, one of the biggest factors in all this is trying to determine where recovery fits in.  It’s long been a conundrum for people who want to make emergency management an exact science to be able to stick a pin in the exact spot where response ends and recovery begins.  Not only does the lack of that delineation persist for the pandemic, it’s exacerbated.  But that’s not all.  While some recovery activity has already started (more about that in a bit), the big push may not be able to start until society can at least begin to intermingle (though likely with some continued precautions).  Further, true recovery arguably can’t take place until we have a vaccine.  Until we reach that point, recovery efforts are likely to have a stutter, as we start, then have to stop or at least slow down when infection rates increase again, then resume once they subside.  This is simply not a formula we are used to working by. 

I suppose the best way to examine this is to look at it through the Recovery Mission Area Core Capabilities:

  • Planning
  • Operational Coordination
  • Public Information and Warning
  • Infrastructure Systems
  • Economic Recovery
  • Health and Social Services
  • Housing
  • Natural and Cultural Resources

Planning, Operational Coordination, and Public Information and Warning – I’m initially lumping these three together as they are the ‘common’ Core Capabilities and we generally see these in recovery having eventually transitioned over from the response focus.  The challenge with the pandemic is that we see the overlap of response and recovery, in some circumstances, more than we are used to compared to other disasters.  Also, a lot of the recovery we currently see is coming in the form of direct services from the Federal government, with little to no connection to state or local governments.  This is heavily emphasized in matters of Economic Recovery (more on this later).  The overall sense I’m getting is that the fundamentals of these three common Core Capabilities haven’t substantially changed (obviously some of the tasks have), though the experience different jurisdictions are having varies.  Consider that most jurisdictions aren’t used to dealing with prolonged incidents such as this.  In fact, many jurisdictions have decided to no longer operate EOCs (hopefully these were virtual!) as the impacts within their jurisdictions have been minimal and what problems do exist are largely being addressed by an emergency manager supported by a multi-agency coordination group.  Other jurisdictions, obviously, are being hit much harder and their management of this incident has continued to grow as they address the myriad issues that rise up and prepare for what they expect to see next.  There are some of the differences in Operational Coordination. 

Looking a little closer at Planning, this should still be taking place regardless of the volume of work your jurisdiction is experiencing, and even if your jurisdiction doesn’t have a public health department.  There is a lot of planning that still needs to take place to account for recovery, continuity of operations, and contingencies.  This one really permeates the other Core Capabilities the most. 

Lastly within this group, Public Information and Warning.  Absent jurisdictions that are used to dealing with more prolonged responses and recovery, most haven’t had to address a need for persistent public messaging.  While a lot of it is echoing guidance coming from certain authorities like the CDC or state health departments, more localized matters still need to be addressed in terms of what local services are or are not available (or how they now need to be accessed), providing information on planned events, and addressing rumors and mis-information. 

Infrastructure Systems – Restoration of infrastructure is often a big emphasis in most disasters.  Roads, bridges, water and waste water systems, electricity, and other systems are often damaged or destroyed as the result of the disaster of the day.  In the matter of the pandemic, generally the most impact we see in these systems is delays in maintenance because of some decreased capacity among those that are responsible for them.  Perhaps the one significant exception, through from a very different perspective, is internet services.  While internet services weren’t damaged by the pandemic, they were heavily impacted with many organizations directing staff to work from home.  College students are now engaged in classes from home instead of the campus.  Families and friends are connecting more often via video calling. Even on-line gaming has seen a surge with people spending more time at home.  All this changed the dynamic of internet use.  Most businesses are provided with dedicated lines by internet service providers, designed to handle the concentrated surge of internet use demanded by a facility or collection of facilities.  Much of that use has dwindled, shifting to a drastic increase on residential services.  We also see increased demands on either end of this, with attention being drawn to entire areas that have no internet service as well as the need for increased server capacity of companies that host video calling and gaming platforms.  Even organizations and their employees have had to scramble to ensure that employees (and students) have internet access at home, the hardware required to access the internet, and the ability to connect to the organization’s servers and services. 

Another interesting perspective on infrastructure, however, comes from the emphasis on essential services and essential employees that we hear of every day.  While definitions of this have existed for some time, in this disaster alone we have seen that definition change a few times as we realize the connectivity between certain services and organizations.  Some important lessons to be documented and applied to future planning efforts. 

