Tag emergency planning

The Emergency Management Support Act – Update 1

Tim Riecker, The Contrarian Emergency Manager Leave a comment

My original post on this bill generated some great discussion on Twitter and LinkedIn.

The actual bill text was finally posted on Congress’ bill tracking website.

My observations and comments:

  1. The short title of the bill suggests that the bill can be cited as the ‘EMS Act’.

Ugh. Really? Thanks Rep. Thompson for continuing to perpetuate confusion related to emergency management.

2. The bill provides, as an amendment to PKEMRA, a definition of local emergency management director: ‘An official designated at the local level to coordinate local disaster response, emergency planning, emergency preparedness, disaster recovery, disaster mitigation, and related activities on a full-time or part-time basis.’

While this is a necessary definition to include in the bill, I think that since the bill is focused on EMPG-funded local emergency management programs, it should specify those are the only local EM directors this applies to. Depending on how states administer and distribute EMPG funds locally, there are some states with many local emergency management programs that are not EMPG funded.

3. The bill provides, as an amendment to PKEMRA, a condition for eligibility of EMPG grant funds, that states ‘require local emergency management directors to successfully complete Federal Emergency Management Agency provided baseline emergency management training developed in accordance with the National Incident Management System not later than 1 year after the date of enactment of this subsection and recurrently at an interval determined by the Administrator to strengthen local emergency management capacity.’

So as mentioned in my original post, there is still no actual identification of what topics are to be addressed in the training. While it states ‘in accordance with NIMS’, that’s still not at all specific. I suppose to one extent, it’s good that politicians aren’t assuming they know what ‘baseline emergency management training’ looks like, and it also allows this would-be provision of an amended PKEMRA some longevity and flexibility to address changing needs. On the other hand, we still don’t know what the actual intent of this training is. Of course, we want emergency managers to be trained to a baseline. That’s certainly a good thing. Though as mentioned in my original post, many states have developed their own local emergency manager training programs. I assume that most of these state-developed training programs meet identified needs within the state, including specific state emergency management processes and operations which would not be included in any FEMA-developed training. Will states be allowed to substitute this training for the ‘FEMA-provided’ training indicated in this provision? If not, this will be an additional training requirement, which superficially isn’t a bad thing, but it is one more thing that emergency managers need to do – and not just once, but annually.

The provision doesn’t state the delivery modality of the training, so I suppose FEMA has the option of this training being independent study, in-person, live remote, or any hybridization of the above. While independent study is certainly the most convenient for everyone, we all know that it has limitations on learning taxonomies. That said, the language states ‘FEMA-provided’, not FEMA-conducted. Since other language in the bill indicates that States are to report to FEMA on compliance, it seems the intent is to have FEMA develop said training for state delivery (i.e. G courses). I suppose this can provide an opportunity for state training officers to amend the FEMA-developed course to include state-specific information without taking away from the material FEMA developed.

But with all that, what of other training initiatives out there, such as the FEMA Basic Academy? While there is no federally-driven grant requirement for the Basic Academy, the materials could be included within this. But with that, while I continue being a big advocate for training and see the value of the Basic Academy, the number of courses and duration of training could be a barrier – especially for part-time directors. And with the refresher requirement, there obviously can’t be an expectation for people to re-take the academy, so a separate refresher training would have to be developed and delivered.

As a former state training officer, there are a lot of possibilities, but also a lot of logistical issues to be addressed.

4. The bill does provide language to address gaps in compliance, with states being required to identify barriers of all local emergency management directors completing training and an approach to overcome those barriers with a timeline for compliance.

I really do appreciate accountability in laws and grants, and while this provision is a good start, there is no provision for a penalty, so it really has no teeth to it. To me, this seems very much like the NIMS training requirements that came about following HSPD-5, which initially had a lot of complication in tracking but devolved into a simple statement of compliance in EMPG reporting.

As mentioned, there was a lot of great discussion prompted by my last post. Most people agreed there were a lot of concerns absent seeing the bill itself. Now that we have, it still doesn’t really address most of those questions and concerns. There were some comments on the original post that at least this works to establish some kind of standard. I can only partially agree with that sentiment. The bill itself doesn’t define a standard at all. Let us be honest that this is not a standard for all emergency managers – it’s only for local emergency management directors funded by EMPG. Yes, that’s an important group, but it should not be confused with being a standard for the profession. Also, training should be based on an established standard; and generally speaking, training is not itself a standard.