Economic Recovery – For as much as Infrastructure Systems (largely) haven’t been impacted, Economic Recovery has needed to be significantly re-imagined.  With businesses being forced to close and employees being furloughed or laid off, the global economy has taken a significant hit.  This is certainly a prime example, perhaps our first, of how deep a disaster of a global scale can cut us.  As a result, many nations around the planet have been pushing out some sort of economic stimulus, helping those that are unemployed as well as those businesses that are still open yet struggling with decreases in revenue.  The economic hit from the pandemic will take years to recover from and will require some very different ways of solving the problem.  Governments have only so much money to give.  Many jurisdictions are also examining the association between infrastructure and economic recovery in a different light, especially as thought is being put into when and how to re-open our communities and economies. 

As a related side note, we were recently awarded a contract to provide guidance on the reopening of transportation and transit in major cities.  Continued preventative measures as well as human behaviors are going to apply some interesting demands on urban planning, prompting cities to respond appropriately to these changes if they want to see businesses rebound, or even thrive as we move further into recovery. 

Health and Social Services – Rarely does public health lead the way through a major disaster.  Though we realize that just with other disasters where we might like to think that people are in charge, the disaster itself still remains in the driver’s seat and we are really just along for the ride, trying to address problems the best we can. Our health system is stretched, yet we see an interesting irony of hospitals laying off staff, as elective surgeries and other non-emergency services are presently suspended.   Obviously public health will continue to lead the way through our recovery.  Even with others seemingly in charge of other recovery functions, it is public health markers which will become the decision points that dictate our overall recovery.  On the social services side of this Core Capability, we also see a change in dynamics.  While the pandemic doesn’t have the physical impacts of a more traditional disaster, we are also seeing fewer people being displaced overall due to emergency legal protections being put in place to prevent evictions and utility service disconnections from lack of payment.  That said, we are still seeing traditional social service issues related to food, medicine, and mental health exacerbated due to the pandemic, the economic impact from the pandemic, and the mental stresses imposed by the pandemic as a whole, as well as social distancing, deaths, and other factors.  While many social services have traditionally been very hands-on and face-to-face, many of these services have moved to remote models, though others, by necessity, are still physically operating.  Social services recovery, linked to economic recovery as well as psychological matters like PTSD, will persist long after the pandemic.  Recovery plans must be re-imagined to address this.  Public health recovery, similarly, will last long after the pandemic as we need to take an honest look at the gaps in our system and work to address them. 

Housing – As mentioned earlier, there are few displacements (that should be) happening as a result of the pandemic.  Houses haven’t been destroyed as a direct result of the pandemic. Though how long will landlords be able to reasonably wait for back rents to be paid to them?  While those that own large apartment complexes may be able to absorb these losses, landlords with small properties will not.  They are small businesses, with bills to pay and mouths to feed.  While it’s great for tenants to get a reprieve, this also has impacts.  Local economies will likely need to figure out how to address this. 

Natural and Cultural Resources – Similar to infrastructure and housing, our natural resources have seen, overall, limited impact from the pandemic.  In fact, by many reports, many of our natural resources have seen marked and measurable improvement due to decreases in pollution and other impacts of ‘normal’ human activity.  Many cultural resources, on the other hand, have been impacted. I speak not of historical sites, which are often considered in the reconstruction activities associated with disaster recovery, but of museums and performance centers.  Museums, as with any other organization, rely on income to survive.  Many are non-profits, and generally put revenue into improving the facility and its collections, leaving not much of a ‘rainy day’ fund.  Similarly, collections haven’t been damaged, as they might have in another disaster, so there is no insurance claim to cover losses.  Similarly, performance centers, such as the 1930s era theater where I perform improv, haven’t seen revenue in weeks.  Here, we blur the lines between a different perspective on cultural preservation with economic recovery.  Another challenge local economies will have. 

So where does this leave us?  Clearly we are seeing different perspectives of each of these Core Capabilities, requiring us to approach them in ways different than we have in the past.  While the easy solution to many of them is money, an economy globally impacted has little funding to adequately do so.  We also see the interconnectivity of these Core Capabilities.  For many, there is reliance on others to make progress before another can see tangible improvement.  That said, planning is still the crux of it all. We must make deliberate planning efforts to address each of these.  Sure, we can reference current plans, but I argue that most current plans are inadequate, as the problems and the resultant solutions were not anticipated to look like this.  Planning also needs to occur at all levels, and there absolutely must be an emphasis on the first step of the CPG 101 planning process… Form a Team.  Our recovery from a global, national, and community level requires people working together.  We see now, more than ever, how interconnected things are.  This is no time to be insular.  We must consider all stakeholders, including citizens, organizations, and businesses, as part of our planning teams.  And by the way, we’re already behind. 

A couple more items before I close this rather long post.  First of all, consideration should be given to Continuity being added to the Core Capabilities.  Perhaps as a common Core Capability, but at least as one that is included in more than one mission area.  It’s a specific effort that, yes, does include planning (as should any other Core Capability), but has a very specific function and implementations. 

Second (and lastly), you absolutely must be capturing and documenting lessons learned (strengths and areas for improvement).  In fact, don’t wait to hotwash.  If you haven’t already, do one now.  You will do another later.  And likely one or more after that.  The duration of this disaster, and the different focal points and phases of it will constantly shift our attention and cause people to forget what they have learned.  Lessons learned must be captured in phases, allowing us to focus on sets of activities.  Be sure to document your lessons learned, share them far and wide, and set a timeline for implementing improvements.  There is so much to learn from this disaster, but it’s a waste if we ignore it or expect someone else to tell us what to do.   

I hope I delivered in this piece, highlighting the different perspectives of disaster recovery we are dealing with.  Are all disaster recovery activities fully turned on their heads?  Of course not.  We are still able to apply the standards we have been for decades, though some of them do need to be looked at and approached from a different perspective.  I’m very interested in feedback and thoughts. 

Stay safe. 

© 2020 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Improv in Emergency Management

In emergency management we put a lot of emphasis on planning and training, and rightfully so.  Deliberate planning establishes a foundation for our actions, thought out well ahead of any incident or disaster we might deal with.  Further, most training we receive is necessarily sterile.  We are trained how to respond to, organize, and manage incidents and the various facets of them.  To learn the elements and procedures being taught, we must first learn them in their most raw form, free of other distractions.  We also know that in reality, our plans and training only get us so far.

I’ve recently been reading American Dunkirk: The Waterborne Evacuation of Manhattan on 9/11 by James Kendra and Tricia Wachtendorf.  This is an incredible book, the story of which I only knew small pieces of.  It tells of boat operators and waterfront workers who supported the mass evacuation of people from Manhattan as well as the delivery of responders, equipment, relief supplies, and services proximate to ground zero.  This book is well researched and supported by a multitude of interviews and other accounts of the heroism and actions taken following the attacks.

One of the themes that struck me early in the book was that of improvisation.  For over a year now, I’ve been taking improv classes and doing some performances.  We have an outstanding group of people and I’ve learned a lot, not only on the stage, but skills that I can apply across various aspects of my life, from work and podcasting to social situations.  While I’ve always intuitively known that our emergency plans only get us so far and then we basically have to make things up, I never actually labeled it as ‘improv’.

Kendra and Wachtendorf state “Since it is difficult to anticipate everything, communities need to be able to improvise as well as plan ahead.” They further elaborate that “Theatrical improvisers exercise skills that allow them to perform skits and routines spontaneously.  They are making things up as they go, but they know which principles to pull together.  They know how to make use of props and cues and the environment closest to them.  Instead of following a scripted plan, improv performers match what they know and what they have at hand.”  Consider this in the context of emergency management.  Does it sound familiar?  It certainly should.

We use our plans as a foundation.  We should continue to endeavor to make those plans as solid as possible without being unwieldy, while still recognizing that for a period of time, certainly early in the incident and very likely at other periodic times throughout, chaos rules.  Circumstances take us away from the pages of the plan, but that doesn’t mean that we have lost control, it simply means that we need to improvise to bring the incident back into line with our assumptions, or, if it’s not possible, we are developing a new plan in the moment.  Even if we have deviated from the plan, the principles contained within the plan still hold incredible value.  They become touchstones for us, reminding us what must be accomplished and what our principles for managing the disaster are.

Collectively, I challenge everyone to flex some improv muscles.  This can tie to several things.  First, take some improv classes.  Many larger urban areas have them available.  Don’t be afraid to try something different.  Next, find opportunities where you can use your plans as a foundation, but with scenarios that may deviate from the plan.  Even if it’s a zombie attack scenario, which may sound silly, but when you break it down to many of the fundamental impacts (infrastructure, public health, mass care, civil unrest, etc.) many jurisdictions already have a lot of the planning in place.  Some creativity with a scenario like this or another, forces people to think outside the box and work together to solve problems, which is what improv is all about.