Continued Thoughts on Training (for those who are interested)

Philosophically, there is a great opportunity here to develop a comprehensive baseline training course or program that includes elements of a lot of existing training as well as some new content, but that training, at least as developed by FEMA, can only address federal processes and fundamentals of emergency management from that perspective – it can’t speak to the unique approaches and nuances of each state, which means there is a critical component that would be missing from this training if the intent is for it to be truly ‘baseline’. I’d hope that whatever is developed provides room for states to incorporate locally specific information to make this training more worthwhile and valuable.

Will this be valuable, or will this become ‘one more thing’ for emergency managers to do? Will this be some pencil-whipped compliance item? While it leaves FEMA (and hopefully the emergency management community at large) to identifying what that standard will be (i.e. the content of the training), I expect that much of the EM community will want less instead of more. Again, as a former state training officer, I heard people complain every day about the duration of training and wanting to cut corners. I expect many current EMs will express this to be a waste of time for themselves, likely being shortsighted about the potential value to new personnel. That said, I’ll also suggest that if this is truly for local emergency management directors, these individuals should have the ‘baseline’ knowledge BEFORE being hired to the position of director – though we know that many, especially those who are current or retired fire and police who are often given these jobs actually know very little about emergency management beyond response.

The most comprehensive standard we have in emergency management is NFPA 1660, though I don’t feel that this, alone, is enough to provide the ‘baseline’ of training that local emergency management directors need as there are several other essential content areas, many covered by existing training. Also, while NFPA 1660 is a solid standard for emergency management and continuity programs, it doesn’t prescribe means and methods for the activities identified therein. That’s not a gap… that’s actually how standards should be developed which allows for innovation. So in figuring out what this ‘baseline’ training is to be, we also need to determine what the desired taxonomy is – what do we want them to know, to what extent, and what do we expect them to be able to do with that knowledge? (see my series of ICS Training Sucks articles for more discussion on Bloom’s Taxonomy and learning outcomes). If we want them to know how to do things, we need to provide implementation guidance for each area of NFPA 1660. Some of that we have, such as CPG 101 for emergency planning.

This is a rabbit I can chase for a long time down a lot of holes. If this bill passes, I’d love to be at the table with folks at EMI to help develop this.

© 2023 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Big City Emergency Management Audits

Tim Riecker, The Contrarian Emergency Manager Leave a comment

In October of 2022, audit reports were released for the emergency management offices for the two largest cities in the US – interestingly enough conducted by controller’s offices. New York State Comptroller Thomas DiNapoli’s office conducted an audit of NYC Emergency Management, while City of Los Angeles Controller Ron Galperin’s office conducted an audit of LA’s Emergency Management Department. While these audits were conducted by controller’s offices, they were not only financial. In fact, both audits contained considerable programmatic assessment.

Before I get into the findings of the audits, there are a few things I want to express. First off, I think third party audits are great. Organizations are supposed to be taking certain actions – either dictated by mandate, devised by their own commitment, or encouraged by demonstrated need – and so often fall short in execution. We can all make excuses, many of them justifiable and valid, as to why actions weren’t taken or completed, and while an external evaluation may lack important context, they can help keep us on track. All that said, I wonder who the people were conducting the audits. Do they have any backgrounds in emergency management? Is that even necessary? Certainly, emergency management is a complex system of systems, that non-emergency managers could understand, but did the auditors have that understanding? It seems to be a failure right off that only emergency management offices were audited and not emergency management programs of those jurisdictions. I think we have great precedent and understanding of that demonstrated by the Emergency Management Accreditation Program (EMAP), as their accreditation reviews are of programs, not just agencies. Those items expressed, let’s get to the meat of the audits. Feel free to dive into the audits for additional information.

The New York City audit zeroed in on three key areas:

  1. Hazard mitigation planning deficiencies
  2. Lack of updating evacuation plans
  3. Gaps in continuity of operations (COOP) planning and exercises

The LA audit listed these key findings:

  1. Gaps in planning for specific hazards, such as cyberattacks, climate change, and drought
  2. Lack of assistance provided to other city agencies for emergency planning and COOP planning
  3. Deficiencies in tracking qualifications and credentials of designed emergency operations center (EOC) staff
  4. An observation that training and exercises decreased during the pandemic, but noting that the department is reorganizing its training and exercise program
  5. Failure to adequately track all corrective actions from exercises, incidents, and events
  6. Lack of supply and equipment assessments to support city preparedness

Both audits identified needs to create or update plans, and also called on the emergency management offices to better support other city agencies in the development and maintenance of emergency plans and COOP plans. Given that planning is the foundation of emergency management, this should certainly be a priority for every emergency management agency and program. While these audits were not centered on emergency management programs for the jurisdictions, I did appreciate that they identified city-wide gaps in planning. While I feel that each agency should be responsible for its own plans – and certainly city agencies of that size should have their own emergency management specialists – they should still be able to count on some support from the city emergency management office.

I find it interesting that the NYC audit honed in considerably on deficiencies in hazard mitigation planning, while the LA audit cited the hazard mitigation plan but didn’t have any criticisms. Overall, the two audits provided some very different perspectives in their concerns, with the NYC audit focused on known issues (i.e. identified hazard mitigation measures, evacuation plans); while the LA audit had considerable focus on emerging matters. Neither audit was big on identifying what agencies did well, which I think is a deficiency of the audits.

The NYC audit included a rebuttal from OEM, though the LA audit did not include any rebuttal from EMD.

Overall, the audits identify deficiencies which I think are common across many local and state emergency management agencies, not just those of big cities. While there are excuses and justifications, the items listed seem fair. As mentioned, though, emergency management is a complex system of systems, opening a lot of opportunity for things to be missed or mishandled. Emergency management is also not just a responsibility of emergency management agencies. Further, when we get into response mode, we tend to forsake many other activities. This was exacerbated considerably by COVID-19 and other disasters that occurred during the pandemic. We all have room for improvement.

What have you learned from this that you can apply to your own agency or program? Are there any external entities that audit or review your emergency management agency or programs?

© 2023 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

The 2022 National Preparedness Report – Another Failure in Reporting

Tim Riecker, The Contrarian Emergency Manager 3 Comments

As with past years, FEMA gifts us the annual National Preparedness Report for the prior year around the holidays. Some reminders: 1) You can find my reviews of the reports of prior years here. 2) To get copies of the reports of prior years, FEMA archives these in the unrestricted side of the Homeland Security Digital Library. 3) Each report is derived from data from the year prior, so this December 2022 report actually covers the calendar year of 2021.

Compared to last year’s report, this year’s follows much of the same format, with sections on risk, capabilities, and management opportunities. They appropriately moved some of the content in this year’s report to appendices, which helps each of the sections get more to the point.

Last year’s report was on a kick of catastrophic risk, committing what I think was an excessive amount of content to data on large-scale disasters. While we should certainly plan for the worst, most areas do a mediocre job at best with preparing for, mitigating against, responding to, and recovering from mid-sized disasters. If they can’t manage all aspects of these, it’s not even realistic for them to be able to manage the largest that nature, terrorists, or accidents can throw at us. This year’s report has a much better focus on risk, threat, and hazards; with some reflection on THIRA/SPR data from 2021, grounded realities of climate change, and some time given to cybersecurity and infrastructure. In line with the FEMA strategic plan (and continuing from last year’s report), this year’s report also discusses equity, social vulnerability, and risk exposure; with reference to social vulnerability measures (of which I’m a big fan).

Last year’s report covered risk associated with healthcare systems and the economy, which didn’t get much of a mention in this year’s report, which I think is unfortunate. The reality of surge and the shortage of hospital beds has been brought to the forefront over the past few years, with little to nothing being done to address it. Similarly, we’ve also had the fragility of organizations revealed over the past few years, yet have not seen as much of a push for continuity of operations as we should have seen. While thankfully this year’s report doesn’t have the focus on COVID that last year’s did, it seems people want to move on without addressing the glaring lessons learned.