As always, I’m interested in hearing your thoughts on the topic.

© 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™

 

 

Expanding Hazard Mitigation Plans to Truly Address All Hazards

Planning efforts and documents are incredibly central to everything we do in preparedness.  When we look at the spectrum preparedness elements of Planning, Organizing, Equipping, Training, and Exercises (POETE), ‘planning’ being first should be a reminder that everything goes back to planning.  Our organizations, equipment, training, and exercises should all reflect back on plans.  These aren’t just emergency operations plans, either, but should include all plans.

A fundamental plan for many jurisdictions is the hazard mitigation plan.  Most responders tend to ignore this plan as it’s not about response, but it has a great deal of valuable information.  Hazard mitigation plans are built on a lot of research and data analysis, trends, and science behind a variety of hazards that could impact the area.  For as much as hazard mitigation plans can get neck-deep into science, they are not only good references but can be built into good, actionable plans.  The leadership of practically every agency in a jurisdiction should be involved in the development and update of hazard mitigation plans and be knowledgeable of what they contain.  That said, there are a couple of issues I have with how hazard mitigation plans are done.

First of all, they should be developed to be more than a catalog of information, which is how many are built.  We should be able to do something with them.  FEMA’s standards for hazard mitigation planning have gotten better and better through the years, thankfully.  While their standards include the identification of potential projects for a jurisdiction to address hazards, I’ve seen many plans (and the firms that develop them) cut this section particularly short.  I’ve seen plans developed for major jurisdictions having only a handful of projects, yet I’ve had experience developing plans for much smaller jurisdictions and identifying a significant list of prioritized projects.  While the onus is ultimately on the stakeholders of the jurisdiction to identify projects, consulting firms should still be actually consulting… not just regurgitating and formatting what stakeholders provide them.  A good consultant will advise, suggest, and recommend.  If your consultant isn’t doing so, it’s probably time to find someone else.

The second issue I have with hazard mitigation plans is that so many truly aren’t ‘all-hazard’.  Many hazard mitigation plans address natural hazards and some human-caused hazards, such as damn failures and hazardous materials incidents.  Rarely do we see hazard mitigation plans addressing hazards such as cyber attacks or active shooter/hostile event response (ASHER) incidents.  There are some obvious issues with this.  First, the hazard mitigation plan is generally looked upon to have the best collection of data on hazards for the jurisdiction.  If it excludes hazards, then there is no one good place to obtain that information.  This is particularly dangerous when other plans, such as EOPs, may be based upon the hazards identified in the hazard mitigation plan.  As I mentioned at the beginning, if something isn’t referenced in our planning efforts, it’s likely not to be included in the rest of our preparedness efforts.  Second, if these other hazards aren’t in our hazard mitigation plans, where are we documenting a deliberate effort to mitigate against them?  While hazards like cyber attacks or ASHER incidents are generally seen to be mitigated through actions labeled ‘prevention’ or ‘protection’, they should still be consolidated into our collective mitigation efforts.  Those efforts may transcend traditional hazard mitigation activities, but why would we let tradition impede progress and common sense?  A fire wall should be listed as a hazard mitigation project just as flood control barrier is.  And bollards or large planters are valid hazard mitigation devices just as much as a box culvert.

Let’s be smart about hazard mitigation planning.  It’s a foundational element of our comprehensive preparedness activities.  We can do better.

© 2018 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

2017 National Preparedness Report – A Review

With my travel schedule, I missed the (late) release of the 2017 National Preparedness Report (NPR) in mid-October.  Foundationally, the findings of the 2017 report show little change from the 2016 report.  If you are interested in comparing, you can find my review of the 2016 NPR here.

The 2017 NPR, on the positive side, provided more data and more meaningful data than its predecessor.  It appeared to me there was more time and effort spent in analysis of this data.  If you aren’t familiar with the premise of the NPR, the report is a compilation of data obtained from State Preparedness Reports (SPRs) submitted by states, territories, and UASI-funded regions; so the NPR, fundamentally, should be a reflection of what was submitted by these jurisdictions and regions – for the better or worse of it.  The SPR asks jurisdictions to provide an honest analysis of each of the core capabilities through the POETE capability elements (Planning, Organizing, Equipping, Training, and Exercising).