In all, this year’s report spends about half the page volume on risk compared to last year’s report. While this year’s report provides better information, I still think there were some missed opportunities.

Looking into the assessment of capabilities, the first noted issue is that the capability targets for 2021 were the same as those for 2020. While consistency is important for long-term measurement, the lack of any alteration indicates to me that those who establish the capability targets are lacking some critical awareness of the emergency management landscape. While I don’t necessarily dispute the targets included, I think many of them could use some better refinement and specificity. The lack of inclusion of the cross-cutting Planning Core Capability (which is the foundation of all preparedness) is mind-blowing, as is the lack of the Recovery Mission Area’s Housing Core Capability (considered by many to be our greatest area of fragility). I’d really like to see the data substantiating the THIRA/SPR submissions that indicate such a high achievement of Unified Operations. Reflecting back on the necessity for long-term measurement, this year’s report offers none at all. This limits our ability to perceive preparedness gains or losses over time. As with last year’s report, which similarly did not provide this information, I feel this report has failed to meet its primary goal. It’s nothing more than a snapshot in time of very limited metrics – certainly not a comprehensive review of the state of the nation’s preparedness.

One particular graphic, identified as Figure 11 on page 24 of the report, is extremely telling. The chart identifies the non-disaster grant investments for FY21 across various grant programs. The grant distribution seems to not at all align with the established capability targets, which is good in some cases (we still need to invest in plans) but bad in other cases (fatality management is an established capability target that had minimal investment). By far, the greatest expenses are related to planning, as I feel they should be, yet the ground truth is that there are still a lot of horrible plans being generated. We have significant gaps in certain capabilities such as the aforementioned Fatality Management, along with Public Health/Healthcare/EMS, Housing, and Economic Recovery yet we see minimal investment in these. Lastly, for this section I’ll note that last year’s report highlighted some specific capabilities and provided some narrative and data on each, which, while it needed refinement, was a good direction for this report to go into. This year’s report dropped that depth of information completely.

The final section is Management Opportunities. The three opportunities identified in this section are:

  1. Building Community-Wide Resilience to Climate Change Impacts
  2. Reduce Physical and Technological Risks to Critical Infrastructure
  3. Increase Equity in Individual and Community Preparedness

I don’t argue at all with these three items, but the content, as usual, is lacking. What we should see here is a strategic approach to addressing these priority issues. Of course, to best do so, it would need to align with grant funding priorities and other efforts… which is something we’re just not seeing. They do provide some references and data within their analysis, but they do more for making a case for why these are priority issues and thumping their chest for what they have accomplished rather than laying a national roadmap for accomplishing these priorities. Reviewing last year’s management opportunities, I don’t recall many external products that really worked towards addressing these, nor does this year’s report reflect on any progress of these. Without doing so, this section is nothing but well-intentioned yet intangible statements.

My last statement pretty much sums up the entirety of the report… nothing but well intentioned yet intangible statements. This continues on a trend of previous National Preparedness Reports providing a few good data points but certainly NOT reporting on our nation’s preparedness in any meaningful, much less comprehensive, manner. I stand by my statements from last year that we, the emergency management community, should not be accepting this type of reporting. FEMA receives THIRA and SPR data from states, UASIs, and territories; all of which have years of legacy data. Similarly, FEMA receives regular reports on the grants they provide to jurisdictions, all with metrics that should tie back to a common foundation – the National Preparedness Goal’s Core Capabilities. Yet they fail every year to connect these dots and provide tangible, grounded reports with actionable recommendations. This effort, investment, and the FEMA Administrator’s endorsement is both disappointing and concerning. I continue to feel these reports do not meet the intent of the PPD8 requirements.

Happy New Year one and all!

© 2023 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

NIMS Change – Information and Communications Technology Branch

Tim Riecker, The Contrarian Emergency Manager 4 Comments

FEMA recently released a draft for the National Incident Management System (NIMS) Information and Communications Technology (ICT) guidance, providing a framework for incorporating ICT into the Incident Command System (ICS). The draft guidance in many ways formalizes many of the functional changes ICS practitioners have been incorporating for quite a while.