From the perspective of the jurisdictions, no one wants to look bad.  Not to say that any jurisdiction has lied, but certainly agendas can sway subjective assessments.  Jurisdictions want to show that grant money is being spent effectively (with the hopes of obtaining more), but not with such terrific results that anyone would think they don’t need more.  Over the past few years the SPRs, I believe, have started to normalize and better reflect reality.  I think the authors of the NPR have also come to look at the data they receive a little more carefully and word the NPR to reflect this reality.

The 2017 NPR (which evaluates 2016 data from jurisdictions) identified five core capabilities the nation needs to sustain.  These are:

  • Environmental Response/Health and Safety
  • Intelligence and Information Sharing
  • Operational Communications
  • Operational Coordination
  • Planning

I’m reasonably comfortable with the first two, although they both deal with hazards and details that change regularly, so keeping on top of them is critical.  Its interesting that Operational Communication is rated so high, yet is so commonly seen as a top area for improvement on after-action reports of exercises, events, and incidents.  To me, the evidence doesn’t support the conclusion in regard to this core capability.  Operational Coordination and Planning both give me some significant concern.

First, in regard to Operational Coordination, I continue to have a great deal of concern in the ability of responders (in the broadest definitions) to effectively implement the Incident Command System (ICS).  While the implementation of ICS doesn’t comprise all of this core capability, it certainly is a great deal of it.  I think there is more room for improvement than the NPR would indicate.  For example, in a recent exercise I supported, the local emergency manager determined there would be a unified command with him holding ‘overall command’.  Unfortunately, these false interpretations of ICS are endemic.

I believe the Planning core capability is in a similar state inadequacy.  Preparedness lies, fundamentally, on proper planning and the assessments that support it. While I’ve pontificated at length about the inadequacy of ICS training, I’ve seen far too many plans with gaps that you could drive a truck through.  I’ve recently exercised a college emergency response plan that provided no details or guidance on critical tasks, such as evacuation of a dormitory and support of the evacuated students.  The plan did a great job of identifying who should be in the EOC, but gave no information on what they should be doing or how they should do it.  The lack of plans that can be operationalized and implemented is staggering.

The NPR identified the top core capabilities to be improved.  There are no surprises in this list:

  • Cybersecurity
  • Economic Recovery
  • Housing
  • Infrastructure Systems
  • Natural and Cultural Resources
  • Supply Chain Integrity and Security

Fortunately, I’m seeing some (but not all) of these core capabilities getting some needed attention, but clearly not enough.  These don’t have simple solutions, so they will take some time.

Page 10 of the NPR provides a graph showing the distribution of FEMA preparedness (non-disaster) grants by core capability for fiscal year 2015.  Planning (approx. $350m) and Operational Coordination (approx. $280m) lead the pack by far.  I’m curious as to what specific activities these dollars are actually being spent on, because my experience shows that it’s not working as well as is being reported.  Certainly there has been some positive direction, but I’m guessing that dollars are being spent on activities that either have negligible impact or actually have a negative impact, such as funding the development of some of the bad plans we’re seeing out there.

I’m curious as to what readers are seeing out in real life.  What capabilities concern you the most?  What capabilities do you see successes in?  Overall, I think everyone agrees that we can do better.  We can also get better and more meaningful reports.  This NPR was a step in the right direction from last year’s, but we need to continue forward progress.

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Awareness of Public Health Preparedness Requirements – CMS

Emergency management and homeland security are collaborative spaces.  Think of these areas a Venn diagram, with overlapping rings.  Some of the related professions overlap with each other separately, but all of them overlap in the center.  This overlap represents the emergency management and homeland security space.  What’s important in this representation is the recognition that emergency managers and homeland security professionals, regardless of what specific agency they may work for, need to have awareness of that shared space and the areas of responsibility of each contributing profession.  One of the biggest players in this shared space is public health.Presentation1

For nearly a year, public health professionals have been talking about new requirements from CMS, which stands for The Centers for Medicare and Medicaid Services.  How does Medicare and Medicaid impact emergency management?  CMS, part of the Department of Health and Human Services (HHS) covers over 100 million people across the US – far more than any private insurer.  As an arm of HHS and a significant funding stream within public health, they set standards.

The most relevant standard to us is the Final Rule on Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers.  The rule establishes consistent emergency preparedness requirements across healthcare providers participating in Medicare and Medicaid with the goal of increasing patient safety during emergencies and establishing a more coordinated response to disasters.