Essentially, the guidance creates an ICT branch within the Logistics Section. That branch can include the traditional Communications Unit as well as an Information Technology (IT) Service Unit. They also make allowances for a Cybersecurity Unit to be included the branch – not as an operational element for a cyber incident, but largely in a network security capacity. The creation of an ICT branch is also recommended for emergency operations centers (EOCs), regardless of the organizational model followed.

The IT Service Unit includes staffing for a leader, support specialists, and a help desk function, while the Cybersecurity Unit includes staffing for a leader, a cybersecurity planner, a cybersecurity coordinator, and a cyber support specialist. The position descriptions and associated task books are already identified pending final approvals and publication of this guidance, with the Cybersecurity and Infrastructure Security Agency (CISA) seemingly ready to support training needs for many of the new positions.

I’m fully in support of this change. FEMA is accepting feedback through October 20, 2022, with instructions available on the website provided previous.

Not being a communications or IT specialist myself, I’m interested in the perspectives of others on this.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Applying What We’ve Learned

Tim Riecker, The Contrarian Emergency Manager 2 Comments

The COVID-19 pandemic shattered so many of our planning assumptions. Not only assumptions on how a virus would act, spread, and react, but also assumptions on human behavior. Many of our plans accounted for security in the transportation and distribution of vaccines to address theft and violence caused by people who would commit these acts to get their hands on the vaccine (perhaps too many apocalyptic movies led us to this assumption?), we also falsely assumed that everyone would want the vaccine. The political divisiveness, faux science, misinformation, disinformation, and members of the public simply not caring enough for each other to take simple actions to prevent spread were largely unanticipated.

I think that had the virus been different, we would have seen things align better with our assumptions. Had the symptoms of the virus been more apparent, and had the mortality rate been higher, I think we would have seen more people wanting to protect themselves and each other. Would this have been fully aligned with our earlier assumptions? No. I think that we’ve learned that human behaviors aren’t as easy to generalize, but also the societal and political climate we are in, not just in the US but in many other nations around the world would have still perpetuated many of the problems we have and continue to see during the COVID-19 pandemic.

Where to from here? I’m not a sociologist, but I’m a firm believer that much of what we do in emergency management is rooted in sociology. I’m sure an abundance of papers have already been authored on sociological and societal behaviors during the pandemic, with many more to come. I’m sure there are even some that are aligned to support and inform practices of emergency management, with valuable insights that we can use in planning and other activities. I look forward to having some time to discover what’s out there (and always welcome recommendations from colleagues). Speaking of implementation, what I do know is that we shouldn’t necessarily throw away the assumptions we had pre-COVID-19. Most of those assumptions may still be valid, under the right circumstances. The challenge is that there are many variables in play that will dictate what assumptions will apply. We do need to learn from what we have/are experiencing in the current pandemic, but this doesn’t hit the reset button in any way. This doesn’t necessarily invalidate what we thought to be true. It simply offers an alternative scenario. The next pandemic may yet align with a third set of truths.

While it makes things much more complex to not know which assumptions we will see the next time around, at least we know there are a range of possibilities, and we can devise strategies to address what is needed when it’s needed. What also adds complexity is the reinforcement of plans needing to be in place for various aspects of a pandemic and written to an appropriate level of detail. Most pandemic plans (and other related plans) that were in place prior to the COVID-19 pandemic simply weren’t written to the level of detail necessary to get the job done. Yes, there is a matter of variables, such as assumptions, but the fundamental activities largely remain the same. As with many disasters, jurisdictions were scrambling to figure out not only what they needed to do but how, because their plans were written at too high a level. As always, we are challenged to ensure the right amount of flexibility in our plans while still providing enough detail.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Putting Together an Emergency Plan That’ll Prepare You for When Disaster Strikes

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Back in April of 2020, Carla Lopez guested on my blog, writing Thriving After Your Small Business Closes, which gave some tips for dealing with the hard truths many small businesses experienced during the pandemic. Carla has returned with a new post about emergency planning with an eye on small businesses. My thanks to Carla for referencing EPS in her article! – TR

About Carla – Carla Lopez kept her entrepreneurial spirit even after retiring a couple years ago. She created Boomerbig.org for retirees who still desire to work and achieve – a site that offers business resources for people in their golden years.

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As per the news reports, it’s become more and more apparent that natural disasters are occurring more frequently than ever before, largely in part due to climate change. As such, one can never be too prepared if a natural disaster should happen to you and your family. Here are some tips from Emergency Preparedness Solutions on how to prepare for the worst.

Keep on top of the potential hazards that could occur in your area

Because natural disasters are so varied in nature, ranging from tornadoes to earthquakes to flooding, it makes sense, then, to keep on top of the potential hazards that are unique to your area.

Stock up your disaster kit

Make sure to stock up on a disaster supply kit that’s ready to go at all times. Basically, this kit should include the most essential items that will keep you going for at least a few days should things suddenly come to a complete standstill. Items that you should pack ahead of time in one or two backpacks should include important documents such as your identification documents, insurance policies, passports, medical records, etc. And be sure to pack them away in such a way that it is safe from water damage. Other essential items to think about include a pair of spare clothing, toiletries, chronic medication, extra cash, sleeping bags, a first aid kit, etc.

Plan your escape route

SafetyCulture points out that you should establish an evacuation plan for every eventuality or for what’s most applicable to your country’s most probable disaster. In it, you could include details pertaining to where you would find the most protection in your home in the case of a tornado, how to find your quickest route out of the home in the case of a fire, and alternative routes out of your town if you had to evacuate quickly and the main roads were no longer accessible.

Protect your business

Make sure to confirm with your insurers that your home business will also be covered by your homeowner’s insurance policy should your home be destroyed in a natural disaster. And if your current insurance policy isn’t designed to protect your business assets if you work from home, then be sure to find out what will be by getting a policy that’s specifically for your business. Or if you would prefer to group everything under a single policy, you could try to get an endorsement on your existing policy to include cover for your home office.

Stay in touch-always

In the case of a natural disaster occurring, you should establish multiple ways of staying in contact with your loved ones if the signal is down, such as making use of a central point of contact who can vouch for your whereabouts if your family or friends can get a hold of you and vice versa.

Make a plan for your beloved animals too

If you’re a pet lover, you wouldn’t dream of leaving your pets behind in the midst of grabbing your essentials and rushing out the door to safety. That’s why it is also important to plan what the safety steps would be for your pet, too.

Familiarize yourself with the processes

You should also ideally practice the steps covered in the plan beforehand so that when the time comes it is instinctual as opposed to chaotically looking for solutions, which can lead to catastrophic mistakes at a time when your mind has to be at its clearest.

In summary

You can never be too prepared for the unexpected when the unexpected is what we’ve come to expect. Therefore, having a well-thought-out plan in place that can help to prepare you for every outcome is a great place to start when you’re faced with a scary event that’s beyond your control.

Image via Pexels

The Value of a Plan

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Lately I’ve seen things circulating yet again which reflect on the old adage, one I’ve even used myself, that ‘plans are worthless, but planning is everything’. I believe this original quote is credited to Dwight D. Eisenhower, though the quote has been paraphrased and altered through the years. A point being made by this quote is that there is great value in the process of planning. The coordination between parties. The effort put into considering strategies and analyzing variables. Meeting people at the planning table for the first time instead of the heat of battle (or a response). And that such activity can have greater value than the documented outcome.

In recognition of these points, and with all due respect to Ike, I’ve grown tired of this quote and all derivations thereof. Why? Because plans are NOT worthless.

Oh, don’t get me wrong, plans CAN be worthless. I’ve seen plenty that fit this definition. But to lay a blanket over all plans, I think is an overgeneralization. In fact, it’s rather insulting to the time and effort put forth by the planning team and the plan writers and an insinuation of a waste of funds which may have been spent to support the process. If your plan is really that worthless, this is likely to be a reflection of a terribly executed planning process – which then really negates the spirt of the quote in the first place.

Yes, there is great value in the planning process WHEN DONE PROPERLY. But a well-executed planning process should also bring about a valuable plan. While I’ve never seen a plan address all circumstances of an incident with even moderate complexity, a well written plan should get you most of the way there. It should also lay the groundwork for getting you the rest of the way through moderate deviations from the plan and some improvisation. If you think of your plan as a roadmap, you need to anticipate and plan for the potential for multiple detours, GPS outages, potty breaks, and a flat tire or two. It’s a fundamental principle of emergency management that we need to expect the unexpected, which makes the unexpected not so unexpected after all.

If you approach planning with the anticipation that an incident will force you to deviate from your plan, accommodate that in the plan. As I’ve told people for years, don’t plan yourself into a corner. Give yourself outs. Identity contingencies and alternate strategies. Even if you don’t plot the entirety of the detour, identify the exits and give guidance for how the unknown might be navigated. Extreme detail for all possible alternatives will give us plans with hundreds or thousands of pages which no one will ever use.

Speaking of using plans, the disuse of plans might actually be the largest failure. It’s unfortunately a rare occasion I’ve ever seen anyone reference a plan during a response. A very early question should be ‘what does the plan say?’. We need to analyze our current circumstances and see how they apply to the plan assumptions, then use the guidance formulated in the plan the best way possible. For more on emergency planning, check out this post authored by me and this one authored by Ashley Morris.

© 2022 Tim Riecker, CEDP

Emergency Preparedness Solutions, LLC®

Bring MAC Back

Tim Riecker, The Contrarian Emergency Manager Leave a comment

Multi Agency Coordination, or MAC, is a concept most frequently applied to incident management. MAC Groups are the most commonly defined, being a collection of executives from various agencies, organizations, and/or jurisdictions who may commit the resources of their respective agencies, and often provide high-level decision-making and policy coordination to support an incident. Multi Agency Coordination Systems (MACS) have also been commonly defined, essentially as the combination of resources assembled to support the implementation of multi agency coordination. Multi agency coordination, as a concept, however, transcends MAC Groups and MAC Systems. In incident response we see multi agency coordination occur at the field level and in emergency operations centers (EOCs), the latter of which is generally viewed as an operational extension of the MAC Group. We even see the concept of multi agency coordination specifically extended into Joint Information Systems and Joint Information Centers. Multi agency coordination can and often does also exist across all phases and mission areas associated with emergency management. This is simply a reinforcement that emergency management is a team sport, requiring the participation and input of multiple organizations before, during, and after a disaster as well as in steady-state operations. MAC can be applied in many effective ways to support all of this.

But where did MAC (the more formal version) go? MAC was one of the foundational aspects of the National Incident Management System (NIMS) at one time. But now if you look for information on MAC, you will be pretty disappointed. The NIMS doctrine provides barely a single page on MAC, which might be fine for a doctrinal document if there were supplemental material. Yet, when looking through FEMA’s page for NIMS Components, there are no documents specifically for MAC. There used to be a pretty decent independent study training course for MAC, which was IS-701. That course, and the materials provided, no longer exist as of September 2016. (side note… lots of states and other jurisdictions assembled NIMS Implementations Plans. Many of those have not been updated in years and still reference this as a required training course). You will find only scant references to MAC in some of the ICS and EOC courses, but not with the dedicated time that once existed.

So why is this a problem? MAC as a concept is still alive and well, but without doctrine, guidance, and training to reinforce and support implementation, it will fall into disuse and poor practice. Just in the past two weeks alone, I’ve had direct conversations about MAC with three different clients: one in regard to a state COVID AAR; the other for all hazard planning, training, and exercises; and the other for state-level coordination of a response to invasive species. Superficially, MAC seems an easy concept. You get a bunch of executive-level stakeholders in a room, on a call, or in a video chat to talk about stuff, right?  Sure, but there are right and wrong ways to go about it and best practices which should be embraced. There is no single true model for MAC, which is appropriate, but absent any reasonable guidance, MAC may be misapplied, which could become an impediment to a response – something we’ve certainly seen happen.

All that said, we need to bring significant MAC content and guidance back. One of the better resources I’ve found out there comes from Cal OES. It’s a bit dated (2013) but still relevant. While it does have some language and application specific to California, it is an all-hazards guide (actually adapted from a wild-fire oriented FIRESCOPE document). The document is good, but I’d like to see a national approach developed by FEMA (properly the National Integration Center). MAC is an incident management fundamental, with application even broader than response. Their importance for response, especially larger more complex incidents, is huge, yet the information available on MAC is fairly dismissive. While some content exists in training courses, most of the courses where the content is found are not courses which many MAC Group members would be taking. We must also not confuse training with guidance. One does not replace the other – in fact training should reflect guidance and doctrine.

© 2022 Tim Riecker, CEDP – The Contrarian Emergency Manager

Emergency Preparedness Solutions, LLC®

Vulnerable Populations Behind Walls

Tim Riecker, The Contrarian Emergency Manager 4 Comments

There is finally meaningful and productive discussion and actions in emergency management circles about vulnerable and under-served populations. It’s a step in the right direction, though still has a long way to go, with many concerns yet found in regulation and bias which must be identified, assessed, and changed. There are, however, other vulnerable populations which are rarely spoken of – those behind walls. These are persons incarcerated in prisons and jails, those receiving mental health treatments at in-patient facilities, and those with physical and cognitive disabilities in group residential settings. Hospitals and nursing homes also have vulnerable populations in this regard, and while concerns still exist and progress must yet be made, these facilities seem largely to have made more progress than others when it comes to disaster preparedness for their facilities and those in their care.

Populations behind walls are often forgotten during disasters, either because it is assumed they are someone else’s responsibility, or because the facility itself seems to be overlooked as a part of the community. People also tend to have biases toward the populations of these facilities – especially jails and prisons; though plenty of bias also exists against those receiving mental health treatment and those with physical and cognitive disability. We also likely have subconscious impressions of the facilities themselves, especially larger jails and prisons, being physically formidable and resilient, therefore having less vulnerability to certain disasters. While that may be true for some hazards, it’s certainly not true for all. Rarely do we find these facilities identified in emergency operations plans, much less addressing the potential needs of their residents during disasters. These facilities, and their residents, are still part of your community.

Specific to prisons, the GAO recently cited the Federal Bureau of Prisons for lack of consistent data in this regard, and the National Institute of Prisons posted a paper published in December 2013 by Northeastern University which states that “prisons are not prepared to respond to and recover from disasters.” and that prisoners “seem to be a forgotten subset of our population when it comes to emergency management.” In fact, according to the Northeastern University paper, while the Federal Bureau of Prisons provides guidance and tools to support emergency management, they have few requirements.

Certainly, there are challenges associated with all these facilities, particularly in regard to emergency management; and I don’t envy the responsibility the owners and operators (sometimes government, sometimes private or non-profit) have for ensuring the wellbeing of residents. Facilities are generally more concerned with security and routine safety risks than disasters. Residents of all these facilities are, even if temporarily, wards of these facilities, with the owners and operators of these facilities being legally responsible for their protection and wellbeing.

One of the bigger concerns for any of these facilities is movement of residents. Relocating a number of residents within the same facility can be a significant enough challenge, but this pales in comparison to evacuating the entire population. That said, no one ever properly labeled emergency management as being ‘easy’. Movement of residents is only one of many concerns, however, as the residents have the same needs as any other people in our communities during a disaster. Staff must also be protected, and in times of disaster continuity of operations can also be a significant concern for these facilities if staff are not able to get to work.

What to do? Certainly, appropriate regulators and those having legal authority over these types of facilities need to reaffirm any existing requirements and move to create (and enforce) requirements where gaps exist. This would be the top-down approach. While I think we’d like to see owners and operators assume the responsibility themselves, that’s much less likely to happen due to costs. I think there is also an opportunity for emergency management to influence this. We should see state emergency management officials, especially State Directors, working with their governors and appropriate state agencies to influence change. Local emergency managers, likewise, should be reinforcing these needs to State Directors and elected officials, while also working with the facilities themselves to open communications and begin partnerships. Emergency management revolves around partnerships and addressing issues should always begin with a conversation.

When a gap is left untended, the consequences are not only borne by those directly responsible, but also by communities. If a facility is impacted by a disaster, the consequences may fall to the community to address. These types of facilities MUST undergo regular assessments, mitigate hazards, and appropriately prepare for all hazards. The communities they are in MUST be part of the process, likewise the facilities should also participate in these efforts with their communities. The sharing of information is critical for these efforts to be successful.

How is your relationship with these types of facilities in your community?

© 2022 Timothy Riecker, CEDP

Emergency Preparedness Solutions, LLC®