The CMS rule incorporates a number of requirements, which include:

  • Emergency planning
  • Policies and procedures
  • Communications planning with external partners
  • Training and exercises

These are all things we would expect from any emergency management standard.  Given the different types of facilities and providers, however, the implementation of the CMS rule can be complex.  A new publication released by the HHS ASPR (Office of the Assistant Secretary for Preparedness and Response) through their TRACIE program (Technical Resources, Assistance Center, and Information Exchange), provides some streamlined references to the CMS rule.  It’s a good document to study up on and keep on hand to help keep you aware of the requirements of one of our biggest partners.

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC

Incident Evaluation

I’ve written at length about the importance of quality evaluation of exercises.  Essentially, if we don’t evaluate exercises, and do it well, the benefits of the exercises are quite limited.  Generally, we don’t see a benefit to incidents.  By their very nature, incidents threaten and impact life, property, and environment – things we don’t view as being beneficial.  However, benefits are often a product of opportunity; and we absolutely should take the opportunity to evaluate our responses.

Many incidents do get evaluated, but through research after the fact.  We retrace our steps, review incident documents (such as incident action plans), interview personnel, and examine dispatch logs.  These efforts usually paint a decent picture of intent and result (things that are often different), but often miss the delta – the difference between the two – as well as other nuances.  When we evaluate an exercise, we do so in real time.  Th evaluation effort is best done with preparation.  Our evaluation plans, methodologies, and personnel are identified in the design phase of the exercise.  Just as we develop emergency operations plans and train personnel to respond, we can develop incident evaluation plans and train personnel to evaluate incident responses.

Understandably, a hurdle we might have is the availability of personnel to dedicate solely to evaluation, especially on larger incidents – but don’t be afraid of asking for mutual aid just to support incident evaluation (just be sure to include them in your preparedness efforts).  Just as regional exercise teams should be developed to provide cooperative efforts in exercise design, conduct, and evaluation; incident evaluation teams should be developed regionally.  To me, it makes sense for many of these personnel to be the same, as they are already familiar with how to evaluate and write up evaluations.

In exercises, we often use Exercise Evaluation Guides (EEGs) to help focus our evaluation efforts.  These are developed based upon identified Core Capabilities and objectives, which are determined early in the exercise design process.  While we don’t know the specific objectives we might use in an incident, we can identify these in general, based upon past experiences and our preparedness efforts for future incidents.  Similarly, our emergency planning efforts should be based around certain Core Capabilities, which can help inform our incident evaluation preparedness efforts.  Job aids similar to EEGs, let’s call them incident evaluation guides (IAGs), can be drafted to prepare for incident evaluation, with adjustments made as necessary when an incident occurs.

Evaluating an incident, in practice, is rather similar to how we would evaluate an exercise, which is why the training for these activities is relatively portable.  Evaluation efforts should avoid evaluating individuals, instead focusing on the evaluation of functions and processes.  Don’t reinvent the wheel – evaluate based upon documented (hopefully!) plans and procedures and use the Homeland Security Exercise and Evaluation Program (HSEEP) standards to guide your process. Incident evaluation must be managed to ensure that evaluation gaps are minimized and that evaluation progresses as it should.  Observations should be recorded and, just as we would for an exercise, prepared for and eventually recorded in an after action report (AAR).

I favor honest after action reports.  I’ve seen plenty of after action reports pull punches, not wanting the document to reflect poorly on people.  Candidly, this is bullshit.  I’ve also heard many legal councils advise against the publication of an after action report at all. Similarly, this is bullshit.  If our actions and the need to sustain or improve certain actions or preparations is not properly recorded, necessary changes are much less likely to happen.  If an AAR isn’t developed, a corrective action plan certainly won’t be – which gives us no trackable means of managing our improvements and disavows our intent to do so.

As a profession, public safety must always strive to improve.  We have plenty of opportunity to assess our performance, not just through exercises, which are valuable, but also through the rigors of incident responses.  Prepare for incident evaluation and identify triggers in your emergency plans for when evaluation will be employed, how, and who is involved.  Begin evaluation as early as possible in an incident – there are plenty of lessons learned in the early, and often most critical moments of our incident response.  Finally, be sure to document lessons learned in an AAR, which will contribute to your overall continuous improvement strategy.

How does your agency accomplish incident evaluation?  If you don’t, why?

Need help with the evaluation of incidents?  We are happy to help!

© 2017 – Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC